Environmental Health and Safety Blog | EHSWire

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

by Bruce Groves

Through my membership with the New Jersey American Industrial Hygiene Association (NJ-AIHA), I had the opportunity to make a presentation at the New Jersey Clean Air Council’s (NJCAC) annual meeting on April 13 ^th.   This particular meeting sounded intriguing as it would be focusing on a topic of great interest to me – a technical dialogue on how to measure and identify the effect of air pollution (and other environmental stressors) on the cumulative health issues of the public. The meeting aimed to bring professionals from varying disciplines to discuss technical approaches, academic research and general opinions on how to reduce this pollution and therefore improve the health of the affected populations.  

The meeting lasted a full day with contributing presentations from a dozen or so professionals. There were 15 NJCAC Board members at the meeting and 50+ attendees comprised of 11 presenters, NJDEP staff, and members of the public.  As a presenter, we were each given about 20 minutes to make our points regarding specific urban populations that have inordinately higher exposure to air contaminants as compared to people living and working in “cleaner” urban, suburban and rural areas of the state.  The majority of the presentations concluded that there are neighborhoods where pollution levels are chronically and significantly high.  Presented evidence also linked higher incidences of illnesses and disease with these cumulative exposures to contaminants and other environmental (and social) stressors.  

Bob Martin, the NJDEP Commissioner, gave an introductory presentation outlining current and future regulatory initiatives for reducing air pollution in New Jersey. One plan is to ban older diesel equipment in areas that do not have effective emission controls.  Joe Suchecki, a representative of the Engine Manufacturers Association, correspondingly, presented convincing evidence that new diesel technology does not create air pollution problems.  The trick now is to get all the older diesel equipment off all the roads and construction sites replaced by either new equipment or equipment retrofitted to control air emissions.

Ana Baptista, PhD, gave an excellent presentation on the high levels of pollution in the Newark Ironbound district and the resulting links to disease in the residential population resulting from cumulative exposure to these contaminants.  Dr. Robert Laumbach gave a similar presentation about future research that he is leading to test people who live in the Ironbound in an attempt to prove this link of air pollution exposure to increased illness and disease.

My own presentation discussed Emilcott’s experience measuring local air pollution (particulates and vapors) and other environmental parameters (noise, wind speed and direction) using the Greenlight Environmental Monitoring System which collects, in real-time, data for particulates (at multiple particle size ranges) and vapors, coupled with data of wind speed and direction, to identify emission sources and measure their impact on local air pollution.  We have found that “what is measured, improves”, and by using this sophisticated and integrated air monitoring approach, identified emission sources can be controlled to make immediate and sustainable improvements to the local air quality. 

Overall, excellent information was presented, reinforcing the fact that the air quality in much of New Jersey is not very good and, in certain areas (usually in disadvantaged urban neighborhoods), it is extremely poor.    And, residents living in zones with the worst air pollution also show some link to increased disease and illness.     

I left the NJCAC annual meeting knowing that solid academic work was underway to prove that high levels of air pollution causes disease.  What was missing was evidence that effective, short-term actions are being taken, to reduce the levels of pollution and contaminant exposure in these areas to improve overall health for the resident population.

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Topics: indoor air quality, health and safety, General EHS, Air Monitoring, Air Sampling, environmental air monitoring, Public Safety, cumuluative health, perimeter air monitoring, air pollution

By Don Hoeschele, MS, CHMM

In an age where we are reliant on modern technology as a part of our job, it is difficult to imagine not being able to use your cell phone or access the Internet because of topography.  As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”?  Specifically, I had to meet OSHA’s requirements for communication:  29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”.  

For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help?  In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it!

On this particular project, numerous construction crews were working at different, extremely remote locations with a distance of several miles between each work crew. While the power line tower construction and electric line-stringing companies included requirements for an eventual end-to-end 2-way radio system, the system was not available for at least the first year of the project. And, since cell phones and the average two-way radio systems were not able to be consistently or reliably available to meet the communication needs required for this project, I needed to find an alternative. 

After digging around and countless meetings, calls, and trips to all kinds of communications companies, we settled on a resourceful, cost-conscious and effective method of communicating between the crews, safety personnel, surveyors and managers. The end result was a creative mix of new technologies:

• Cell phone signal boosters in each vehicle in the field


• GPS SPOT locator units for each  crew


• New technology satellite phones for work crews heading into the most remote locations.  

The vendor that built these systems also owned many of the frequencies needed for an end-to-end two-way radio system that would reach across the 275-mile project location.

Of course, the system’s effectiveness had to be proven – we were relying on it! So, I spent hours deep in the mountains field testing the equipment in some of the most remote project locations I have ever seen. Luckily, I was helped by some of the project team members who had spent a great deal of time in this area. Experience also helps communication!

This project had unusual difficulties – a big, remote, mountainous and unpopulated area – that could have thwarted OSHA’s communication requirements.  At any time, it would have been easy to throw in the towel, cross our fingers or perhaps put together a patched-together system and hope it worked.  However, with some tenacious ingenuity and a confidence that a reliable health and safety communication system could be found, we were able to overcome the almost overwhelming challenges and put an effective field communication system into place.

Have you been faced with challenges to provide adequate communication systems for your employees?  What has made a job site seem almost impossible to conquer? What did you do to overcome those challenges?

