Environmental Health and Safety Blog | EHSWire

Bruce Groves - CIH

In July, David Michaels, Assistant Secretary of Labor for Occupational Safety and Health, published a memo to his staff at OSHA highlighting several new approaches that OSHA is using (or planning to use) in its effort to protect workers.  Dr. Michaels is building on the progress of his predecessors and reinforcing some of the weak links in the system created both by Congress and former administrations. In his recent letter, Dr. Michaels reviews some legacy issues that limit OSHA-influence in creating safer workplaces such as

• OSHA has only 2,000 inspectors responsible for the health and safety of 130 million workers at 7 million worksites


• OSHA fines are too small to have an adequate deterrent effect


• OSHA standards provide limited protection to whistleblowers from retaliation


• OSHA occupational exposure standards have been established for only a small percentage of chemicals used in US workplaces (most of those are based on out-of-date science) with a slow and resource-intensive standard-setting process

Dr. Michaels states that OSHA needs to transform how it addresses workplace hazards, and in its relationship to employers and workers. As such he outlines a new strategy that is a clear shift from recent years indicating that there is a “new sheriff in town” and business (ALL businesses) should take heed.  Here are some of my extrapolations and thoughts regarding 6 of these transformational items -- consider how they will affect your business or workplace.

1.       Stronger Enforcement:  Some Employers Need Incentives to Do the Right Thing

OSHA will have more and bigger sticks.  OSHA is redirecting resources to conduct inspections of high risk industries and tasks including ergonomics.

Read More

Topics: Emilcott, OSHA, indoor air quality, health and safety, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Occupational Training, Safety Training in Spanish, water safety, small business

Paula Kaufmann, CIH

In a recent blog about the rapidly approaching Toxic Substance Control Act (TSCA) Form U submission in 2011, I mentioned that the EPA published a Proposed Rule detailing TSCA Inventory Update Reporting Modifications. The EPA anticipates promulgating a final rule by the spring of 2011 as the next scheduled IUR submission period is currently scheduled to run from June 1, 2011 through September 30, 2011.

Some of these modifications are really a big deal and will require a lot additional effort for most submitters. We should be seeing some commentary in response to the proposed rule about the cost of compliance with the modifications along with the benefits of having this collection of information about chemical importation, manufacture and use in the US. Hopefully this will be a spirited discussion and we will keep you posted on the outcomes and what they mean to you.

Although we don’t know what the final rule will look…the following is a list of the proposed changes that may affect many of our clients and you:

• Electronic reporting of the IUR data, using an Agency-provided, web-based reporting software
  
  
  
  • After the final rule’s effective date, paper submissions would no longer be accepted.
  
  
  
  


• Form U submission every 4 years (instead of every 5 years)


• All submissions would require processing and use information (Part III of Form U)


• No minimum manufacture (or import) quantity for certain chemical substances
  
  
  
  • This an elimination of the 25,000 lb. threshold for the chemical substances that are subject to rules or orders in following TSCA sections:
    
    
    
    • Section 5(a)(2) Significant New Use Rules (SNURs)
    
    
    • Section 5(b)(4) Chemicals of concern to EPA
    
    
    • Section 6 Prohibitions for chemicals with unreasonable risks
    
    
    • Section 5(e) Requirements or restrictions on chemical production or use
    
    
    • Section 5(f) Chemical with an unreasonable risk
    
    
    
    
  
  
  
  


• IUR exemption changes for the following chemical substances:
  
  
  
  • No exemption for those with an enforceable consent agreement (ECA) to conduct testing.
  
  
  • Full exemption water.
  
  
  • Removal of polymers that are already fully exempt from the partially exempt list of chemical substances.
  
  
  
  


• Significant new reporting requirements Form U completion:
  
  
  
  • Name and address belonging to the parent company.
  
  
  • Current Chemical Abstracts (CA) Index Name, as used to list the chemical substance on the TSCA Inventory, as part of the chemical identity.
  
  
  • Production volume for each of the years since the last principal reporting year. For the 2011 report this would include 2006, 2007, 2008 AND 2009 in addition to 2010.
  
  
  • Production volume directly exported and not domestically processed or used.
  
  
  • Volume of manufactured chemical substance (such as a by product) that is recycled, remanufactured, reprocessed, reused, or reworked .
  
  
  • Company Business Information (CBI)
    
    
    
    • Submission of substantiation for CBI claims in Section III (processing and use information).
    
