---
title: Audit, Compliance and Risk Blog | STP | Jon Elliott (9)
description: STP's blog giving insight into audit, compliance and risk issues for EHS, business and accounting.  (9)
---

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# Audit, Compliance and Risk Blog

## Jon Elliott

### Recent Posts

## [OSHA encourages switch from hard hats to safety helmets](https://blog.stpub.com/osha-encourages-switch-from-hard-hats-to-safety-helmets)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Tue, Jan 09, 2024

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[![](https://blog.stpub.com/hs-fs/hubfs/images/jon_f_elliott.jpg?width=190&height=227&name=jon_f_elliott.jpg) ](https://blog.stpub.com/osha-encourages-switch-from-hard-hats-to-safety-helmets)

On November 22, the Occupational Safety and Health Administration (OSHA) issued a Safety and Health information Bulletin (SHIB) discussing “safety helmets” as evolved alternatives to traditional hard hats, and offering recommendations for situations where employers should switch. On December 11 the agency announced that it’s following its own advice and replacing its own employees/inspectors hard hats with safety helmets. The rest of this note discusses OSHA provisions for personal protective equipment (PPE) providing head protection, and the rationale and examples of the benefits of upgraded headgear.

[Read More](https://blog.stpub.com/osha-encourages-switch-from-hard-hats-to-safety-helmets)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/osha-encourages-switch-from-hard-hats-to-safety-helmets#comments-listing)

 Tags: [Health & Safety](https://blog.stpub.com/topic/health-safety), [OSHA](https://blog.stpub.com/topic/osha), [Safety and Health at Work](https://blog.stpub.com/topic/safety-and-health-at-work), [workplace safety](https://blog.stpub.com/topic/workplace-safety)

## [OSHA requires workplace noise controls](https://blog.stpub.com/osha-requires-workplace-noise-controls)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Fri, Jan 05, 2024

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[![](https://blog.stpub.com/hubfs/worker_with_headphones.jpeg) ](https://blog.stpub.com/osha-requires-workplace-noise-controls)

The Occupational Safety and Health Administration (OSHA) Region 3 (covering Delaware, Pennsylvania, West Virginia, and the District of Columbia) has renewed a Regional Emphasis Program under which it focuses inspection resources on “High Level Noise.” This announcement provides a useful reminder to employers throughout the US to evaluate occupational noise and the risks of employees’ hearing loss. The remainder of this note summarizes OSHA’s Occupational Noise Standard for General industry (separate requirements cover construction).

[Read More](https://blog.stpub.com/osha-requires-workplace-noise-controls)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/osha-requires-workplace-noise-controls#comments-listing)

 Tags: [OSHA](https://blog.stpub.com/topic/osha), [workplace safety](https://blog.stpub.com/topic/workplace-safety), [PPE](https://blog.stpub.com/topic/ppe), [PEL](https://blog.stpub.com/topic/pel)

## [OSHA reminds employers about duty to keep young workers safe](https://blog.stpub.com/osha-reminds-employers-about-duty-to-keep-young-workers-safe)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Tue, Dec 19, 2023

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[![](https://blog.stpub.com/hubfs/Safety-worker.jpeg) ](https://blog.stpub.com/osha-reminds-employers-about-duty-to-keep-young-workers-safe)

The Occupational Safety and Health Administration (OSHA) provides a “Young Workers - You have rights!” webpage on its website, compiling regulatory and practical information for employers and workers. As we approach the annual spike in youth employment during the end-of-year Holidays, this provides a timely reminder to focus on the needs and rights of young people in workplaces. The webpage targets information as follows:

- Young Workers
- Employers
- Parents and Educators
- Real Stories
- Hazards
- Resources

The remainder of this note summarizes these materials, focusing on information useful to employers.

