Environmental Health and Safety Blog | EHSWire

by: H. Dale Wilson, CIH, LEED AP

Stronger standards aimed at reducing the number of Legionellosis (Legionnaires' disease) cases are being brought about through the proposed American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 188, “Prevention of Legionellosis Associated with Building Water Systems.” Hospitals and other medical facilities are advised to prepare for these changes to get a better grasp of potential problems before the standard is finalized.

According to the CDC, between 8,000 and 18,000 people are hospitalized every year with Legionnaire's disease, which is fatal in 5-30% of cases. It's a serious infection that can affect those with chronic lung conditions, smokers, or individuals with chronic immune system disorders or weaknesses.  It is hoped that these changes to ASHRAE's Legionella standard will prevent thousands of cases every year.

The changes are comprehensive, and include several steps. From the proposed Standard:

• The facility is surveyed to determine its risk characterization, which determines what preventive measures are required under the standard.


• A Hazard Analysis and Critical Control Points (HACCP) team is formed by the building owner, the owner's building management team or both. The team must include at least one person who understands the principles of HACCP and at least one person who understands the building water systems. Members of the HACCP team can be employees, suppliers, consultants or any combination thereof.


• The team identifies the end point uses of potable and utility water systems within the facility.


• The team creates at least two process flow diagrams—one for potable water and another for utility water—to describe how the water is processed and used in their facilities.


• An on-site inspection confirms that the flow diagrams are accurate.


• Using the flow diagrams, the team identifies control points in the process. Control points are any steps at which biological, chemical or physical factors can be controlled.


• The team then determines which control points should be designated as critical control points, which are steps in the process where it is essential to prevent or eliminate a hazard or prevent harm to a person.


• The team establishes critical control limits for each critical control point. These are the specified values for hazard control, such as the amount of chlorine needed or the temperature range needed to control the hazard of Legionella.


• The team creates monitoring procedures for each critical limit as well as a monitoring frequency.


• The team establishes corrective actions to take when deviations from critical limits are found.


• The team validates its selection of critical control points, critical limits and corrective actions.


• The team establishes verification procedures and record-keeping procedures as required by the standard.

The changes incorporate concepts found in Hazard Analysis and Critical Control Point (HACCP) plans, well-established to be effective in the food industry to prevent food-borne illnesses. The HACCP model was also chosen because of the inexpensive (and sometimes free) availability of the plans and the ease of implementation. While some have stated that the changes seem complex, the HACCP model is being incorporated to streamline the processes and standards.

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Topics: Emilcott, indoor air quality, General EHS, Air Monitoring, Legionellosis, ASHRAE's Legionella Standard, Hazard Analysis and Critical Control Point, HACCP, Refrigerating and Air-Conditioning Engineers, Legionella, American Society of Heating

Topics: Emilcott, indoor air quality, NJDEP, Vapor Intrusion, Portfields, ASTM, Brownfields

By Paula Kaufmann, CIH

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Topics: Emilcott, TSCA & R.E.A.C.H., TSCA, CDX registration, CDR, Toxic Substance Control Act

By Bruce D. Groves, CIH

Compared with the air quality monitoring methods of even a few years ago, today’s air monitor system offers its users a quicker, more effective, and comprehensive way to assess potential environmental hazards.

2nd Ave Subway Construction Muck House - What emissions from here are impacting the Local Air Quality?

 

The recently published article, “ MTA: 2nd Avenue Subway Construction Not a Danger to Your Health,” responds to a rise in complaints about possible environmental health hazards from the construction. In the article, MTA Capital Construction President Michael Horodniceanu suggested the public faced no danger from the construction based on results from a fall 2011 Parsons Brinkerhoff (PB) air monitoring study.

The PB study highlights important facts and issues about the project and makes useful points about air quality monitoring in general; however, PB used the same traditional dust and vapor monitors and methods that were used at the World Trade Center recovery site in 2001.

In the last decade and especially over the last few years, superior air monitoring technologies have been developed and used to help ensure that emission rates from major hazardous waste remediation operations in the New York metropolitan area are kept as low as possible. The use of innovative, more effective, and more cost-saving air monitoring equipment and methods would have provided data for the PB study that would better support MTA’s assertions.

Greenlight Map View of Integrated Air Monitoring Data

For example, state-of-the-art air quality monitors today use integrated, real-time environmental air sampling that measures multiple dust particle sizes while simultaneously tagging each sample to wind speed and direction—a particularly valuable approach for evaluating the impact of blasting, material (rock) loading, vehicle exhaust emissions, and other construction-related activities in densely populated urban sites where wind direction varies significantly. In addition, vapor and gas measurements, including VOCs, SO2, CO, H2S, and NH3, can now be integrated into a single database to create a visual map of the air quality and wind direction across a project area. The data are then transmitted in real time to computers, including iPads and other handheld technology, for quick response to problems.

