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Environmental Health and Safety Blog | EHSWire

DELAYED!! TSCA Form U Submission 2011 Period

Posted by Shivi Kakar

May 15, 2011 11:56:18 PM

Paula Kaufmann, CIH

We have some news on this year’s TSCA IUR Form U submission.  Well, it really isn’t information about the requirements – but we do know that this year’s Form U submission period will not be June 1 to September 30.  It will most likely be later this year.  So, we all can move that task to another segment of the calendar year!

More Information


On May 11, 2011, the EPA issued a Federal Register Notice amending the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) regulations by delaying  the June 1 to September 30 submission period for the 2011 Form U reports.  The notice indicated that this delay will not alter the timing of subsequent submission periods (e.g., the submission period from June 1, 2016 to September 30, 2016).  This is an interesting statement as one of the changes included in the proposed IUR Rule is a change of the reporting period cycle to every four (4) years from the current five (5) year cycle.

The EPA is delaying the submission period because the proposed IUR modifications rule has not yet been finalized.  EPA expects to have the final version of the changes to the IUR reporting requirements in the near future. The revised 2011 submission period will be announced with the publication of the final IUR modification rule. 

How does this delay what the EPA rule refers to as a “suspension” affect what needs to be done for the 2010 reporting period?  It seems that the EPA will mandate a new submission period but it is not clear when this will be during 2011.

  • We are assuming that the reporting period will remain as the 2010 calendar year. 

  • Our next assumption, or guess, is that the Form U submission period will shift to September 1 to December 31, but that will require that the final rule on the IUR modifications be published very soon.


“Food” for Thought…


As recently as March 4, 2011, representatives from the American Petroleum Institute (API) met with the EPA presenting concerns about several aspects of the proposed IUR modifications rule.  One topic the API presented was that when the last set of revisions of the IUR was finalized in 2003 with the next reporting period was extended by one year shifting from 2004 to 2005 with Form U submission in 2006.  During 2004 and 2005, the EPA held many workshops and issued clarification and guidance documents.

And, for now, we wait for the Final Rule and hope that the data we have all collected for the 2010 reporting period will be adequate.  Emilcott's recommendations for what to do while we wait are in my January blog:  “ TSCA IUR Update – What Are the Changes ?”. Essentially, we are advising our clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Here are a couple of items to keep on your radar:

  • Be sure your list of manufactured chemicals is complete.  Your list should be based on all chemical processes and imported materials received at the site and not just on the products.

  • When calculating individual substance volumes – include imported mixtures with those manufactured at the site aggregating all mixtures containing that substance. 


...And, Emilcott will continue to keep you posted!

What to do if you need help or have questions?


If you need assistance related to the TSCA New Chemicals regulatory requirements or the potential changes due to the Inventory Update Reporting Rule, Emilcott can guide you through the reporting.  We can also help you navigate the maze of reporting a potential Form U violation from prior filing years to the EPA (See http://www.emilcott.com/services/svcenvcompliance.asp). 

As more information becomes available from the EPA regarding the IUR and as testing of the electronic tool begins, Emilcott will keep you up-to-date via EHSWire and our "Regulatory Updates" Newsletter.  

Please give me a call at 1-800-886-3645 or write a comment below if you have any questions or additional information to contribute.
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Topics: Emilcott, health and safety, General EHS, EPA, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, reporting, regulation, chemicals

You Better be Qualified if You are a Respiratory Protection Program Administrator!

Posted by Shivi Kakar

Mar 21, 2011 2:31:48 AM

by Paula Kaufmann

What’s the job of a Respiratory Protection Program (RPP) Administrator? 


This individual is officially listed in the site’s written Respiratory Protection Program and is accountable and responsible for the day-to-day operation of the program. Some of those “day-to-day” tasks include

  • Maintaining the site Respiratory Protection Program

  • Assessing the workplace for potential respiratory hazards

  • Defining worker exposure for these hazards

  • Selecting appropriate respirators to provide protection from defined hazards

  • Ensuring

    • Medical evaluations are conducted of employees required to wear respirators PRIOR to fit testing

    • Respirators are fit tested for all required users

    • Proper use of respirators during routine and emergency operations

    • Respirators are appropriately cleaned, disinfected, stored, inspected, repaired, discarded, and maintained

    • Adequate air quality air is supplied if supplied air respirators are used.

