Audit, Compliance and Risk Blog

California Adopts Workplace Violence Prevention Requirements For Health Care Facilities

Posted by Jon Elliott on Thu, Feb 09, 2017

Health care and social service workers suffer workplace violence at much higher rates than in most other sectors, because of the higher risk from their patients and clients. In response, worker protection laws and regulations have begun to require workplace violence prevention in these sectors. The California Occupational Safety and Health Standards Board (OSHSB) just adopted a new regulation, implementing 2014 legislation that expands state requirements for hospital security plans, to include specified workplace violence prevention programs. Compliance begins in phases during 2017-2018, and will be administered by the Division of Occupational Safety and Health (Cal/OSHA)).

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Tags: Employer Best Practices, Health & Safety, OSHA, Employee Rights, Workplace violence

OSHA Revises Walking, Climbing and Fall Protection Standards – Part 2 (Protective Systems and Training)

Posted by Jon Elliott on Tue, Jan 31, 2017

The Occupational Safety and Health Administration (OSHA) has issued massive revisions to its regulations requiring most employers (“General Industry”, in OSHA parlance), to protect employees from slip and fall hazards in most workplace contexts, including:

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

OSHA Revises Walking, Climbing and Fall Protection Standards – Part I (Surfaces and Pathways Between Levels)

Posted by Jon Elliott on Mon, Jan 23, 2017

The Occupational Safety and Health Administration (OSHA) has issued massive revisions to its regulations requiring most employers (“General Industry”, in OSHA parlance), to protect employees from slip and fall hazards in most workplace contexts, including:

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

U.S. Environmental Regulatory Trends at the Close of the Obama Administration

Posted by Larry Cahill on Thu, Jan 19, 2017


“The care of human life and happiness, and not their destruction, is the first and only object of good government.”

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Tags: Business & Legal, Health & Safety, Environmental risks, Environmental, EPA

The US Green Building Council’s New LEED v4 Rating System

Posted by Rebecca Luman on Thu, Dec 15, 2016

The US Green Building Council (USGBC), founded in 1993, is a consensus-based nonprofit organization with more than 12,000 national members representing the entire building industry. USGBC plays an important role in providing leadership and integration for the building industry in driving sustainable building.

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Tags: Health & Safety, Environmental risks, Environmental, EHS, RCRA

Nanotechnology Workplace Safety

Posted by Jon Elliott on Tue, Dec 06, 2016

As entrepreneurs commercialize “nanomaterials”, occupational safety and health (OSH) agencies and professionals are developing standards to evaluate and manage the associated hazards. These protective efforts cover the full range of OSH agency efforts. The easiest step is to expand application of the Employer’s General Duty to protect workers against workplace hazards to cover nanomaterials –easiest since this Clause requires employers to take steps against “recognized” hazards, and do not bind the agencies to promulgate specific standards (I’ve written about the General Duty Clause here, and about recommendations for comprehensive safety and health programs here). At the other extreme, the Occupational Safety and Health Administration (OSHA) or other OSH agencies can issue enforceable OSH standards –so far there are none exclusively addressed to nanomaterials, although some materials do trigger some standards (see below). Between these extremes, agencies can and do offer non-mandatory but detailed guidelines for some hazards – the National Institute for Occupational Safety and Health (NIOSH) just issued such a guide for nanomaterials, building on similar publications by other agencies. The rest of this blog discusses the new NIOSH guide, “Building a Safety Program to Protect the Nanotechnology Workforce: A Guide for Small to Medium-Sized Enterprises” (NIOSH Guide), and references some of resources used to produce them.

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Tags: Employer Best Practices, Health & Safety, OSHA, Employee Rights, EPA

OSHA Revised Safety and Health Program Guidelines

Posted by Jon Elliott on Tue, Nov 15, 2016

On October 18, the Occupational Safety and Health Administration (OSHA) issued “Recommended Practices for Safety and Health Programs” (Recommendations) – which revises its 1989 “Safety and Health Program Management Guidelines” (S&H Guidelines). As the name indicates, these recommendations suggest activities employers should undertake to ensure their employees’ safety and health. They are not regulations or other requirements, but the 1989 Guidelines have long been used by agency inspectors and onsite S&H personnel as generally applicable roadmaps to safer workplaces. This month’s revision end a review process that included a proposal and request for comments published in November 2015 (I blogged about the proposal here).

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

OSHA Proposes Technical Changes To Dozens Of Requirements

Posted by Jon Elliott on Tue, Nov 08, 2016

The Occupational Safety and Health Administration (OSHA) has proposed to update and/or clarify dozens of provisions in its regulatory standards, within its General Industry, Construction, and Shipbuilding Standards, as the latest round in an ongoing “Standards Improvement Project.” The proposals were published in the October 4 edition of the Federal Register, and comments are due by December 5. Depending on the comments (and perhaps on the outcome of the Presidential election), OSHA plans to finalize changes early in 2017.

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

U.S. Commission on Civil Rights Criticizes EPA’s Environmental Justice Efforts

Posted by Jon Elliott on Tue, Oct 18, 2016

In September 2016, the U.S. Commission on Civil Rights (Commission) issued its annual “Statutory Enforcement Report for 2016”; this year’s topic is the Environmental Protection Agency’s (EPA’s) efforts to protect and promote “Environmental Justice.” The Commission reviews decades of EPA efforts, and criticizes longstanding inadequacies.

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Tags: Health & Safety, Environmental risks, Environmental, EPA, ghg, Hazcom, RCRA

EPA Establishes Formaldehyde Limits For Composite Wood Products

Posted by Jon Elliott on Tue, Aug 30, 2016

EPA has just issued final rules to limit exposure to formaldehyde emissions from plywood and other laminated and composite wood products. The Formaldehyde Emission Standards for Composite Wood Products Act of 2010 (“the Act”, which is codified as Title VI of the Toxic Substances Control Act (“TSCA”)) required EPA to develop these rules. The Act responded to evidence of dangerous emissions from substandard construction products, publicized particularly by health hazards in temporary trailers provided by the Federal Emergency Management Agency (FEMA) to victims of Hurricane Katrina and other natural disasters. The Act established standards based on California rules, and directed EPA to issue nationwide rules by January 1, 2013 to enforce these standards. EPA missed its deadline, but has just announced rules that will become effective after publication in the Federal Register (probably in August 2016).

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