An integrated approach also helps:

• Differentiate the sources of air contaminants so that those associated with the construction can be distinguished from those of other background sources

• Determine when emission levels from the construction/remediation activity begin rising

• Deliver immediate information to construction management so that they can make timely decisions to protect workers and the public

• Measure the efficacy of engineering controls and work practices in reducing emission rates, even when concentrations are below project or regulatory safe levels

Given the options, PB and the MTA would have found these and other meaningful enhancements in air monitoring equipment and techniques valuable to the 2nd Avenue Subway construction project.

I encourage you to learn more about state-of-the-art air monitoring equipment, including integrated systems that allow users to make evidence-based decisions to protect workers and the public.

Second Avenue Subway (SAS) Project – Air Quality Monitoring Study of Construction Activities between 69th and 87th Street on Second Avenue

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Topics: Emilcott, Air Monitoring, air quality monitoring systems, environmental health hazards, Greenlight, air monitoring equipment, MTA, monitoring air quality, health hazards, air monitoring techniques, Air Sampling, Greenlight System

The Office of Management and Budget received the final rule update for the Hazard Communication Standard (1910.1200) on 10/25/11.  The 90 day review period is over but the review period has been recently extended.  There is no notice of the length of the extension and it should be noted that OMB has had the OSHA proposed Occupational Exposure to Crystalline Silica Standard for nearly a year, since 2/14/11, and it is still listed as having an extended review period.

You can view the rule at HERE

One of the changes is the inclusion of an “Unclassified Hazards” category; a definition is provided below.  The U.S. Chemical Safety Board recently released a statement supporting the Unclassified Hazard category to allow for inclusion of combustible dust hazards on safety data sheets and labeling.

“Unclassified hazard” means a chemical for which there is scientific evidence identified during the classification process that it may pose an adverse physical or health effect when present in a workplace under normal conditions of use or in a foreseeable emergency, but the evidence does not currently meet the specified criteria for physical or health hazard classification in this section. This does not include adverse physical and health effects for which there is a hazard class addressed in this section.

It should also be noted that EPA began to make amendments in November of last year to regulations for the "Protection in the Workplace" (40 CFR 721.63) and "Hazard Communication Program" (40 CFR 721.72) components of the Significant New Uses of Chemical Substances regulations at 40 CFR 721 to align them with the GHS changes in the OSHA Hazard Communications Standard.

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Topics: Emilcott, OSHA, OSHA Compliance, EPA, hazards

Here is a handy table we recently created for our clients — a gentle reminder to get organized! Even if you miss a deadline, it’s better to start playing catchup as soon as you find out that you are not in compliance.

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Topics: Emilcott, NPDES, OSHA, Emergency Planning and Community Right-to-Know Act, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, EPCRA, Hazardous Waste Management, TSCA & R.E.A.C.H., TSCA, CDR, Toxic Substance Control Act, Biennial Hazardous Waste

As you begin to gather the information for your TSCA 2012 CDR submission, keep in mind that almost all polymers are exempt from reporting.

What polymeric substances are exempt from reporting?

• Chemical substances described with the word fragments “*polym*”, “*alkyd”, or “oxylated” in the Chemical Abstracts (CA) Index Name


• Chemical substance which is identified in the TSCA Master Inventory File as-    Siloxane(s) and silicone(s)

-       Silsesquioxane(s)

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Topics: Emilcott, TSCA, CDR, CDR Reporting, polymeric substance, polymers, Uncategorized

Bringing in the New Year is always an exciting time for everyone. People enjoy setting new goals, looking forward to the journey that the New Year brings and starting that resolution they promise they are going to keep. While the New Year brings many things to look forward to, it also is a time where we look back at the year that has passed and take a moment to reflect on what has happened.

At Emilcott, 2011 was a successful year where we were able to tackle new projects, serve our clients and continue to respond to current industry issues in the environmental, health and safety field. Though we have had many great memories from 2011, we would like to mention some of the things that stood out most in our business for 2011.