[Read More](https://blog.stpub.com/osha-reminds-employers-about-duty-to-keep-young-workers-safe)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/osha-reminds-employers-about-duty-to-keep-young-workers-safe#comments-listing)

 Tags: [Health & Safety](https://blog.stpub.com/topic/health-safety), [OSHA](https://blog.stpub.com/topic/osha), [Safety and Health at Work](https://blog.stpub.com/topic/safety-and-health-at-work), [workplace safety](https://blog.stpub.com/topic/workplace-safety)

## [California adopts general requirements for workplace violence prevention](https://blog.stpub.com/california-adopts-general-requirements-for-workplace-violence-prevention)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Fri, Dec 15, 2023

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[![](https://blog.stpub.com/hs-fs/hubfs/images/jon_f_elliott.jpg?width=190&height=227&name=jon_f_elliott.jpg) ](https://blog.stpub.com/california-adopts-general-requirements-for-workplace-violence-prevention)

On September 30, 2023, California’s governor Gavin Newsom signed Senate Bill (SB) 553, which expands the state’s workplace violence prevention (WVP) requirements, adding duties and rights for most employers in the state. Most importantly, SB 553 requires all non-exempt employers in the state to create WVP plans. These expanded requirements will be administered by California’s Division of Occupational Safety and Health (DOSH, but generally referred to as “Cal/OSHA”), which already administers WVP planning requirements for healthcare employers (which I wrote about [HERE](https://blog.stpub.com/california-adopts-workplace-violence-prevention-requirements-for-health-care-facilities)), and has been working on a general rule (I wrote about the latest draft [HERE](https://blog.stpub.com/california-again-considering-requirements-for-workplace-violence-prevention)). The remainder of this note discusses SB 553, which takes effect on January 1, 2024 but remains subject to further rulemakings.

[Read More](https://blog.stpub.com/california-adopts-general-requirements-for-workplace-violence-prevention)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/california-adopts-general-requirements-for-workplace-violence-prevention#comments-listing)

 Tags: [Workplace violence](https://blog.stpub.com/topic/workplace-violence), [California](https://blog.stpub.com/topic/california), [DOSH](https://blog.stpub.com/topic/dosh), [WVP](https://blog.stpub.com/topic/wvp), [IIPP](https://blog.stpub.com/topic/iipp)

## [California enacts two new climate-related reporting laws](https://blog.stpub.com/california-enacts-two-new-climate-related-reporting-laws)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Thu, Dec 14, 2023

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[![](https://blog.stpub.com/hubfs/images/Greenhouse%20gas.jpg) ](https://blog.stpub.com/california-enacts-two-new-climate-related-reporting-laws)

On October 7, 2023, California’s governor Gavin Newsom signed two important bills expanding climate-related reporting requirements for targeted organizations doing business in the state – SB 253 (Wiener) (Climate Corporate Data Accountability Act) and SB 261 (Stern). These requirements will be administered by the California Air Resources Board (ARB), which already includes most state greenhouse gas (GHG) regulatory requirements within its extensive air quality and climate authority (centered on the Global Warming Solutions Act of 2006 (AB 32). The remainder of these note discusses these new requirements.

[Read More](https://blog.stpub.com/california-enacts-two-new-climate-related-reporting-laws)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/california-enacts-two-new-climate-related-reporting-laws#comments-listing)

 Tags: [Environmental](https://blog.stpub.com/topic/environmental), [Greenhouse Gas](https://blog.stpub.com/topic/greenhouse-gas), [ghg](https://blog.stpub.com/topic/ghg), [California](https://blog.stpub.com/topic/california), [Environment](https://blog.stpub.com/topic/environment), [Environmental Policy](https://blog.stpub.com/topic/environmental-policy)

## [WorkSafeBC reminds employer to prevent slips, trips and falls](https://blog.stpub.com/worksafebc-reminds-employer-to-prevent-slips-trips-and-falls)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Tue, Dec 05, 2023

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[![](https://blog.stpub.com/hubfs/pexels-towfiqu-barbhuiya-12460181.jpg) ](https://blog.stpub.com/worksafebc-reminds-employer-to-prevent-slips-trips-and-falls)

On October 24, 2023, WorkSafeBC, British Columbia’s provincial occupational health and safety (OHS) regulator and workers’ compensation overseer, issued a reminder to employers to address the hazards of workplace slips, trips and falls. The reminder began with a recitation that approximately 20 percent of all workplace injuries in the province relate to slips, trips, and falls. The agency also reported that “in the past six years, almost 41,000 workers in B.C. suffered slip-trip-and-fall injuries, including fractures, sprains, and dislocations.” The agency notice follows these statistics with reminders of what employers can and should do to reduce the likelihood and severity of these injuries. The remainder of this note summarizes this information.`

