Audit, Compliance and Risk Blog

EPA Adopts Pharmaceutical Waste Management Requirements

Posted by Jon Elliott on Tue, Mar 12, 2019

After a long rulemaking, the US Environmental Protection Agency (EPA) has just promulgated rules defining certain waste pharmaceuticals as “hazardous wastes” under the Resource Conservation and Recovery Act (RCRA), and establishing standards for their management by selected healthcare and “reverse distribution” waste management facilities. These regulations replace general RCRA generator and treatment requirements otherwise applicable to hazardous wastes.

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Tags: Health & Safety, EPA, Hazcom, RCRA, pharmaceuticals

Keeping Safe in Winter Weather

Posted by Jon Elliott on Tue, Feb 05, 2019

Even if the latest polar vortex has ended by the time you read this, employers in most parts of the continent should be worrying about protecting workers against winter weather. Occupational safety and health regulators include “environmental” hazards as those that may require employers to provide their employees with personal protective equipment (PPE), and employers also bear a “general duty” to protect workers against recognized hazards. These requirements cover potential harm from extreme temperatures including cold, as well as slippery surfaces and other hazards from frozen and melting snow or other precipitation.

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

Is Your Workplace Injury and Illness Log Ready for Compliance with OSHA Requirements?

Posted by Jon Elliott on Thu, Jan 31, 2019

The Occupational Safety and Health Administration (OSHA) requires employers to prepare and maintain records of occupational injuries and illnesses (I&I Logs) as they occur. OSHA also requires employers to post an annual I&I Summary in each “establishment” within their workplace by February 1, summarizing that workplace’s I&Is during the previous calendar year. In states that administer federal standards within state-run programs, employers follow the comparable state requirements. Establishments with 250 or more workers must file electronic summaries by March 2.

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Tags: Business & Legal, Health & Safety, OSHA, Workplace violence

California Requires Pharmaceutical and Sharps Waste Stewardship

Posted by Jon Elliott on Tue, Jan 29, 2019

Beginning January 1, 2019, a new California law establishes extensive requirements for proper management of waste pharmaceuticals and “sharps.” These new provisions complement – but aren’t actually well-connected to -- medical waste management requirements (I outlined typical state-based requirements here), and workplace provisions to protect workers from “bloodborne pathogens” that may be present because of health and medical procedures and the wastes they generate (I discussed OSHA’s “BBP” Standard here). The rest of this note summarizes these new requirements, adopted by Senate Bill (SB) 212 (Jackson).

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Tags: Health & Safety, California Legislation, Environmental risks, Environmental, Hazcom, pharmaceuticals

EPA Will Aggregate “Substantially Related” Activities When Considering “Project” Thresholds For Pre-Construction Permit Review

Posted by Jon Elliott on Tue, Jan 15, 2019

If you’re contemplating significant changes at a facility that’s regulated as a “major source” under the Clean Air Act (CAA), you’d better figure out whether those changes will “modify” the source enough to trigger significant pre-construction review and permitting by the US Environmental Protection Agency (EPA) or its state or local delegee. The likely answer to questions like yours has changed with CAA amendments and regulations over the decades. EPA has just changed them again, after ending a decade long year delay of a regulatory “interpretation” published in the last week of George W. Bush’s presidency, and stayed by the Obama-era EPA throughout his presidency, and now reaffirmed and activated by the Trump-era EPA.

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

Protecting Workplaces From Combustible Dust

Posted by Jon Elliott on Tue, Nov 20, 2018

On October 24, the US Chemical Safety and Hazard Investigation Board (which uses the truncated acronym CSB) issued a “Call to Action: Combustible Dust” seeking information about what it has long considered a major industrial hazard. Since 1980 CSB has identified hundreds of industrial accidents involving dust that have injured nearly 1000 workers and killed more than one hundred. In 2006 CSB issued 4 formal recommendations to the Occupational Safety and Health Administration (OSHA) to enhance that agency’s regulation of occupational hazards from combustible dust – particularly from possible fires or explosions, with mixed responses.

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

Are My Machines Guarded To Prevent Injuries?

Posted by Jon Elliott on Tue, Nov 06, 2018

The Occupational Safety and Health Administration (OSHA) and state worker protection agencies require employers to “guard” moving portions of machines and powered equipment, to prevent entanglements, pinches and amputations. OSHA sets general requirements for machine guarding under its Machine Guarding Standard, plus specific requirements for six different types of equipment in separate standards.

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

Finding and Correcting Workplace Mold Infestations

Posted by Jon Elliott on Tue, Oct 23, 2018

Summer brought its inevitable share of rain, and even flooding and hurricanes in some places. Residual moisture increases the possibility of mold infestations, which might endanger people in your workplace. The Occupational Safety and Health Administration (OSHA) and state worker protection agencies have longstanding information and recommendations to employers for finding, evaluating and eradicating mold infestations in their workplaces. Recently, the Environmental Protection Agency (EPA) has just updated its mold cleanup as part of its broader initiatives to help employers plan for floods and hurricanes (I wrote about updated hurricane information here). EPA’s approach is narrower than OSHA’s, since it focuses on post-incident activities.

