Audit, Compliance and Risk Blog

Environmental Compliance: California Prepares To Regulate “Fracking”

Posted by Jon Elliott on Wed, Nov 20, 2013

Advances in field techniques have recently made hydraulic fracturing— “fracking”—a major part of energy production in the United States and Canada. Frackers pump high-pressure fluids into rock formations to expand cracks and create pathways for valuable hydrocarbons to flow out. The stimulant fluids are usually water-based, with additional chemicals (acids, surfactants, biocides, etc.) to improve effectiveness and solid ‘proppants’ to prop open the expanded openings (sand, etc.). Read my earlier blog here

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Tags: Health & Safety, California Legislation, Environmental risks, Environmental, EHS, Hazcom, fracking, hydraulic fracking, Oil & Gas

California Adopts Safer Consumer Products Regulations

Posted by Jon Elliott on Thu, Sep 19, 2013

Do you know what's in the chemical products you buy and use, and whether they're "safe?"  Effective October 1, 2013, California regulations provide criteria and procedures for state-level identification and listing of likely-hazardous chemicals of concern.  Manufacturers and importers will be required to evaluate chemicals of concern in consumer products, their potential alternatives, and how best to limit exposure or reduce hazards.  Assemblers and retailers will have related responsibilities.  Although these requirements apply directly only within California, any reviews and reformulations are likely to affect global production and distribution decisions.

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Tags: Health & Safety, California Legislation, Environmental, EHS, EPA, Hazcom

Recent OSHA Updates

Posted by Viola Funk on Mon, Aug 26, 2013

OSHA Expands Exemption for Digger Derricks Used in Construction Work

On May 29, the Occupational Safety and Health Administration (OSHA) issued a final rule that revises the regulations for cranes and derricks used in construction. These amendments expand the digger-derrick exemption to include all digger derricks used in construction work subject to 29 CFR1926 subpart V, Power Transmission and Distribution. A digger derrick (also called a radial boom derrick) is a specialized type of equipment designed to install utility poles. This revision removes from coverage under 29 CFR 1926 subpart CC certain types of non-pole digger-derrick work described by Edison Electrical Institute. OSHA also made several minor clarifications to the text of the exemption.

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Tags: Corporate Governance, Employer Best Practices, Health & Safety, OSHA, Employee Rights, Training, EHS

Obama Issues Executive Order On Chemical Facility Safety

Posted by Jon Elliott on Wed, Aug 21, 2013

One small but critically important sub-category of chemical incidents consists of those that can produce mass casualties, usually when a cloud of toxic or superheated gases are spewed out by a fire or explosion.  Given America’s fragmented approach to hazardous materials regulation, it’s no surprise that separate regulatory programs have grown up to address these concerns—leading inevitably to overlaps and gaps in coverage.

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Tags: Corporate Governance, Business & Legal, Health & Safety, OSHA, Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, Hazcom

EPA Excludes Solvent-Contaminated Wipes From RCRA Regulation

Posted by Jon Elliott on Wed, Aug 14, 2013

All hazardous wastes are not created equal.  The basic model is that:

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Tags: Business & Legal, Employer Best Practices, Health & Safety, Environmental risks, Environmental, EHS, EPA, RCRA

Environmental Compliance: One Chemical, Many Regulations

Posted by Jon Elliott on Fri, Aug 02, 2013

If government provided a unified approach to chemical regulation, then each chemical might be subject to a single set of requirements, which ideally would be tailored to reflect chemical-specific hazards throughout its life cycle.  Instead, each chemical is subject to its own loosely connected (some would say haphazard) collection of environmental, health and safety (EH&S) requirements.  Some are federal, some are state (or provincial if you’re in Canada), and others are regional and even local.  You may need to refer to agencies at all three levels (federal, state and local) to identify your regulators and their requirements – although many organizations only deal with the agency responsible for permitting and inspecting day-to-day activities.

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Tags: Audit Standards, Environmental risks, Environmental, EHS, EPA, Hazcom, MSDS, mact

STP Launches New Industry-Specific MACT Standards Guides

Posted by Lorraine O'Donovan on Fri, Jul 12, 2013

Organizations increasingly need specialized guidance in order to self-audit and show efforts to comply with legislation, and demonstrate due diligence.

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Tags: Corporate Governance, Business & Legal, Audit Standards, Environmental risks, Environmental, EHS, mact

Environmental Compliance: TRI Reports Due

Posted by Jon Elliott on Fri, Jul 05, 2013

July 1 was the deadline for subject facilities to file their annual toxic chemical release inventory (TRI) reports with the US Environmental Protection Agency (EPA) and their state, on one of two EPA-mandated forms, Form R or Form A.  These TRI reports are mandated by Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), which was adopted as the first Congressional response to the December 1984 toxic gas disaster in Bhopal, India.

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Tags: Corporate Governance, Business & Legal, Health & Safety, Environmental risks, Environmental, EHS, Hazcom

ISO 14001 and the ISO 26000 Guidance on Social Responsibility

Posted by Allison Campbell on Fri, Jun 07, 2013

Organizations with a well-established ISO 14001 Environmental Management System (EMS) are discovering a new advantage as the issue of “social responsibility” becomes more widespread throughout business communities. EMS managers are finding that techniques and methodology from their EMS can be used to identify and prioritize social responsibility issues and efficiently integrate them into their organization. Furthermore, managers building an EMS system are able to develop it in concert with social responsibility initiatives.

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Tags: Corporate Governance, Business & Legal, Employer Best Practices, Environmental, EHS, EPA

Mandatory GHG EPA Reports Due April 1, 2013

Posted by Jon Elliott on Mon, Feb 04, 2013

The US Environmental Protection Agency (EPA) continues to expand and refine environmental compliance requirements, including those related to greenhouse gas (GHG) emissions. In particular, facilities and organizations subject to EPA's mandatory GHG emission reporting rules should be preparing to submit reports covering calendar year 2012. Even an entity that reported 2010 or 2011 emissions will still have to adjust its data collection and information reporting efforts. Although reports typically are due March 31, that’s a Sunday this year so April 1 is the date.

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Tags: Environmental risks, Environmental, EHS, EPA, ghg, fracking, climate change