Audit, Compliance and Risk Blog

You May Be Getting More Labeling Information Soon

Posted by Jon Elliott on Tue, Oct 03, 2017

One of California’s longstanding amplifications of national environmental health and safety (EH&S) programs is provided by “Proposition 65.” I summarized these provisions here. As I described, the main thrust of this 1986 state enactment is to provide warnings about potentially hazardous chemicals, to customers, workers, and other “potentially exposed individuals." Prop 65 provides sample texts for warnings, including “safe harbor” text for product labels and in-store signage. After 30 years, the state is revising these safe harbors to be more informative. Revised safe harbor text became available for use August 30, 2016 and replace their expiring predecessors on August 30, 2018. Since we’re half way through this two year transition, it’s a good time to review.

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

Natural Disasters Remind Us To Review Emergency Plans

Posted by Jon Elliott on Tue, Sep 26, 2017

Although environmental health and safety (EH&S) regulations focus primarily on safe handling of materials and wastes during routine operations, reports following hurricanes Harvey and Irma, and the major earthquake in Mexico, should remind us to plan to prevent releases from non-routine situations, up to an including natural disasters. Press reports include the following:

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Tags: Health & Safety, Environmental risks, Environmental

Safety: It's Not All About You

Posted by Tanya Conole on Tue, Aug 29, 2017

What if I told you that safety wasn’t about you? That the ‘safety starts with you’ mantra no longer applies? What would you think? How would you act? Could this even be true?

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Tags: Health & Safety, Training, Transportation

What’s In Your Janitor’s Closet? New York Seeks More Information

Posted by Jon Elliott on Tue, Aug 22, 2017

Even workplaces with very limited chemical use probably use cleaning supplies. If these supplies are bought in typical retail packaging intended for consumer use, the employer and employees may lack ready access to chemical content information beyond that on the labels. That’s because the Hazard Communication Standard (Hazcom) administered by the U.S. Occupational Safety and Health Administration (OSHA) exempts consumer products in their final form for consumer use, unless worker use is greater than that by typical consumers.

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Tags: Health & Safety, OSHA, California Legislation, Environmental risks, Environmental, EHS, Hazcom

California’s “Be a Manager, Go to Jail” Law

Posted by Jon Elliott on Tue, Jul 18, 2017

One of California’s many unique environmental, health and safety (EH&S) laws is its “Corporate Criminal Liability Act (CCLA).” CCLA provides greatly expanded potential personal criminal liabilities for violations by managers, so is often referred to as the “Be a Manager, Go to Jail” law. Enacted in 1990, CCLA draws both from occupational safety and product liability laws, to provide sweeping requirements for corporations and managers to abate or warn exposed individuals (including employees) about a broad variety of serious concealed dangers occurring in a broad variety of circumstances, including both workplaces and products. Although this law has been used by prosecutors and advocates to strike fear into the hearts of corporate managers, there have been few reported cases in its nearly three decades on the books.

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Tags: Health & Safety, OSHA, California Legislation, Environmental risks, Environmental

Thinking About Occupational Hearing Protection After Better Hearing and Speech Month

Posted by Jon Elliott on Thu, Jun 22, 2017

May was Better Hearing and Speech Month, and the National Institute for Occupational Safety and Health (NIOSH reminded employers that Occupational hearing loss (OHL) is one of the most common work-related illnesses in the United States. Each year, about 22 million U.S. workers are exposed to hazardous noise levels at work. NIOSH reports that U.S. employers paid more than $1.5 million in penalties for not protecting workers from noise in 2016, and that $242 million is spent annually on workers' compensation for hearing loss disability.

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

EPA Revises Stormwater General Permit For Construction

Posted by Jon Elliott on Tue, Mar 14, 2017

Effective February 16, 2017, the Environmental Protection Agency (EPA) has issued a revised “National Pollutant Discharge Elimination System [NPDES] General Permit for Discharges from Construction Activities” (CGP).” This new 2017 CGP replaces EPA’s 2012 CGP, updating requirements for entities with construction sites that disturb more than 1 acre of land – readers should keep in mind that this covers individual projects, so that even if your organization isn’t a construction company or developer, a big expansion at your facility may be covered.

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

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