Organizations with facilities that may be subject to routine water infiltration or leaks, or sudden flooding from hurricanes or other events – should consider both sets of information.

Mold Basics

Molds and other fungi are both ubiquitous and plentiful--they have been estimated to make up a quarter of all the biomass on the planet. Molds are found almost everywhere, and can grow on just about any surface, as long as moisture and oxygen are available.

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

The Unexpected Benefits of Walking to School

Posted by Jane Dunne on Thu, Sep 20, 2018

Remember when splashing through puddles, collecting pretty-coloured leaves and deciding to keep a caterpillar for a pet were part of getting to and from school? Imagine all that you would have missed if your walk to school as a kid had been replaced with a sterile car ride. October is International Walk to School month (iWalk) and that has got me thinking…

Could Walking Boost Creativity?

Friedrich Nietzsche once said, “all truly great thoughts are conceived while walking” and many of the world’s greatest thinkers have recognized the power of a walk to spark new ideas and thoughts. Charles Dickens felt that walking enabled him to develop novel ways to write and some say that his walking stick was almost as important for his writing as his pen. (Charles Dickens Museum) A Stanford study has confirmed this belief and found that walking does boost creative inspiration. According to the study, creative output increases by an average of 60 percent when a person is walking. (Stanford News) Apparently, even after a walk, creative juices continue to flow, which is great for kids just arriving at school.

Exercise for Life

Setting up good habits when a child is young can translate into an active teen and adult life. Being driven to school each day contributes to sedentary behaviors and since much of the day is spent sitting in a classroom, an opportunity to be active while walking to school can help to develop life-long patterns of choosing exercise. Canadian Physical Activity Guidelines recommend that kids aged 5 to 11 get at least 60 minutes of moderate- to vigorous-intensity exercise every day. (For details on these guidelines, see Canadian Physical Activity Guidelines.) 

Clearing the Air

Car fumes are not healthy for anyone, but the one place that really should not have exhaust surrounding it is your local school. University of Toronto assistant professor, Matthew Adams, recently found that school kiss-and-ride drop-off zones are exposing children to increased levels of air pollution (see U of T News.)  Knowing that your family has chosen to walk, and is not contributing to poor air quality around schools by driving a short distance and then idling, is empowering. The morning walk to school is a chance for students to breathe fresh air and means that kids arrive at school feeling more alert and able to learn.

Street Smarts

Many parents find that letting their kids walk to school helps kids to learn how to be responsible and to make decisions by themselves. Walking or biking to school is a great way to improve academic performance. A recent study found that children who exercise have more brain power. Researchers were able to show that physical activity can actually increase the size of children’s brains and that kids who are physically fit have a greater volume of grey matter in the frontal and temporal regions and the calcarine cortex, all of which are important for learning, motor skills and visual processing. (For more information, see Brain Power.) 

Why Wouldn’t Kids Walk to School?

Some parents tell themselves that driving the kids to school is what is best for safety, but who is this really best for? When you consider that children are at a greater risk of injury in a car than while playing or walking, you really can’t put safety forward as the reason to drive them to school.

One fear that parents have is that their child will be kidnapped. Kidnappings are incredibly rare, but parents don’t want to be that 1 in 14 million, even though limiting their child’s independence is an expected outcome of not allowing them to experience the world on their own. A good way to quash this particular fear is to find a group of kids that can walk to school together. Set up rules on how everyone sticks together and no one is left behind. (For ideas on starting a walking school bus in your area, see Walking School Bus.) 

Getting Involved

For those of you living in British Columbia, you can register a school to participate in the Walk and Wheel to School event (October 1 – 5th 2018) with the Directorate of Agencies for School Health (DASH BC). (See DASH BC for more information.)

Jane Dunne is a Senior Editor for Specialty Technical Publishers. She works on a diverse catalogue of environmental publications that are recognized across North America as effective tools to ensure regulatory compliance with complex requirements.

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

Circuit Court Ends a Decade of Delay by Ordering EPA to Cancel a Hazardous Pesticide

Posted by Jon Elliott on Tue, Sep 18, 2018

The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) empowers the Environmental Protection Agency (EPA) to define and regulate pesticides meeting statutory qualifications, providing extensive procedural directions how to do so. In addition, the Federal Food, Drug, and Cosmetic Act (“FFDCA”) authorizes EPA to regulate the use of pesticides on foods according to specific statutory standards, and grants EPA limited authority to establish tolerances for pesticide residuals on foods. These directions govern EPA’s analyses of applications for registration, ongoing evaluations of evolving scientific understanding and practical experience with pesticides that have been registered, and response to public comments and petitions (I provided a basic summary of FIFRA registration procedures here).

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