Audit, Compliance and Risk Blog

EPA Proposes To Revise Hazardous Waste Generator Requirements–Part 1

Posted by Jon Elliott on Mon, Jan 18, 2016

Summary Of Proposals

The U.S. Environmental Protection Agency (EPA) has spent the last decade considering revisions to its hazardous waste management regulations (issued under federal laws generally referred to as the Resource Conservation and Recovery Act (RCRA)), exploring opportunities to clarify and simplify the text of the regulations and the actions necessary for compliance. In September, EPA published substantial regulatory revisions (which EPA entitles collectively as the Hazardous Waste Generator Improvements Rule) in the Federal Register; comments were due by December 24, after which EPA will decide whether to finalize the changes. EPA calculates that these proposals will include more than 60 changes to specific requirements, and more than 30 additional technical clarifications and corrections. These revisions would clarify some existing provisions, remove some longstanding requirements, and also add some additional new requirements. Some requirements apply to nearly all generators, while others are targeted at one or more of three volume-based tiers.

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Tags: Health & Safety, OSHA, EHS, EPA, Hazcom

Are You Ready For Flu Season?

Posted by Jon Elliott on Wed, Dec 16, 2015

Every winter, employee and public health officials around the world prepare for influenza (“flu”) seasons, which vary from mild to the occasional pandemic. Here in the U.S., the Centers for Disease Control and Prevention (CDC) issue annual forecasts of the strain(s) expected to be dominant, the severity of resulting health impacts, and of the availability and efficacy of vaccinations.

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

OSHA Proposes to Revise Safety and Health Program Guidelines

Posted by Jon Elliott on Tue, Dec 08, 2015

In 1989 OSHA issued “Safety and Health Program Management Guidelines” (S&H Guidelines), recommending activities employers should undertake to ensure their employees’ safety and health. The S&H Program Guidelines encourage employers to institute and maintain an “effective occupational safety and health program.” Some state occupational safety and health regulators have used these (voluntary) guidelines as the basis for mandatory employer programs – including California’s Injury and Illness Prevention Program (IIPP) requirement and Washington’s Accident Prevention Program (APP) requirement. OSHA proposed a national rule in 2012, but after several delays has designated it a “long term action.”

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

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

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

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

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

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

Designing Environmental, Health & Safety (EH&S) Audits

Posted by Jon Elliott on Tue, Jul 07, 2015

Management of chemicals by your organization raises a host of environmental health and safety (EH&S) issues.  Some of those issues are represented by legal and regulatory compliance requirements, others by formal but non-binding programs that range from company policies to ISO certifications.  In response, organizations adopt and implement a wide variety of EH&S programs, including very broad ones (e.g., compliance with the Hazard Communication Standard) as well as very narrow ones (e.g., programs for managing entry into Confined Spaces).  Organizations with sufficient resources and the will to organize themselves will create systematic programs to evaluate EH&S issues to ensure they’re addressed, and to design and coordinate programs in ways that do so effectively and efficiently. (In 2013-2014 I prepared a series of e-books that outlined EH&S regulatory requirements triggered by chemicals - click here to download).

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