    • Respirator users are trained in respiratory hazards, and the proper use and maintenance of respirators

    • Periodical evaluation of the Respiratory Protection Program implementation

    • Workers who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation, and cleaning, storing and maintenance requirements of the standard

    • All voluntary-use respirator users understand Appendix D of the standard




Yes, these incessant and critical health and safety tasks can be quite overwhelming!  What’s the big deal? For the company or job site or administrator who does not understand why a qualified and empowered RPP Administrator is a big deal, here is a triple-play of Top 5 facts that illustrate the importance of qualified training for Respiratory Protection Program Administrators!

Top 5 OSHA Violation!


Did you know that the Respiratory Protection Standard was in the Top 5 most frequently cited standards by OSHA compliance officers last year?  Why be a part of that statistic?  More about 2010’s Top 10 cited violations can be found in a recent EHSwire blog by Emilcott’s Sarah Damaskos.

Top 5 Reasons YOU need to be “Qualified”



  1. Workers at your site are required to wear respirators for protection from respiratory hazards – and you selected these respirators.

  2. You train respirator users on how to put on and take off their respirator – along with the limitations on their use, and their maintenance.

  3. Implementation of the site respiratory protection program (which you wrote) is just another one of your jobs!

  4. Airline (atmosphere-supplying) respirators are used at your site – and you make sure that an adequate air supply, quantity, and flow of breathing air is available.

  5. You coordinate the medical evaluation of employees who must use respirators.


Top 5 OSHA Compliance Indicators!


If you get a visit from an OSHA Compliance Safety and Health Officer, they review these essential factors to help determine if the Respiratory Protection Program Administrator is “Qualified”:

  1. The written Respiratory Protection Program and interviews with the program administrator reveal an understanding of the familiarity with the respirator standard, site respiratory hazards, and the use of the respirators in the workplace.

  2. Respiratory fit testing is conducting annually or at assignment and the program administrator maintains.

  3. Hazardous airborne contaminants that employees may inhale have been identified.  Reasonable estimates of employee exposures were used in determining the appropriate respirator for employees to use.

  4. Recent changes in the workplace such as new processes have been evaluated for necessary respiratory program changes

  5. The program administrator keeps a written assessment of the program operations and implements changes that may be considered as efforts toward improvement.


How to Become a Qualified RPP Administrator


Focused, hands-on training with experienced health and safety instructors can make the difference for a Respiratory Protection Program Administrator – clarifying the waters by understanding the objectives of the law and how it applies to each work site!

As Health and Safety consultants to many types of companies, Emilcott staff are on job sites each day and see health and safety violations such respirators perched on foreheads or tissues jammed in the sides to ensure a bitter fit. Are these problems an employee violation or a company-wide result of not understanding the importance of a competent Administrator who can develop, maintain and enforce a respirator protection program that reduces occupation risk?

In these cases, we conduct urgent and immediate on-site RPP Administrator training that often includes high level managers to ensure that there is a top to bottom understanding of the importance of proper respirator usage. In addition to our private training, the Emilcott Training Institute offers public enrollment Respiratory Protection Program Administrator training courses in two formats:  an intense 3-hour course with a small class size and an in-depth two-day course.  In both classes, students learn the level of information required for their sites and are taught by an experienced H&S instructor that can answer questions. 

So if you are unfamiliar with your required duties as an RPP Administrator or you want a better understanding of how to encourage better respirator usage by your site personnel, look around for an effective RPP Administrator training class. Once complete and in practice, you should dicover aTop 5 list that looks more like this:

  1. OSHA respirator inspection passed without any problems, fines or additional action.

  2. Site personnel actively wear their respirators – the way that they are supposed to!

  3. Site workers reinforce the importance of respirator use to their colleagues (even when you’re not around)!

  4. Managers understand the need for respirator use and support related site activities such as testing of hazardous airborne contaminants.

  5. Written assessments of program changes are treated as a necessity for business to move forward rather than resented.


You ARE a Qualified Respiratory Protection Program Administrator!

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Topics: Emilcott, OSHA, Personal Protective Equipment, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Fire Safety, Exposure, Respiratory, Occupational Training, RPP, respirator protection program, administrator

Hazardous Waste How-To for Manufacturers, Laboratories and other General Industry Companies

Posted by Shivi Kakar

Mar 14, 2011 7:27:43 AM



Carrie Bettinger, CHMM, CSP

As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our “General Industry” clients in an effort to lift their game with dealing with hazardous waste.  There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan!  The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.

The Rules


The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage  and disposal of Hazardous Waste, which “ General Industry” businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; …well, just about everyone) needs to know!
OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA's general industry standards, directives, and standard interpretations.