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, HazCom, Compliance, worker safety, Occupational Health, Occupational Safety, Hazard Communication Standard, communication

Dale Wilson, CIH, LEED AP

We all know what Green Buildings are, right? There are various permutations but generally, to be green, the structure is designed, built, maintained and sustained in an environmentally responsible and resource-efficient manner. The end-all objective is to reduce impact of the “built package and system” on both the environment and mankind by

• Using energy, water, and other resources efficiently


• Protecting occupant health


• Improving employee productivity


• Reducing pollution and waste

As a LEED AP-certified professional who specializes in Indoor Environmental issues with a focus on fire and life safety, I was very interested in recent articles that are creating awareness of some critical health and safety problems inherent to the green building movement that 1) use innovative, locally-produced products, and 2) implement new design, construction, and operation approaches intended to reduce energy usage and be environmentally sound.

Green Building Fire Safety

In Megan Grennille’s recent EHSWire article about the seminal Triangle Fire, it noted that building and fire code rules caught up with the high rise construction only after the tragedy of 146 worker deaths highlighted the challenges of safety and rescue in the case of a fire. The same situation recently occurred in Bakersfield where a green-constructed Target store highlighted some new concerns for health and safety for emergency responders:

“The fire at the Bakersfield Target started, firefighters learned, at the photovoltaic array [solar] on the building's roof. Even after the firefighters disconnected the electrical mains, they discovered that the solar panels were still energized, presenting a safety challenge in addition to the fire.”

This brings to light how the integration of green building practices on a seemingly typical commercial building can present new hazards that must be identified to protect building occupants and emergency responders.  Fire fighters responding to an alarm may cut electrical power from the supply grid, but what is the procedure if there is an active solar array or an integrated wind turbine generating power as a part of the building?  Other “new” electrical and fire hazards facing unprepared emergency responders include the unknown level of fire resistance of recycled/green building materials, how to control fire spread on green vegetative roofs, and how to control smoke in wide, open atrium areas.

“ owners of green buildings might have to be aware that the green designs can present previously unconsidered challenges that arise as a direct result of construction choices. ...Because codes — even a decade after green design concepts hit the mainstream — still largely deal with traditional building designs and materials, facility managers have to know how to address the intersection of green design and current codes.”

The bottom line is that "green concepts should be reviewed as part of a fire-protection and life-safety analysis”, because buildings, green or not, must meet building and fire code standards to protect the health and safety of both the occupants and emergency responders.

Moisture and Mold Management in Green Buildings

Another potential hazard of green buildings is the management of moisture within the building and how selection of a green design and materials may be inappropriate if the location and weather are not considered:  “the design-and-construction community must not assume that if one builds green, then one will be building regionally correct or even lower risk buildings”.

A recent article, Hidden Risks of Green Buildings, was written from an insurance underwriter’s perspective and centered on the management of moisture.  The article mentioned the trend of using carbohydrate-based building products instead of petroleum-based building products.  That is where my eyes widened! Any indoor quality consultant knows the formula:  moisture + food source = perfect habitat for mold growth.  Carbohydrate-based building products are food for mold!

Moisture comes from many sources in a building: bulk water from a rook, window, or facade leak; water pipe break; HVAC condensate overflow; condensation on cold surfaces; or vapor (relative humidity) in the air.  Additional humidity can be added to the air by introducing humid outdoor air that has not been properly dehumidified or from other sources such as showers, locker rooms, steam rooms, gyms, kitchen facilities, human respiration (particularly if more people are occupying the space than the original design).  ( More information on these moisture-related potential problems including the risk of LEED “flush-outs” can be found here.)

Moisture meeting carbohydrate-based building materials over time certainly does look like the potential beginning of The Perfect Storm, because, in reality, carbohydrate-based building materials, even treated with the best biocide, would only be “mold resistant” not “mold proof”.  Given food, water, and time… mold will grow.  So as a professional IEQ consultant who has seen it all when it comes to mold contamination, I sincerely believe the article’s foreshadowing that “ the design community would be advised to prioritize the lessons…already learned from the waterproofing, humidity control, and building forensics community”.  When using potential mold “food” within a building, moisture control is ever more critical to the air quality of the building as well as the building material’s life cycle.

Are you interested in green construction? Have you thought of the potential hazards that can be created when using new technologies, new materials and tightening up the envelope?

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Topics: indoor air quality, health and safety, General EHS, Construction H&S, Emergency Response, worker safety, Air Sampling, Mold, Fire Safety, Exposure, Respiratory, green buildings, Working Green

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, worker safety, Occupational Health, Occupational Safety, regulation, Fire Safety, shirtwaist, fire, triangle

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

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

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

• EHS Specialists


• Certified Industrial Hygienists (CIH)


• Certified Safety Professionals (CSP)


• Certified Hazardous Materials Managers (CHMM)

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

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:

• Water Damage – How to Minimize Mold and Costs 


• 10 Items You Need To Know About Water and Mold Damage In A Commercial Building


• The EPA’s New Year’s Resolutions: Replace PCB-Containing Light Fixtures in Schools and Radon Testing in January


• Vapor Intrusion Air Sampling…Getting the Big Picture

Read More

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

Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, TSCA & R.E.A.C.H., TSCA, reporting, Form 300, Greenhouse Gas Reporting