Audit, Compliance and Risk Blog

What is TENORM?

Posted by Rebecca Luman on Tue, May 24, 2016

Every place on Earth has at least a little radioactivity. It is found in bodies, food (not just in industrially irradiated food), the ground, and in many consumer products. The sun and outer space are sources of radiation. Radioactive materials prevalent in nature, such as those present in soils and rock formations and in the water that comes into contact with them, are called naturally occurring radioactive materials, or NORM. NORM typically does not present a problem to human health or the environment, as the radiation levels are very small, and there is generally not an exposure pathway. However, NORM can become concentrated as the result of certain human activities that also expose people and the environment to radiation hazards. Over time, this collection of individual concentrations/exposures has come to be regarded as part of a single, larger, and more complex problem—radiation contamination—referred to as TENORM (tee-norm).

EPA has identified a variety of naturally occurring materials that, when concentrated as the result of some type of human activity, exposes people and the environment to radiation hazards, generate TENORM. Certain industrial sectors, such as mining and resource extraction, energy production, drinking water and wastewater treatment, generate TENORM as a result of their processes. TENORM can also be found in consumer products, such as antiques, phosphate fertilizer, building products and tobacco. In addition, radon, a naturally occurring radioactive gas found in soils, rock, and water throughout the U.S., can be concentrated due to industrial activities. It can also become TENORM simply by the addition of structures or wells in areas with elevated radon levels that serve as conduits for the radon to concentrate, providing an exposure pathway for humans and the environmental.

TENORM is found in all 50 states—basically anywhere processes that generate it take place. While identifying TENORM is not specifically identified in the environmental site assessment (ESA) process, as with any type of site contamination, existing, undetected TENORM can become a liability to purchasers and lenders involved in a property transaction. Purchasers, lenders, and consultants working toward a property transaction where TENORM contamination is possible should take steps to ensure that TENORM is addressed adequately during the overall site assessment process. The parties involved should reach a written agreement on the level of TENORM assessment to be included in each phase of ESA, and information on this type of contamination investigated and reported in the same way that other types of contamination are investigated and reported.

EPA has recently updated its radiation control, TENORM, and radon websites to provide the latest information, regulations, and guidance on understanding their impacts on human health and the environment. For more information, see the following websites:

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Tags: Audit Standards, Health & Safety, Environmental risks, Environmental, EHS

Protecting Employees Against The Zika Virus

Posted by Jon Elliott on Tue, May 17, 2016

The first significant outbreak of the mosquito-borne zika virus in the Americas was announced in Brazil in May 2015. Public health officials in the United States began to prepare responses, and have accelerated efforts in reaction to reports that the virus is spreading into U.S. territories, beginning with Puerto Rico and Florida and expanding northward. Late in April, the Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) entered the fray, by issuing joint “Interim Guidance for Protecting Workers from Occupational Exposure to Zika Virus.” The rest of this note summarizes that Guidance.

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Tags: Employer Best Practices, Health & Safety, Employee Rights, EHS

Protecting Employees Against Bloodborne Pathogens

Posted by Jon Elliott on Tue, May 10, 2016

The Occupational Safety and Health Administration (OSHA) requires employers to protect their employees against possible exposure to “bloodborne pathogens (BBPs).” OSHA’s Bloodborne Pathogen Standard prescribes protections for workers occupationally exposed to blood or other potentially infectious materials (OPIM). Healthcare workers are the most obvious beneficiaries, but emergency responders and others may also be regularly at risk to these exposures.

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Tags: Employer Best Practices, Health & Safety, OSHA, Employee Rights, Environmental risks, EHS, Hazcom, pharmaceuticals

Employee Suspension: A Legitimate Disciplinary Measure?

Posted by STP Editorial Team on Thu, May 05, 2016

Supreme_Court_Canada_cropped.jpgIf you are an employer and are considering using suspension as a disciplinary measure, be aware that the Supreme Court of Canada has indicated that employers do not have unfettered authority to withhold work from their employees and that legitimate business reasons must be shown in the context of any administrative suspension. Absent such reasons, an administrative suspension—even with pay—may be found to be a constructive dismissal.