Give me an R! Give me a C ! Give me an R! Give me an A! What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t have a side business of burying industrial waste on the family farm.   RCRA is a complex law with lots of parts and many industries are affected by its components.  In addition to being complex, the text of the Act with all of its parts and sections is hard to follow.  My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262) . RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training.

But the EPA’s RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site.  The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H.   The International Air  Transport Association (IATA) has rules for the air transport of hazardous materials ( http://www.iata.org/) including training requirements.

To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s hazardous materials in DOT and IATA eyes.  For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.

The Required Training


So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have -- per both EPA and DOT/IATA.

All employees at sites that generate hazardous waste need to be trained in how to:

  • Properly identify what qualifies as regulated “Hazardous Waste” per federal (EPA) or your state requirements.

  • Know where to properly dispose of any hazardous waste you may generate (I will give you a hint:   It’s NOT down the sink drain!).

  • Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.


Employees who are designated as responsible for the management and control of this hazardous waste need additional training. And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to

  • Properly label containers

  • Implement accumulation area requirements and time-on-site limits

  • Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems

  • Complete Hazardous Waste shipping manifests

  • Ensure proper shipping methods and a qualified transporter are used

  • Develop site-specific procedures

  • Know and implement emergency procedures and site contingency plans


Refresher Training


A common point of confusion is when refresher training is needed for employees.  The DOT and EPA have two separate requirements:

  • The EPA requires annual refresher training for their regulations.

  • The DOT requires refresher training every 3 years for their regulations.


And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations .

The Bottom Line

We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans – everything that DOT/IATA and RCRA training develops for your company – are vital in the cleanup of the environment and protection of employee and public health and safety.

For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott.  As part of  The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA:
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Topics: Emilcott, OSHA, DOT, General EHS, EPA, Emergency Response, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, Lab Safety & Electrical, regulation, General Industry, emergency response training, Occupational Training, IATA, Resource Conservation and Recovery Act, Lab Safety, hazwaste, transportation, hazmat, generation, RCRA

Need a Paradigm Shift with Safety Attitudes at your Manufacturing Site? Try OSHA 10-Hour Outreach Training for General Industry

Posted by Shivi Kakar

Mar 7, 2011 1:13:18 AM

Martha Hernandez

When it comes to training, OSHA takes it seriously. With good reason:  training keeps workers safe and reduces incidents.  Many OSHA standards specifically require the employer to train employees in the safety and health aspects of their jobs. Other OSHA standards require the employer to make sure that only certified, competent, or qualified workers are assigned specific tasks--meaning that they have had special previous training.  OSHA compliance officers look to see that employers have provided appropriate training to their employees.  

In an effort to improve the consistency of the quality and content of health and safety training, OSHA has developed a series of “Outreach” training programs.  OSHA Outreach training focuses on segments of labor in the business sectors of General Industry and Construction and Maritime Industries. The courses are either 10 or 30 hours in duration with strict agenda guidelines containing focused and topical material, and must be taught by instructors that have extensive training and are approved to deliver the instruction.  The instructors or “Authorized Providers” must attend OSHA train-the-trainer courses, adhere to rigorous standards, and are subject to unannounced audits by OSHA at any time.  Over 3.2 million workers have participated in this type of training over the last 5 years!

In today’s blog we will look at the General Industry Outreach Training.

What is General Industry Outreach Training?


“General Industry” is defined by OSHA as any industry not directly involved with agriculture, construction, and maritime industries.  The standards applicable to General Industry are contained in Section 29 of the Code of Regulations, Part 1910.  As a result of the broad “General Industry” definition, one of the most popular OSHA Outreach courses is the 10-hr General Industry Training  which teaches safety and health hazard recognition and prevention.   OSHA Outreach training focuses on segments of labor in the business sectors of General Industry and Construction and Maritime Industries.

Who Should Attend a 10-hour General Industry Training Course?


The OSHA 10-hour General Industry course is designed for plant superintendents and engineers, floor foremen, safety professionals, project managers, and any other personnel responsible for workplace safety. Indeed, many organizations include all their plant personnel in this training because EVERYONE is responsible for safety. This course is an excellent introduction to health and safety programs for new employees or when it is time to create a paradigm shift in attitudes about safety at a facility.  The General Industry course can help line management get “safety religion”!  In fact, OSHA recognizes the completion card as an indication of the importance of safety and health at an organization.  Workers’ Compensation insurance providers often will reduce rates for companies that provide this training to their staff.

