What’s the Difference Between OSHA’s General Industry and Construction Standards on Asbestos?

What’s the Difference Between OSHA’s General Industry and Construction Standards on Asbestos?

With so many entities regulating asbestos – EPA to OSHA to State Governments to even City and County Governments – we see a lot of confusion.  These regulations cross over and intertwine with each other and it’s sometimes difficult to remember which rule is required by which agency.  In this article, we will tackle OSHA’s side.

OSHA has two separate regulations regarding asbestos.  The General Industry Standard is at 29 CFR 1910.1001 and the Construction Standard is at 29 CFR 1926.1101. Unlike other regulations that are shared between 1910 and 1926, these are NOT a carbon copy of each other.

Which One is For You?  Well….It Depends.

In many standards, a company follows either the standard in 1910 or the standard in 1926 based on what type of facility you are.  If you’re a manufacturer, fixed facility, traditionally the 1910 general industry standard applies to you.  If you’re a construction company who moves from site to site, the 1926 construction standards typically apply to you.  However, for asbestos regulations, the one that applies to you depends on what’s going on at your site and what your workers are doing.

A general rule of thumb is daily management of asbestos at your facility falls under the general industry standards.  When you are intentionally disturbing asbestos, then you follow the construction standards.  So a “general industry” facility could be subject to both the general industry and the construction standards if they have a renovation going on.  It’s important that you know the difference between the two distinctions.

The Similarities

We’ll first take a look at the similarities between the two standards.  Remember that OSHA’s goal is the safety of the worker so regulations are focused on worker protection.

Notifying Employees of the Hazards of Asbestos

Both regulations require that you notify workers of the hazards of asbestos and you can do this for everyone through your compliance activities for the hazard communication standard or you can do it through separate training.  This includes informing workers of the presence and location of asbestos in their workplace as well as the health hazards caused by asbestos.  Housekeeping personnel are required to be notified of asbestos-containing areas they could be cleaning.  Outside contractors and project bidders who could work in areas where asbestos could be disturbed are required to be notified where it is.  If asbestos is to be disturbed, such as a removal projects for a renovation, those people working in areas adjacent to those work areas are to be notified of the project.  Tenants of buildings are required to be notified by the owner of the building.

Signage/Labels

Warning signs are to be posted on regulated areas where removal is being conducted or asbestos is being disturbed.

Warning labels should be on raw materials, mixtures, scrap, waste, debris, bagged protective clothing, and other products containing asbestos fibers, or be placed on their containers. Entrances to mechanical rooms or mechanical areas where employees could be exposed should have labels attached where they will clearly be noticed by employees.

Exposure Limits and Medical Surveillance

Each standard sets limits for the amount of asbestos a worker can be exposed to.  If there’s the potential that a worker will be exposed past the limits in the standards, then respiratory protection is required and certain PPE is as well.  If that limit is exceeded, then the worker also needs to be placed in a medical surveillance program to monitor the health effects of their potential exposure.

Training

Each standard lines out required training. The level of training required depends on what the worker will be doing and whether or not they’ll be disturbing asbestos.  Training could range from an awareness class to a full week of intense training.  Most asbestos training is required to be repeated annually.

The Differences

General industry standards have a section on suggested work practices for housekeeping personnel to follow, but the construction industry standard dives into detailed work practices for those personnel intentionally disturbing asbestos-containing materials to follow.

In the construction standard is where we find the terms Class I, Class II, Class III and Class IV work.  The specific practices that workers are to follow are spelled out in detail for each class of work.

Class I work is for workers at the highest risk of exposure.  These are the one who will be removing friable asbestos materials.  Friable asbestos materials are those that when dry, can be easily crumbled or pulverized to powder by hand, making the potential for its fibers to be released even greater.  Class I work is the large-scale abatements of thermal systems insulation from pipes, boilers, tanks and ducts as well as removal of sprayed-on insulation, “popcorn ceiling” texture or acoustical plaster and vinyl floor covering.   This work requires specialized asbestos removal/abatement training of up to 40 hours with annual refreshers.

Class II work is the removal of non-friable asbestos.  Non-friable asbestos cannot be easily crumbled or pulverized to powder by hand and its asbestos fibers are usually bonded into other materials. If a non-friable material remains in good condition, it poses little hazard. Because of its strength, incidental contact will not usually release a fiber.  Class II work includes removal of vinyl asbestos floor tile, lay-in ceiling tile, Transite roofing panels, window glazing, asbestos siding and any non-friable materials.  This work requires specialized asbestos removal training that can vary from full 40 hour courses to specialized training for the specific material to be removed.