[Read More](https://blog.stpub.com/worksafebc-reminds-employer-to-prevent-slips-trips-and-falls)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/worksafebc-reminds-employer-to-prevent-slips-trips-and-falls#comments-listing)

 Tags: [Health & Safety](https://blog.stpub.com/topic/health-safety), [Safety and Health at Work](https://blog.stpub.com/topic/safety-and-health-at-work), [workplace safety](https://blog.stpub.com/topic/workplace-safety), [Injury](https://blog.stpub.com/topic/injury), [OHS](https://blog.stpub.com/topic/ohs)

## [Deadlocked Supreme Court of Canada allows restriction of owner-employer contracting out OHS responsibilities to contractors](https://blog.stpub.com/deadlocked-supreme-court-of-canada-allows-restriction-of-owner-employer-contracting-out-ohs-responsibilities-to-contractors)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Thu, Nov 30, 2023

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[![](https://blog.stpub.com/hubfs/images/Supreme_Court_Canada_cropped.jpg) ](https://blog.stpub.com/deadlocked-supreme-court-of-canada-allows-restriction-of-owner-employer-contracting-out-ohs-responsibilities-to-contractors)

Throughout North America, Canadian occupational health and safety (OHS) agencies and US occupational safety and health (OSH) agencies administer and enforce worker protection laws. These laws require extensive employer efforts to protect employees – although in some situations it’s unclear which employer(s) are responsible for which workers. These complex situations include construction sites where one or more landowners or property occupiers hire one or more contractors to performer work. In November 2023 the Supreme Court of Canada deadlocked four-to-three-to-one in a case involving liability for a municipal “owner” that had attempted to contract all responsibilities (and potential liabilities) to the contractor (“constructor”) hired to repair a municipal water main, after a worksite death. (*R. v. Greater Sudbury (City)*) Because the Supreme Court deadlocked, the Ontario Court of Appeal decision finding the city liable becomes the law of the case, overturning many years of practice in which owners contracted-out OHS responsibilities to their constructors.

[Read More](https://blog.stpub.com/deadlocked-supreme-court-of-canada-allows-restriction-of-owner-employer-contracting-out-ohs-responsibilities-to-contractors)

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 Tags: [OSHA](https://blog.stpub.com/topic/osha), [Supreme Court](https://blog.stpub.com/topic/supreme-court), [workplace safety](https://blog.stpub.com/topic/workplace-safety), [Canada](https://blog.stpub.com/topic/canada), [Ontario Court](https://blog.stpub.com/topic/ontario-court), [Ontario](https://blog.stpub.com/topic/ontario)

## [California begins to regulate carbon offset claims](https://blog.stpub.com/california-begins-to-regulate-carbon-offset-claims)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Fri, Nov 24, 2023

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[![](https://blog.stpub.com/hubfs/pexels-pixabay-257775.jpg) ](https://blog.stpub.com/california-begins-to-regulate-carbon-offset-claims)

Regulatory and market-based programs are steadily increasing opportunities for entities to contract with projects that reduce emissions of carbon dioxide and other greenhouse gases (GHGs), and to claim credit for those “carbon offsets.” Some such claims are used to satisfy formal air quality and GHG reduction requirements, while others are touted to enhance entities’ “green” credentials. Programs around the globe compile such claims, and some provide third party validations – but possible “greenwashing” of unjustified claims remains a significant concern. To address these concerns, California has just enacted legislation to regulate Voluntary Cabon Market Disclosures and penalize noncompliance (Assembly Bill (AB) 1305, Gabriel). These requirements synthesize the most thorough voluntary disclosure programs, and are intended not only to protect California consumers but to codify disclosure standards. The rest of this note summarizes carbon offsets, and AB 1305 requirements.