Emilcott’s OSHA 10-Hour General Industry Course


Based on the firm guidelines provided by OSHA, Emilcott’s 10-hour General Industry course provides important information about how OSHA is involved in the general industry community and how employees can recognize and control common workplace hazards. The training focuses on recognizing and controlling hazards found in the industrial workplace. It assumes no prior training nor requires prerequisite training. Much of our 10-hr General Industry course is interactive and hands-on.  More importantly, our courses are taught by instructors with real-world experience. Credentials and certifications provide a way to verify competency in particular fields but real-world experience should not be discounted. It’s one thing to talk about electrical hazards, it’s quite another to actually work around them. This experience allows our trainers to put the material in perspective and helps students make the connection between theory and practice.

Quality Training Makes a Difference


We have found that the OSHA Outreach Courses for both Construction and General Industry help site management really “get it” when it comes to site safety!  This training has given new life to existing safety programs and initiatives at our client sites.  Have you seen safety training make a difference is program compliance at your sites?
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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, General Industry, Occupational Training

The Benefits of Instructor Led vs Online HazWOPER Training

Posted by Shivi Kakar

Feb 28, 2011 6:02:05 AM

by Paula Kaufmann

I have attended some incredibly mind-numbing courses over my lifetime.  The worst course ever was in high school American History when we were “taught” about the FDR Years (1933-45) from an endless series of film strips with audio from a synchronized record. Recently, I attended a full-day, on-demand technical class that immediately transported back to that American History lesson. Needless to say, this comparison does not reflect well for this recent course.

I find I don’t take away much from a course that does not engage me. This could be because the topic is inherently dull, the material is presented in a monotonous or non-engaging manner, or I simply can’t connect with the material or the instructor.  I’ve often joked that I am easily entertained (after all, I am a chemist by training!), but dull, monotonous and distant often leave me with zero recall of the main points, and the details, well, those never seem to penetrate my numb mind!

On-line or Classroom HazWOPER?


In a previous EHSWire blog, Vijay Chintamaneni noted, “ When evaluating the courses based on their published description, Online Training and Instructor Led Training (ILT) may look the same, so it is wise to understand the benefits and drawbacks of both before making a final decision. This is especially important for occupational health and safety training.”

So, when I am asked for my thoughts on whether to attend an on-line or instructor-led HazWOPER training class, my immediate response is clear!  It is CRITICAL to actually learn what is taught in these classes not just fulfill the OSHA requirement.  Why? These workers will be working on a HAZARDOUS WASTE SITE, and the knowledge learned in a HazWOPER class allows them to appropriately protect themselves. Students in a HazWOPER class must be engaged in this particular occupational learning as the material is inherently dry and dull.  The best way to imprint essential HazWOPER components such as risk assessment, hazard information, team emergency response and the practical learning, is from discussion, hands-on and group exercises.  

Training experts insist that hands-on training is the best way to learn!


Consider these situations the next time you consider online training to meet your HazWOPER requirements:

  • Would you SCUBA dive in the Florida Keys after completely an on-line SCUBA diving lesson (without ever handling the equipment on land or even in a pool)?

  • When you call 911 – would you trust an emergency responder that recently received CPR training on-line  without any practice or instructor guidance?

  • Would you lend your car to a friend who just learned to drive by completing an on-line driving class?

  • If folks need to be trained to work as a team with a command/response structure – how successful can team training be when individuals are trained in isolation?

  • How many other things do you do while you are “attending” an online course?

  • Do you really want the guy next to you at the hazardous site to be responsible for your health after taking critical health and safety training…online?


Why the Emilcott Training Institute? Because you will LEARN and be prepared!!


Emilcott offers quality HazWOPER health and safety training that prepares workers for the real world by keeping them engaged and interested in the materials! Our HazWOPER instruction combines classroom knowledge with interactive, hands-on activities, respirator fit-testing, individual and group activities, and a simulated, outdoor hazardous waste operation complete with “what if” scenarios and instructor guidance.

  • The Emilcott 40-hour HazWOPER mock drill is chock full of “what if” scenarios such as unidentified hazards, nosy neighbors, health and safety incidents, decontamination exercises, use of instruments, and more.

  • We film our mock drill and then evaluate the results in class.

  • We have taught thousands of HazWOPER training classes – many of them for the US Armed Forces in the states and Europe.

  • Our 8-hour Site Supervisor course concentrates on group exercises and managerial experience to reinforce essential skills needed to ensure the health and safety of the crew while getting project work completed without incident.

  • We interview our students to ensure that the materials presented are as applicable to their job function as possible.