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Tags: Business & Legal, Employer Best Practices, Employee Rights, Canadian

Can a Hospital Be Both Hygienic and Environmentally Sustainable?

Posted by Jane Dunne on Mon, May 02, 2016

When it comes to hospitals we all expect the highest standard of cleanliness and yet, we want every part of our lives to be more sustainable. Of course, when hospitals are faced with a choice that puts hygiene up against sustainability, hygiene always wins. But I wonder if it’s possible to find ways for both to win?

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Tags: Health & Safety, Environmental risks, Environmental, EHS, EPA, sustainability

Stormwater Regulation Basics: What is Required?

Posted by Jon Elliott on Tue, Apr 26, 2016

The Clean Water Act’s (CWA’s) national water quality purview includes National Pollutant Discharge Elimination system (NPDES) provisions for “stormwater” that may contain pollutants such as oil, industrial contaminants, and sediment. This means run-off of rain or snow melt containing pollutants from manufacturing, processing, or raw material storage areas at an industrial site, that passes through a “conveyance” (such as a storm drain) into waters of the United States. The Environmental Protection Agency (EPA) administers or delegates permit programs covering discharges from the following:

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Tags: Environmental risks, Environmental, EHS, EPA, Hazcom, Stormwater

DOT Requirements For Hazmat Transport Permits

Posted by Jon Elliott on Tue, Apr 19, 2016

The U.S. Department of Transportation (DOT) defines national requirements for the transportation of hazardous materials, under what’s commonly called the Hazardous Materials Transportation Act (HMTA). DOT agencies promulgate most regulatory requirements with nationwide applicability, and delegate most administrative and oversight responsibilities to state transportation and highway patrol agencies. Delegated functions include state-level registration of motor carriers that transport hazardous materials by roadways, and licensing for their drivers.

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Tags: Health & Safety, Environmental risks, Environmental, Hazcom, Transportation

Oil Companies Must Let Shareholders Vote To Expand Reporting Relevant To Climate Change

Posted by Jon Elliott on Thu, Apr 14, 2016

In recent years, activist investors have sought to expand climate-related reporting by publicly traded companies – directly by pressuring the companies, and indirectly by petitioning the U.S. Securities and Exchange Commission (SEC) and other regulators to require additional reporting in periodic reports on the businesses’ status and prospects, and in annual meeting reports and proxy requests. SEC has been criticized for doing very little in response to these requests, but took potentially important actions on March 23.

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Tags: SEC, EHS, Oil & Gas, directors, directors & officers

OSHA Expands Regulation Of Crystalline Silica

Posted by Jon Elliott on Tue, Apr 12, 2016

The US Occupational Safety and Health Administration (OSHA) regulates thousands of chemicals, through regulatory standards directing employers to reduce worker exposures. At the broadest level, employers must evaluate basic information about every potentially hazardous chemical, and provide information to employees in compliance with OSHA's Hazard Communication Standard (I’ve blogged about changing HCS requirements here, and here). OSHA’s Air Contaminants Standard provides ambient workplace air limits for hundreds of listed contaminants. OSHA also provides more tailored requirements for classes of chemicals (such as flammables), and for types of activities that pose chemical hazards (such as welding). For a small number of especially hazardous chemicals, OSHA provides a detailed standard applicable to a single chemical—examples include asbestos, benzene, and lead. On March 25, 2016, OSHA established another single-chemical standard, for respirable crystalline silica (29 CFR section 1910.1053). Most affected employers must comply by June 23, 2018; a few provisions are phased in later, and construction employers must meet most requirements by June 23, 2017.

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Tags: Health & Safety, OSHA, EHS, Hazcom

Emissions in the Shipping Industry: Who Is Steering the Ship?

Posted by Jane Dunne on Tue, Apr 05, 2016

You might ask how it is possible that there is no direct mention of the shipping industry in the Paris Agreement at COP21. Many people wonder just how much air pollution is created by the shipping industry and who is working to improve this mysterious source of greenhouse gas emissions?

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Tags: EHS, Greenhouse Gas, ghg, Hazcom

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