[Read More](https://blog.stpub.com/california-begins-to-regulate-carbon-offset-claims)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/california-begins-to-regulate-carbon-offset-claims#comments-listing)

 Tags: [Environmental](https://blog.stpub.com/topic/environmental), [Greenhouse Gas](https://blog.stpub.com/topic/greenhouse-gas), [greenhouse](https://blog.stpub.com/topic/greenhouse), [California](https://blog.stpub.com/topic/california), [Environment](https://blog.stpub.com/topic/environment), [Environmental Policy](https://blog.stpub.com/topic/environmental-policy), [environmental protection](https://blog.stpub.com/topic/environmental-protection)

## [EPA tightens Toxics Release Inventory reporting requirements for PFAS “Forever chemicals”](https://blog.stpub.com/epa-tightens-toxics-release-inventory-reporting-requirements-for-pfas-forever-chemicals)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Mon, Nov 20, 2023

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[![](https://blog.stpub.com/hubfs/pfas-2-2.png) ](https://blog.stpub.com/epa-tightens-toxics-release-inventory-reporting-requirements-for-pfas-forever-chemicals)

On October 31, 2023 the US Environmental Protection Agency (EPA) tightened its reporting requirements for per- and polyfluoroalkyl substances (PFAS) – frequently called ‘forever chemicals” because they biodegrade very slowly – under its Toxic Release Inventory (TRI) program. These changes finalize a proposal issued in (which I wrote about [HERE](https://blog.stpub.com/epa-expands-toxics-release-inventory-chemical-list-and-proposes-lower-reporting-thresholds-for-pfas-chemicals)), and reflect EPA’s agency-wide efforts to tighten controls on PFASs proposed in December 2022 (I wrote about these efforts [HERE](https://blog.stpub.com/us-government-rolls-out-comprehensive-approach-to-pfas-forever-chemicalspfas)). The new TRI revisions apply to reports beginning in calendar year 2024. The remainder of this note summarizes these changes.  

[Read More](https://blog.stpub.com/epa-tightens-toxics-release-inventory-reporting-requirements-for-pfas-forever-chemicals)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/epa-tightens-toxics-release-inventory-reporting-requirements-for-pfas-forever-chemicals#comments-listing)

 Tags: [Environmental](https://blog.stpub.com/topic/environmental), [EPA](https://blog.stpub.com/topic/epa), [Environment](https://blog.stpub.com/topic/environment), [Environmental Policy](https://blog.stpub.com/topic/environmental-policy), [TRI](https://blog.stpub.com/topic/tri), [PFAS](https://blog.stpub.com/topic/pfas)

## [EPA proposes management requirements for equipment containing HFCs](https://blog.stpub.com/epa-proposes-management-requirements-for-equipment-containing-hfcs)

 Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Mon, Nov 06, 2023

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[![](https://blog.stpub.com/hubfs/ref-roof-condenser.jpeg) ](https://blog.stpub.com/epa-proposes-management-requirements-for-equipment-containing-hfcs)

On October 19, 2023, the US Environmental Protection Agency (EPA) proposed to establish requirements for the management of hydrofluorocarbons (HFCs) potentially released from equipment during maintenance or other services, and manage spent HFCs.. These rules support US efforts to implement the 2016 Kigali Amendment to the United Nations-sponsored Montreal Protocol on Substances that Deplete the Ozone Layer (which I wrote about [HERE](https://blog.stpub.com/the-world-decides-to-help-the-climate-by-helping-the-ozone-layer)), and codified in the December 2020 coronavirus relief bill (American Innovation and Manufacturing Act of 2020 (AIM Act; which included dozens of unrelated provisions within its 5,593 pages). EPA adopted its over-arching HFC phase-down rules in September 2021 (I wrote about them [HERE](https://blog.stpub.com/epa-finalizing-hfc-phase-down-rules)), and continues to adjust and refine their requirements. The remainder of this note summarizes EPA’s new proposal, which would impose requirements using authority under the Clean Air Act (CAA) and the Resource Conservation and Recovery Act (RCRA).

[Read More](https://blog.stpub.com/epa-proposes-management-requirements-for-equipment-containing-hfcs)

 0 Comments [Click here to read/write comments](https://blog.stpub.com/epa-proposes-management-requirements-for-equipment-containing-hfcs#comments-listing)

 Tags: [EPA](https://blog.stpub.com/topic/epa), [RCRA](https://blog.stpub.com/topic/rcra), [Environment](https://blog.stpub.com/topic/environment), [HFCs](https://blog.stpub.com/topic/hfcs), [Environmental Policy](https://blog.stpub.com/topic/environmental-policy), [CCA](https://blog.stpub.com/topic/cca), [environmental protection](https://blog.stpub.com/topic/environmental-protection), [CFC](https://blog.stpub.com/topic/cfc)

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