Hurricane Irene – the immense and powerful Atlantic hurricane that left a path of destruction and devastation was something that definitely stands out in 2011. We remember this event not only because of the wreckage caused by the storm, but also because of the after effects. The staff at Emilcott recognized the importance of addressing the legacy of water intrusion and the promise of mold after the storm and stressed to clients the importance of “timing” to address how to respond to this problem, as well as the importance of selecting the proper remediation technique along with an EHS mold expert and Emilcott’s mold remediation strategy. (Read more: Hurricane Irene Leaves a Legacy of Water Intrusion and the Promise of Mold)

Energy Sector – Emilcott has been thrilled to be able to participate in many different initiatives within the energy sector.  Regionally important to the growth of our economy, the ongoing infrastructure improvements have given us substantial health and safety support work. In EHSWire during 2011 we addressed many occupational hazards as Occupational Heat-related Illnesses where we went over the symptoms that workers may experience, as well as what should be done if someone does experience these symptoms. Besides dealing with working conditions such as heat, Emilcott also provided information on the truths about occupational slips, trips and falls which ended up costing American businesses $13.67 billion in workers compensation costs in 2008. Adhering to proper safety protocols and preventing injuries is something that benefits businesses and their workers. OSHA provides a Walking/Working Surfaces – Safety and Health Topic page which provides links to all the applicable standards.

With issues such as heat affecting the health of workers to preventing injuries on job sites, Emilcott has seen our fair share of mishaps. Being able to share our experiences and knowledge with others never gets old. From teaching someone the hazards about working near a crane, or things you should do when working in certain environments, Emilcott has always tried keeping people in the loop. We even have a 10-Hour Construction Industry Outreach Training Course based on the requirements established by OSHA which is a very hands-on and interactive class that we recommend to avoid a future work related issue. (Read more: Work Near a CRANE? Learn the Hazards!)

9/11 Tenth Anniversary – focused the changes that have occurred since 9/11/2001 such as the new precautions that have taken place on the American Chemical Security issue.   The DHS (the Department of Homeland Security) has been increasing their focus on utilities and chemical facilities which may become targets for terrorist activities and the DHS Chemical Facility Anti-Terrorism Standard (CFATS) now requires completing and submitting a Top Screen analysis to the DHS.

The James Zadroga Act , which was authorized to broaden, renew funding and extend benefits to Ground Zero workers whose death was a result of exposure, is of great significance and has put new emphasis on the importance of proper real-time environmental site monitoring. New technologies are available to protect site workers and the public from exposure to hazardous substances such as those from the collapse of the WTC towers. (Read more: 9/11 Tenth Anniversary Focuses on American Chemical Security)

Toxic Substance Control Act (TSCA) – was of major importance not only to Emilcott, but also to facilities who are manufacturers or importers of chemicals in amounts of 25,000 pounds or greater. With so many questions regarding TSCA and the changes, Emilcott decided to put on a free webinar along with posting a number of blogs that answered many of the concerns our clients had. Emilcott was able to use its expertise and help many clients with TSCA compliance questions and concerns regarding the developments of IUR reporting and reporting obligations in 2011 for the calendar year 2010. (Read more: August 2011 Update on the TSCA IUR-now-CDR Rule)

Though Emilcott has had many remarkable memories of 2011, we felt these 4 really left an impression on our business. Emilcott is privileged to know that we were able to assist our clients in many different businesses not only in 2011, but throughout our history. Emilcott looks forward to a productive 2012 and we are excited to see what this year has in store for us.

Do you have any environmental, health or safety concerns for 2012? If so, please share them with us below!

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Topics: Emilcott, OSHA, health and safety, CFATS, Hazardous Materials, worker safety, Occupational Health, Occupational Safety, TSCA, Toxic Substance Control Act, Uncategorized, Mold

by Paula Kaufmann

We just had our first cold weather snap in the northeast reminding me that 2012 is just around the corner.  A change in the seasons is our cue to ask Emilcott clients that manufacture or import chemicals:   Have you gathered the 2010 chemical volume data AND are you collecting the 2011 data needed for the 2012 TSCA Chemical Data Report?

In a previous blog we summarized the basic requirements of the inventory, production volume and use i nformation that needs to be collected for the EPA’s TSCA 2012 Chemical Data Report (CDR). You can find this “bare bones chart” by clicking here.  The EPA recently presented the following key requirements  in this document  “ Instructions for the 2012 TSCA Chemical Data Reporting.”

HIGHLIGHTS OF 2012 TSCA CHEMICAL DATA REPORTING (CDR)

• The determination of the need to report is based on production volume during calendar year 2011.


• Information on the reportable chemical substance must be reported during the 2012 CDR submission period, February 1, 2012 to June 30, 2012 (40 CFR 711.20).


• All reporting companies must report CDR data electronically, using e-CDRweb, the CDR web-based reporting tool, and EPA’s Central Data Exchange (CDX) system. Prior to submitting data, submitters must register with CDX.


• Reporting is required for all chemical substances listed on the TSCA Inventory, both organic and inorganic, other than polymers, microorganisms, naturally occurring chemical substances, certain forms of natural gas, and water (40 CFR 711.5 and 711.6) when manufacture (including import) of those chemical substances meets the other reporting requirements. Chemical substances that are the subject of any of certain listed TSCA actions may not be eligible for partial or full exemptions (40 CFR 711.6).


