Audit, Compliance and Risk Blog

EPA Revises the Agricultural Worker Protection Standard

Posted by Jon Elliott on Wed, Nov 25, 2015

The US Environmental Protection Agency (EPA) administers a Worker Protection Standard (WPS) designed to protect workers exposed to agricultural pesticides. WPS is patterned after the Occupational Safety and Health Administration (OSHA's) Hazard Communication Standard (HCS) for workers in most other industrial and commercial settings. EPA adopted the WPS in 1992, and just adopted its first revisions late in September 2015. Some of these changes incorporate revisions to HCS adopted by OSHA in 2012 (see here), while others catch up on two decades of industrial hygiene and worker safety practices. The revisions will appear in the Federal Register (probably in November) and become effective 60 days later. Compliance deadlines extend for up to 2 years for the various changes.

What Does WPS Require Now?

I summarized longstanding WPS requirements when I blogged last year about EPA’s proposed revisions (click here ). To further summarize my summary, WPS requires employers whose employees work with or around pesticides to provide the following:

  • Pesticide safety training

  • Labeling information

  • Specific information including pesticide-specific training within 5 days after beginning work (“grace period”), supplementing immediate emergency information and a pesticide safety poster

  • Requirements to keep workers out of areas being treated with pesticides, within nurseries and greenhouses (“buffer”)

  • Requirements to keep workers out of areas during a restricted-entry interval (REI) set for each pesticide

  • Protect early-entry workers doing permitted tasks in pesticide-treated areas during an REI, including special instructions and personal protective equipment (PPE)

  • Required warning to nearby workers about pesticide-treated areas (oral and/or warning signs, depending on the chemical)

  • Monitor handlers using highly toxic pesticides, at least every 2 hours

  • Provide required PPE to handlers (e.g., clothing, respirators)

  • Provide decontamination supplies

  • Provide for emergency assistance.

Some requirements apply on behalf of all agricultural workers who may be exposed, plus additional requirements for pesticide handlers who work with regulated pesticides.

What Changes is EPA Adopting?

EPA has adopted a wide variety of revisions, including provisions that have changed significantly from last year’s proposal. Revisions include:

  • Training (compliance deadline delayed for 2 years):

Read More

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

EPA Proposes Pharmaceutical Waste Management Requirements

Posted by Jon Elliott on Thu, Nov 19, 2015

Pills.jpgIf your organization manages pharmaceuticals, do you know if any of its waste pharmaceuticals are regulated as “hazardous waste” under the Resource Conservation and Recovery Act (RCRA)? And do you know which ones, and why or why not?

Read More

Tags: Health & Safety, OSHA, Environmental risks, Environmental, Hazcom, pharmaceuticals

Hazardous Materials Commentary as Textbook for Professionals

Posted by Jon Elliott on Tue, Nov 17, 2015

For more than 25 years, I’ve taught one of the core required courses in the Hazardous Materials Management Certificate program offered by University of California Santa Cruz Extension (UCSC-Ex). The program is intended to provide professionals with a solid foundation in the principles, regulations, and technologies required to manage hazardous materials and hazardous waste. In my course–the Regulatory Framework for Toxic and Hazardous Materials–I provide overviews of:

Read More

Tags: Audit Standards, Health & Safety, California Legislation, Training, Environmental risks, Environmental, EHS, Greenhouse Gas, ghg, Hazcom, mact

EPA Proposes To Revise Hazardous Waste Import-Export Requirements

Posted by Jon Elliott on Wed, Oct 14, 2015

The U.S. Environmental Protection Agency (EPA) administers rules governing the import and export of hazardous waste regulated by the Resource Conservation and Recovery Act (RCRA). These rules implement requirements established by RCRA, and also ensure that the U.S. meets its international responsibilities as a member of the Organization for Economic Cooperation and Development (OECD) by creating national rules that meet agreed-upon OECD standards. The proposal should appear in the Federal Register soon, opening a 60 day comment period after which EPA will decide whether to finalize the changes.

Read More

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

Cal/OSHA Updates Safety Rules for Storage Batteries

Posted by Deb Hunsicker on Tue, Oct 06, 2015

Cal/OSHA has adopted final rules, effective October 1, 2015, that update the state’s regulations relating to storage battery systems and to changing and charging storage batteries. The purpose of this action is to update standards for storage batteries to address modern types of batteries in addition to clarifying regulations applicable to traditional lead–acid batteries.

Read More

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

EPA Catches Volkswagen Cheating On Emission Tests

Posted by Jon Elliott on Thu, Oct 01, 2015

In recent years, VW officials have sometimes been quoted touting their “clean diesel” vehicles by paraphrasing one of their competitors—“this isn’t your grandfather’s diesel.” This month VW finally admitted to the U.S. Environmental Protection Agency (EPA) and customers worldwide that it “isn’t your regulator’s diesel” either. The company had programmed the electronics in millions of vehicles to provide false data during required emissions tests.

Read More

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

Safety Programs Are Essential For The Automotive Workplace

Posted by STP Editorial Team on Tue, Sep 29, 2015

“No one should have to sacrifice their life for their livelihood, because a nation built on the dignity of work must provide safe working conditions for its people.”
– Secretary of Labor, Thomas E. Perez

Read More

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

New York Targets Legionella

Posted by Jon Elliott on Thu, Sep 10, 2015

Although Environmental Health and Safety (EH&S) requirements target hundreds of micro-organisms (primarily viruses and bacteria), regulation of important hazards remain on the drawing boards, awaiting appropriate testing and control methodologies, sufficient resources … and high enough political priorities. Until recently, one of these unregulated pathogens has been the legionella bacterium, first identified in 1976 as the cause of “Legionnaire’s disease” – named after an outbreak at an American Legion convention in Philadelphia traced to the hotel’s air conditioning system. This summer, however, an outbreak in New York has led state and local health agencies to adopt extremely ambitious testing and disinfection programs.

Read More

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

10 Powerful Environmental Non-fiction Reads

Posted by Jane Dunne on Tue, Sep 08, 2015

How often do you read something that not only changes the things that you think about in life, it also changes the things you do?

Read More

Tags: Health & Safety, Environmental risks, Environmental, EHS, Greenhouse Gas, ghg, Hazcom

OSHA Proposes To Expand Enforceability Of Injury And Illness Reporting Requirements

Posted by Jon Elliott on Tue, Aug 18, 2015

The Occupational Safety and Health Administration (OSHA) has just proposed to revise its requirement that employers prepare and maintain records of occupational injuries and illnesses as they occur – in “I&I Logs.” (I blogged about these requirements here). Employers must also post annual I&I Summaries in each workplace, and respond to survey questions if asked by OSHA or the Bureau of Labor Statistics.

Read More

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