  • Our annual 8-hour Refresher is revised each year to ensure well-rounded exposure for our repeat students.

  • We train students, but we do not pass students who don’t qualify!


What is the importance of a good instructor?


Emilcott HazWOPER instructors are field-experienced health and safety professionals who have seen it all!  In fact many of our instructors have been working on hazardous waste sites and training for over 25 years. Emilcott instructors consist of

As HazWOPER instructors, their job is to review the OSHA-required materials in such a way that students can remember the materials and apply them to their job.  Through a variety of media, discussions and exercises Emilcott ensures that our 24-hour, 40-hour or 8-hour HazWOPER class is as practical and hands-on as possible!

Understand Yourself and the Impact of Effective Training


As a CIH consultant with a family and other obligations, it is always a challenge for me to squeeze in occupational training. After all, time spent learning does compete with project work, and there are only so many hours in the week!  With such a tight schedule, sitting in on a webinar or other type of on-demand learning is easier to squeeze into my schedule. Conversely, I also know that attending a course in a classroom with a qualified instructor is a far better option for learning and applying critical health and safety information that I will need on the job. As a result, whenever I have the option between online or instructor-led, especially for a dreaded or boring topic, the best option is to block out the time for classroom learning; my distractions are reduced, my attendance and alertness is required and, now that I’ve set aside the time, my focus is on learning the most and maximize the opportunity. 

Have you ever taken an online, technical course? What were some of the distracting activities you did while “learning”? My personal favorites are cleaning up my email or wallet! Have you ever taken a technical course for multiple days and walked out of it remembering almost next to nothing and thinking, “Oh, that was a waste!” Has that experience affected your training selection process?
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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, Hazardous Waste Management, Compliance, Occupational Health, Occupational Safety, class, Occupational Training, HazWOPER, training

Renovations to Older Buildings: Think About Lead Paint (and More) or Repent!

Posted by Shivi Kakar

Feb 19, 2011 9:12:51 PM

Genya Mallach - CSP

As part of a standard, pre-work permit inspection by the local township, it was discovered the exterior of a church (and local pre-school) had been painted with lead-based paint!  Unfortunately, the estimates to remove and repaint the church were far beyond the church’s budget. At the acrimonious and finger-pointing church review meeting, a voice suddenly called out, “I’ll take care of it for half the cost of the lowest estimate!” Salvation!

However, when the contractor began the job, he learned that the cost of removal and repainting would be much more than he expected. In a panic, he did not remove the old paint and, to save materials cost, he diluted the new paint by 50% with water!

After the job was completed, a joyous church service was held to honor the contractor. In the midst of the service, a thunderstorm broke out and the congregants began to notice that the paint was literally washing off the building. The bewildered minister raised his arms and called out, “Oh, Lord, what are we to do?"  In reply, a booming voice from above called out, “Re-paint! Re-paint!”

I suppose the EPA heard this story as well because, on April 22, 2008, the EPA issued a rule requiring the use of lead-safe practices when engaging in renovation and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978. Under the rule, beginning April 22, 2010, contractors must be certified and must follow specific work practices to prevent lead contamination. Individuals can become certified renovators by taking an eight-hour training course from an EPA-approved training provider.

This rule applies to all renovations performed for compensation in “target housing” (housing constructed prior to 1978, except housing for the elderly or persons with disabilities --unless a child of less than 6 years of age resides or is expected to reside) and child-occupied facilities, except for the following:

  1. Renovations in target housing or child-occupied facilities in which a written determination has been made by an inspector or risk assessor that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams/per square centimeter (mg/cm2) or 0.5% by weight, where the firm performing the renovation has obtained a copy of the determination.

  2. Renovations in target housing or child-occupied facilities in which a certified renovator, using an EPA recognized test kit and following the kit manufacturer's instructions, has tested each component affected by the renovation and determined that the components are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.


Lead poisonings in an office or domestic setting are mostly caused by exposure to lead dust. Here are a few facts:

  • Lead dust settles quickly on floors, window sills and other surfaces.

  • Paint repair can generate lots of lead dust.

  • Broom sweep won't clean up lead dust.

  • Lead-contaminated dust is invisible to the naked eye.

  • Initially, lead poisoning can be hard to detect — even people who seem healthy can have high blood levels of lead. Signs and symptoms usually don't appear until dangerous amounts have accumulated.

  • Lead usually targets the oxygen-carrying protein in red blood cells (hemoglobin) first. In time, it attacks the nervous system.