    
    
    
  
  
  
  


• Proposed changes for AFTER 2011 Form U submissions
  
  
  
  • Require reporting if the production volume of a substance met or exceeded the 25,000 pound threshold in any calendar year since the last principal reporting year.
  
  
  
  

With this significant list of proposed changes, Emilcott is paying close attention to TSCA-related news so that we can advise and guide our clients to be in compliance. We have worked with multiple U.S. and International clients with U.S. facilities that have misunderstood or ignored TSCA regulations resulting in a big problem that could have been avoided. If your facility falls under the TSCA guidelines, are you paying close attention to modifications to the TSCA IUR program? What do you think of the company cost vs. informational and monitoring benefits? What are you doing to be a part of the debate or prepare for submission?

Read More

Topics: Emilcott, General EHS, EPA, Hazardous Materials, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, reporting, chemical manufacturer, regulation, chemicals, regulatory

Barbara Glynn Alves  Oprah calls them the Ah-Ha Moments-- the second you get that one piece of information or insight that connects all the dots.  I recently had an enlightening moment onboard a flight to Mexico. No, nothing life-threatening like engine failure or loss of cabin pressure! Nor did any cabin attendant pull an inflatable slide to escape his dreary existence. But it did involve Mad Men…

The July issue of Delta’s Sky magazine was devoted to the profound change that the advertising world is experiencing.  It was the cover of John Slattery and Christina Hendricks from the hit show that caught my eye, but it was the fantastic reporting and interviews of ad industry movers and shakers that kept me reading. The feature articles were entirely relatable to the change that the environmental, health and safety industry is experiencing as technology puts a quivering arrow through the heart of what has been known as “Industry Best Practices”.

Recently, my colleague Tom Carlson,PE, in an EHSWire post regarding Best Available Technology, posed the question, “Given the availability today, right now, of newer technologies and systems that can easily help reduce the risks from air-borne hazards, shouldn’t these be used on remediation sites to protect workers and the public?”   The Emilcott answer is a resounding YES…of course!  And, until now, our message to stakeholders has been that it’s time to revisit Industry Best Practices for perimeter air monitoring and embrace the newest practices that technology has to offer. It has been a hard sell.

As director of all things sales and marketing at Emilcott, I had been a bit baffled by the resistance to the clear advantages offered by new technologies.  Delta’s Sky gave me the last dot to complete the picture as it explored the evolution of the ad world from the late 1950’s to the present. Decades of advertising best practices centered on the dominant triune media of TV, radio and print have been turned on their proverbial ears (and eyes) by the introduction of cable media and the Internet-driven marketplace.  Madison Avenue, the traditional epicenter of advertising, completely understands the changes and use of the new media outlets. However, the only firms to be successful are those that have been innovative enough to walk their clients through this new territory – most of these firms are far from Madison Avenue and are practicing near technology havens.

This was my Eureka: Our clients understand that change is upon them, but they are afraid. This was most profoundly stated in an interview with Christian Haas, Executive Creative Director with the ad firm Goodby, Silverstein & Partners out of San Francisco, who told Sky, “Best Practices are by definition the antithesis of innovation. And innovation eventually causes discomfort.”  I get it!  Not only do we have to introduce the change in Best Available Technology as changing Industry Best Practices, we also have to tell them how WE will help them make the change.  Wow!

Emilcott is embracing this enlightened sales message whole-heartily so that we can help our clients understand and embrace the NEW Best Practices with the reassurance that the expertise of Emilcott will be with them – for the whole ride. Have you or your clients been reluctant to try new Best Available Technologies in the field because it seems intimidating? What would it take to get you to embrace innovation?

Read More

Topics: Emilcott, General EHS, perimeter air monitoring, best practices, innovation

Topics: Emilcott, indoor air quality, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, worker safety, Lab Safety & Electrical, Fire Safety, Public Safety, Working Green

Topics: Emilcott, OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Emergency Response, H&S Training, Hazardous Waste Management, HazCom, worker safety, Occupational Health, Occupational Safety, MSDS, Hazard Communication Standard, Occupational Training, Safety Training in Spanish

Topics: Emilcott, OSHA, health and safety, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Occupational Training, Safety Training in Spanish

Compact Fluorescent Light Bulb Rules and Regulations

Dian Cucchisi - PhD - CHMM

Read More

Topics: Emilcott, EPA, Hazardous Waste Management, Working Green