Audit, Compliance and Risk Blog

Another Hazcom Transition Deadline December 1, 2015

Posted by Jon Elliott on Mon, Nov 30, 2015

The Occupational Safety and Health Administration (OSHA) adopted massive changes to its Hazard Communication Standard (HCS or Hazcom) effective May 25, 2012, updating chemical information, labeling and training requirements that had been in place since the 1980s. These revised requirements conform U.S. requirements to international guidelines under the U.N.-sponsored Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Recognizing the extent of these changes, OSHA provided multi-year compliance phase-ins for employers whose workers manufacture, distribute or use chemicals (I’ve previously blogged about the changes here, here and here). The next such deadline is December 1, 2015, when distributors must only ship containers that meet the latest labeling requirements – so if you work for an employer that’s an end user of chemicals, all containers entering your facility must meet these requirements rather than the pre-2012 requirements.

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

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?

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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:

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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.

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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.

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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.

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

Meeting OSHA Requirements On Employee Exposure And Medical Records

Posted by Jon Elliott on Tue, Sep 22, 2015

A wide variety of Occupational Safety and Health Administration (OSHA) standards require employers to acquire or create documentation of employees’ exposures to potentially hazardous materials and contaminants in their workplaces, and to inform employees of the presence of these hazards. For example, the Hazard Communication Standard (Hazcom) requires most employers to acquire Safety Data Sheets (SDSs) and provide workplace labeling and employee training. Other standards require employers to monitor their workplaces for airborne exposures to contaminants, and to compare such exposures to permissible exposure limits (PELs) or action levels. Some standards require employers to conduct medical monitoring of employees who are subject to such exposures. These records can be vitally important to provide information on long-term (chronic) health effects of exposures.

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

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?

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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.

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

OSHA Narrows Process Safety Management Exclusion For Retail Facilities

Posted by Jon Elliott on Tue, Aug 11, 2015

The Occupational Safety and Health Administration (OSHA) adopted its Standard for Process Safety Management of Highly Hazardous Chemicals (usually referred to as “PSM”) in 1992, to require extensive risk assessment and reduction efforts by facilities where a significant chemical incident might have catastrophic consequences. OSHA has made only minor technical revisions in the ensuing two decades. However, during that time OSHA has issued a series of regulatory interpretations and enforcement guidelines that affect how the Standard is implemented.

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