BEFORE conducting any renovations on older buildings, it's important to understand the hazards that may be discovered as construction continues. Determining if the interior or exterior paint contains lead, if any materials of construction contain asbestos, and if water intrusion has occurred anywhere in the building during its lifetime (wet building materials are a food source for mold) is the first step toward creating a healthier building.

Emilcott regularly assists clients who face building environment investigations such as indoor environmental quality, asbestos and lead management, microbial contamination and vapor intrusion. Our EHS staff work with building managers to quickly learn how their buildings operate, diagnose conditions, complete inspections of building systems, interview occupants, and advise on the best course of action to ensure that the building is a safe place to live, work or play.

Interested in reading more on keeping buildings healthy? Other EHSWire blog posts about building environments include:
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Topics: Emilcott, health and safety, General EHS, Construction H&S, EPA, H&S Training, Compliance, worker safety, Air Sampling, Mold, asbestos, Exposure, environmental air monitoring, Respiratory, lead, lead-based paint

Does DOT/IATA Training for Transportation of Hazardous Materials Prevent Incidents?

Posted by Shivi Kakar

Feb 14, 2011 3:11:26 AM

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

OSHA Recordkeeping 300A…It’s For You and the Rest of the Country!

Posted by Shivi Kakar

Jan 31, 2011 1:59:49 AM

Paula Kaufmann, CIH

Did you know that the OSHA Illness and Injury Summary Log, 300A, is used for more than just recordkeeping at your site?  By documenting your company’s illness and injuries properly, you shape OSHA’s future initiatives!  Specifically, OSHA Summary 300A Forms are gathered by the OSHA Data Initiative (ODI) to help direct OSHA programs and measure its own performance.  

How does OSHA get this information?

OSHA gets these data from two sources:

  • As part of an annual survey, the Bureau of Labor Statistics (BLS) sends injury and illness survey forms to randomly selected employers and uses the information to create the Nation's occupational injury and illness statistics.

  • The OSHA Data Initiative mails its annual survey (in June) that collects data on injuries and acute illnesses attributable to work-related activities in private-sector industries from approximately 80,000 establishments in selected high hazard industries. In 2010, OSHA also collected this information from approximately 20,000 establishments in the construction industry in addition to the non-construction establishments. The Agency uses these data to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities. Traditionally, OSHA collects data from the establishments that meet the following categories, but as we saw in 2010, OSHA can expand these criteria.

    • Non-construction industries with 40 or more employees are chosen randomly

    • Non-respondents in the previous collection year

    • Site with an inspection or consultation visit for performance measurement

    • DART rate (days away from work, restriction or transfer) of 7.0 or higher in previous data collection




Does the data really help OSHA?

Now that OSHA has the data from BLS and the ODI, the Agency uses the information to

  • Calculate and establish specific injury and illness incidence rates

  • Develop targeted intervention programs (i.e., inspections and enforcement action)

  • Assist inspectors so that they can direct their efforts to the higher incidents hazards that are hurting workers.

  • Measure the success of agency efforts to reduce the number of workplace injuries and illnesses in select high-hazard industries

  • Provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation's primary source of occupational injury and illness data.


What is your role?

Be a savvy and educated reporter of your company’s illness and injury information. Understanding the OSHA 300 log reporting requirements will ensure an accurate portrayal of worker health and safety as well as maintaining OSHA compliance. Can you answer the following questions?

  • How do I complete the OSHA 300 Log and Form 301?

  • Am I required to post an OSHA Form 300A ? How do I know if I am exempt? 

  • What is classified as a work-related illness or injury? 

  • How do I fill the forms in correctly without over-reporting?

  • Do I have to fill in the form if I have no recordable injuries or illnesses in the previous year? What are the rules for posting?

  • Once the form is filled in and submitted, if requested by BLS or OSHA, are there other legal requirements I should know?


Not convinced that recordkeeping is important?

Besides providing a visible record of worker safety benchmarks and improvements (or worse, tragedies and reversals), establishments that are requested to but fail to submit a completed data collection form may be subject to OSHA enforcement actions, including the issuance of a citation and assessment of penalties!  So, take the time understand OSHA’s reporting requirements and implement them correctly – it affects your company and the nation’s workers.