• Manufacturers (including importers) are required to report full manufacturing data, for calendar year 2011, and production volume only, for calendar year 2010, for all reportable chemical substances, when 2011 site-specific production volume equals or exceeds 25,000 lb (40 CFR 711.15(b)).


• Manufacturers (including importers) are required to report processing and use data, for calendar year 2011, for all reportable chemical substances, when 2011 site-specific production volume equals or exceeds 100,000 lb (40 CFR 711.15(b)). Inorganic chemical substances are no longer exempt from the reporting of processing and use information.


• Small manufacturers are exempt from CDR requirements unless they manufacture (including import) 25,000 lb or more of a chemical substance that is the subject of a rule proposed or promulgated under sections 4, 5(b)(4), or 6 of TSCA, or is the subject of an order in effect under section 5(e) of TSCA, or is the subject of relief that has been granted under a civil action under sections 5 or 7 of TSCA (40 CFR 711.9) and (TSCA §8(a)(3)(A)(ii)). See Appendix B for further information.


• Information submitted under CDR may be claimed as confidential; however, such claims must be made at the time of submission and substantiated in accordance with the CDR rule. Submitters must provide upfront substantiation of confidentiality claims for processing and use information as well as for confidentiality claims for site or chemical identity. A blank response or a response that is designated as “not known or reasonably ascertainable” may not be claimed as confidential (40 CFR 711.30).

The EPA is frequently adding information to their Inventory Update Reporting and Chemical Data Reporting Resource page.  And Emilcott will continue to update our TSCA Resource Center with helpful information -- check in often!

If you need guidance with the information that you should be gathering (starting now!) for the EPA TSCA 2012 CDR Submission, please contact Emilcott!.You can also subscribe to our TSCA newsletter to be kept up to date and enroll for our free webinar (date to be announced soon) by sending an email to pkaufmann@emilcott.com.  Feel free to post any questions below in the comments section and we will respond quickly.

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Topics: Emilcott, General EHS, EPA, Compliance, TSCA & R.E.A.C.H., TSCA, CDR, Toxic Substance Control Act, submission, IUR, Form U, chemical manufacturer, importer

by Paula Kaufmann

Upcoming TSCA Reporting Period:  February 1 - June 30, 2012.

As of August 6, the EPA has finalized the TSCA IUR -- now named the Chemical Data Reporting (CDR) – Rule. There are many changes with the TSCA IUR to CDR  … some of these will be in place for the 2012 reporting submission and many more for the 2016 submission.

The final rule adopted many of the requirements included in the proposed rule (see What are the Changes?) -- and, thankfully, the majority are not retroactive. At Emilcott, we are asking our clients to define what needs to be collected for the 2012 submission period with 2011 as the Principal Reporting Year. If your facility uses chemicals or is an importer who falls under TSCA’s CDR guidelines (remember, they’ve changed!), your company will need to collect more data and information than that originally planned for the 2011 IUR submission. The chart below is a bare bones list of the inventory, production volume and use information that needs to be collected for the 2012 Chemical Data Report (CDR). And, as stated earlier, your 2016 submission will have even more requirements.

Submit Your Form U Electronically

For the 2012 CDF, all submissions will be required to use the EPA’s free, web-based reporting tool, e-CDRweb, for completion of Form U. In preparation, the EPA will schedule another informational webinar on the electronic submission tool in late September with beta trials completed by early October. Please ask Emilcott if you will need help with the Form U filing.

Additional TSCA Information

Emilcott has set up an online “ TSCA Resource Center” and over the next few weeks will be creating a dedicated TSCA landing page to contain all the information related to both the CDR Final Rule and other TSCA New and Existing Chemicals topics. Links to all EHSWire TSCA blogs will also be located there for quick reference. If you have any questions or would like to consider Emilcott as a TSCA consultant, please give us a call at 973-538-1110 or send an email to pkaufmann@emilcott.com

Did you miss the TSCA 2006 Form U submission?

You must notify the EPA that you missed reporting for the 2006 IUR within 21 days of your discovery.  The EPA has an Audit Policy for Self-Disclosure in which drastic fine reduction is possible if the requirements outlined by the Agency are met.  This policy is presented on the EPA Compliance Incentive and Auditing web site ( http://www.epa.gov/compliance/incentives/auditing/auditdisclose.html). If you would like help, Emilcott has been brought in to work with multiple US and International clients with US facilities that inadvertently missed the Form U deadline due to either misunderstanding or ignorance of the regulations. Our advice is to not wait!

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Topics: Emilcott, General EHS, EPA, Compliance, TSCA & R.E.A.C.H., TSCA, CDR, Toxic Substance Control Act, submission, IUR, Form U, chemical manufacturer, importer