If you need assistance with OSHA recordkeeping, Emilcott offers a variety of ways to help your business stay in compliance from a webinar-based course that outlines the rules and regulations to the development of complete health and safety plans. Or, if you have an OSHA recordkeeping question, just ask us!
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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Compliance, worker safety, Occupational Health, Occupational Safety, Webinar, reporting, regulation, Medical Records, BLS, Bureau of Labor Statistics

The Future of Air Monitoring: Real-time Particle Size Measurement

Posted by Shivi Kakar

Dec 12, 2010 9:31:15 PM

Bruce Groves

Why do we care about particles floating around in our air? Small, inhalable particles are themselves pollutants that have shown to cause illness and chronic diseases such as asthma and certain types of lung cancer . Particles are also excellent indicators (or surrogates) for measuring other pollutants such as vapors and gases. By measuring the aerodynamic size of particles in our air, it is possible to identify and sometimes “fingerprint” them so that we can reduce or stop local sources of pollution immediately. The goal AND end result are to develop as clean a living and working area as possible.

What are we doing today?


Today, air monitoring is a piecemeal approach that is government-mandated but generally project related. When the project is over, the problem is essentially considered to be gone. Of course, in areas of high population density or industrial activity, continuous, real-time air monitoring of general conditions does not exist. Other than pollen counts, very little information about these pockets of high pollution and high particulates is available to the public or government agencies. And, the data that is available is generally much later and does not present an accurate picture of today’s problem.

What is the future in environmental air monitoring?


As technology has improved, so have particle detectors and the ease of data transmission and analysis. By 2013, small particle size detectors, such as those found in the Greenlight Environmental Monitoring System, will be consistently deployed in high population areas in such cities such as NYC, Tokyo, London and Los Angeles. These particle size detectors will be coupled with wind-speed and direction detectors and web cameras to pinpoint the exact sources of particle emissions (e.g., construction or industrial equipment, idling vehicles or high traffic transportation corridors) that are creating a measurable increase in local air pollution.

This web of detector stations will form an active or “live” map of a city that continuously measures and reports the concentration of various particle sizes. The “map” will be automatically programmed to provide warning levels and alarms to reveal when and where total particle concentrations exceed warning and safe threshold levels. By locating (in real time) the place, the direction of the pollution source and supporting video evidence, private companies and government agencies can take measures to stop or reduce the indicated pollution sources. Constant real-time monitoring, assessment and action will provide continuous improvement in local air quality that will reduce the onset of disease associated with inhaling dirty air. Warning systems set up through websites will enable agencies and individuals to check on their local air pollution conditions using their computer or smart phone.

What is the first step?


At Emilcott, we have been working with particulate monitoring on job sites for over 25 years. As an extension of our field experience, we’re working on a solution that meets the needs of our clients (private companies and government agencies) -- the Greenlight Environmental Monitoring System. With multiple project implementations under its belt, the Greenlight System’s particle size measurement, assessment and reporting capabilities are demonstrating how real-time monitoring is helping projects get cleaner each day – reducing the liabilities of our clients while giving them the information to keep the public and workers safe.

As the Greenlight System’s next phase of engineering development is outlined, our goal is to have a universal system that will provide comprehensive sampling in potentially high pollution areas so that neighborhood air quality can be improved and the incidence of lung disease is reduced. It will be a future watchdog for providing cleaner air locally where no such means of protecting local air quality exists today.

What do you think the future of environmental air monitoring holds? What are the benefits or challenges that you associate with monitoring and mapping pollutants in a broad geographic area?
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Topics: Emilcott, indoor air quality, health and safety, Construction H&S, EPA, Emergency Response, Homeland Security, Hazardous Waste Management, Hazardous Materials, worker safety, Occupational Health, Air Sampling, Greenlight System, Exposure, environmental air monitoring, Respiratory, Public Safety, perimeter air monitoring

OSHA’s Top 10 Most Cited Violations – What does it mean?

Posted by Shivi Kakar

Dec 5, 2010 9:53:02 PM

Sarah Stibbe Damaskos



Did you know that, in fiscal year 2010, OSHA issued approximately 94,000 citations?  Using this data, OSHA has recently released its Annual Top 10 list of Most Cited Violations.  OSHA releases this list every year – why? Paula Kaufmann, a CIH at Emilcott, thinks OSHA is telling us where we need to focus!  Use it as a warning or indicator that that OSHA is monitoring these trends and will be targeting companies most likely to have employees working with these hazards. 

At Emilcott, we provide health and safety guidance and support for hundreds of clients that range in size from small, family-owned businesses to Fortune 100 companies with facilities throughout the world. Our EHS consulting work familiarizes us with all types of facilities and a wide range of health and safety issues. One common thread brings these different companies and industries together:  when they embrace a company-wide safety culture they reduce their risks. So, when we look at the categories and the sheer volume of violations (47,000!) that support OSHA’s Top 10, we know that the solution for every violation is universal:   safety training and commitment to creating a safe work environment with management leadership and employee involvement! With a top to bottom buy-in on the importance and value of safety, occupational hazards are observed, analyzed and prevented.  We have seen injury (and insurance) rates drop for our clients that have genuinely adopted this approach.  Some clients have even won highly competitive projects with their safety performance making the winning difference!

Let’s get back to this year's Top 10 categories. From year to years this lists stays virtually the same, but what we strive for, as occupational health and safety professionals, is a reduction in the number of incidents (and violations). 

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees.  As we review just the top 5 violations of 2010, consider if your company is providing adequate training and support to create a safe and healthful workplace for you.  Do you work in a culture of safety? What can you do to make your workplace safer for yourself and your coworkers?  Does your company understand the complete cost of ignoring occupational safety practices? 

1)  Scaffolding (OSHA 29 CFR 1926.454)

Training Solution:   At a minimum – Scaffolding awareness, approximately 2-3 hours of training investment. 

Learn More:  “ When OSHA revised its scaffolds standard in 1996, BLS [Bureau of Labor Statistics] studies showed that 25% of workers injured in scaffold accidents had received no scaffold safety training, and 77% of scaffolds were not equipped with guardrails. OSHA estimates that informed employers and workers, in compliance with correct safety standards, can save as many as 50 lives and prevent 4,500 accidents every year. In a recent BLS study, 72 percent of workers injured in scaffold accidents attributed the accident either to the planking or support giving way, or to the employee slipping or being struck by a falling object.”

2)  Fall Protection (OSHA 29 CFR 1926.503 & 1926.1060)

Training Solution:  OSHA requires training for anyone working on elevated surfaces, an approximate 2-4 hour training investment per person  This includes above excavations!  There is a requirement for Competent Person as well (to ensure that everyone is following the requirements and the equipment is appropriate).

Safety Violations Cost:  “ The U.S. Department of Labor's Occupational Safety and Health Administration has cited, a residential roofing contractor in Belleville, for violations in connection with fall hazards. Proposed penalties total $106,400.”

 3)  Hazard Communication (OSHA 29 CFR 1910.1200 & 1926.59)

Training Solution:  OSHA requires employers to provide employees with effective information and training on hazardous chemicals in their work area.  This means an initial training (1 to 2 hours) and follow-up training when new chemical hazards are brought onsite or when employees have new job tasks involving new chemical hazards.  Maintaining an accurate, up-to-date list of substances and a Material Safety Data Sheet (MSDS) for each substance  are also required.

Learn More:  Find out more about Hazard Communication here and, as global harmonization moves forward, talk to your health and safety staff about new developments or subscribe to updates from this OSHA site

Safety Violations Story: Young Workers:  Robert

4)  Respiratory Protection (OSHA 29 CFR 1910.134 & 1926.103)

Training Solution:  All employees who are required to wear respiratory protection, including filtering face pieces, must be properly trained how to use and care for a respirator-- this takes about 1 hour. Medical Clearance and Respirator Fit-test is also required, as is the assignment of a Respiratory Protection Program Administrator who should be properly trained in this task (about 8 hours).

Learn More:  Why Proper Respirator Protection Lets You Breathe Longer (and Breathe Easy)

5)  Ladders (OSHA 29 CFR 1910.26)

Training Solution:  Employees should be trained to properly use ladders and to recognize the hazards from falls while using ladders and stairways. This is generally a 30-minute training investment and can be part of regularly scheduled Tool Box Talks. OSHA also requires Ladder Inspection Program to remove and destroy defective ladders.

Learn More: “ OSHA rules apply to all stairways and ladders used in construction, alteration, repair, painting, decorating and demolition of worksites covered by OSHA’s construction safety and health standards” and this quick guide to portable ladder-related falls”.

So, are you concerned that you could be caught, written up and fined by OSHA due to safety violations?  Then, you need the Emilcott Training Needs Assessment Tool!  It’s free and is designed to help you determine which employees need health and safety training to meet regulatory compliance specific to your operation.

Here’s a final interesting  statistic:  According to OSHA, an effective safety and health program forms the basis of good worker protection and can save time and money—about $4 for every dollar spent—and increase productivity and reduce worker injuries, illnesses and related workers’ compensation costs.  Now that’s an investment that makes sense to your workforce and your wallet (and keeps you off OSHA’s top 10)!
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Topics: Emilcott, OSHA, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Safety Training in Spanish

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