Class III work is the intentional disturbing of asbestos for repair and maintenance of other items.  For instance, if one needed to cut away a small amount of asbestos to fix a leaky pipe or to potentially disturb some asbestos in order to access an electrical panel for repair, that would fall under this class of work.  This type of work can often be done by in-house maintenance personnel or even maintenance contractors.  However, it’s still an intentional disturbance and so the workers who do these activities are required to take specialized asbestos removal training as well.  Class III work only allows workers to remove a certain quantity of material before it crosses the line and become Class I or II abatement work.  Specialized training to remove these small quantities is required, typically a 16-hour initial class with annual refresher training.

Class IV work is for those who will be conducting maintenance and custodial activities after a removal is completed, that is, cleaning up after Class I, II or III work.  This level has its own specific training requirements with specific content requirements.

Questions?

Asbestos regulations can be hard to interpret and confusing as actually 4 entities can get involved in regulating it: EPA, OSHA, State Governments and City/County Governments.  If you have any questions regarding this article or asbestos in general, contact us.

 

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EPA Looks to Add Air Emissions Reporting Items

EPA Looks to Add Air Emissions Reporting Items

EPA has announced a several changes to its Air Emissions Reporting Rule, or AERR that would make reporting of hazardous air pollutants (HAPs) consistent from state to state, add electronic reporting of stack tests, decrease and standardize emissions thresholds, create earlier reporting deadlines, and add new point sources to reporting requirements.

All of the changes EPA is considering making is to help the agency comply with the presidential commitment to enhance environmental justice by gathering more detailed location-specific information.

HAP Reporting

Per the AERR, industry is already required to report emissions of common or criteria pollutants and the pollutants that form them, called precursors.  Right now, the federal rule doesn’t require HAP reporting, but some states require reporting and voluntarily give this information to EPA.  Not all states do, and not all Indian lands do either.  For the ones that do, the rules can vary greatly from state to state.

The new rule would make HAP reporting standard for all facilities in all states who are:

  • Major sources per Clean Air Act operating permits;
  • Non-major sources who were in a certain industry emitting HAPS at or above a certain threshold;
  • Indian lands; and,
  • Offshore deep water ports.

Facilities would also be required to provide other details and data about HAPs from their stack test and performance evaluations.  EPA would like these to be reported electronically through the Consolidated Emissions Data Reporting Interface (CERDI).

To help states find a way to make reporting this data to EPA be more streamlined without the need to create their own separate data collection programs, EPA would like for states to develop procedures to have industry use the online Combined Air Emissions Reporting System, or CAERS system.  CAERS is already in use for reporting National Emissions Inventories and Toxic Release Inventories (TRI).  EPA even hopes to work towards eventually using CAERS to gather Greenhouse Gas Reporting (GHG) data and incorporate the CERDI as well.

The new rule would start in 2027.  This is because states have told EPA it can take two to three years for them to change their air emissions regulations.  EPA also says time it can take states to migrate from their current systems to CAERS could be one to three years as well.

Shorter Deadlines

The proposed rule looks to make states work faster to get this data to EPA.  Right now, states have 12 months after the end of the reporting period to turn in inventory data.  That is, the reporting period ends on December 31, and EPA has until December 31of the following year to turn it in to EPA after receiving it from industry much earlier than that. Starting in 2027, state inventory data would be due to EPA by September 30 and starting in 2030, data would be due by May 31.

Many states already turn in their collected inventory data sooner than that 12-month deadline, but shortening the due dates may force all states to go to electronic systems and may cause some of them to move up due dates for industry.

If EPA’s goals of using CAERS for multiple emissions reports, EPA speculates the possibility arises industry may eventually see one consolidated deadline for all reports rather than the current tiered deadlines of GHG reports due March 31, some air emissions reports due May 31 and TRI reports due July 1.  Another possibility to help alleviate stress in the deadlines in this case would be for industry to potentially report some data directly to EPA rather than go through the state.

EPA is currently seeking comments about the timing of the phase in deadlines and EPA wants feedback on these potential scenarios.

Standardized Emissions Thresholds

Under the current AERR rule, states report data on criteria pollutants and precursors that exceed certain thresholds.  The thresholds are setup to be different each year over a triennial cycle. That is, they are higher in the first two years and then lower in the third year.  On that third year, more facilities end up qualifying for reporting.  The new rule would make the threshold the same each year.  That would be the lower year 3 emissions threshold, causing more facilities to need to report every year.  HAP thresholds would be the same each year as well.

Small Generating Unit Emissions Data Included

Some facilities use small generating units to help meet demand on high electricity demand days or use them to supplement their own electricity.  EPA wants to make these a new source reporting requirement, taking daily data such as fuel use or heat input.  EPA says that when facilities use a number of these at one time, the units can significantly add to ozone formation through emitting of nitrogen oxides and particulate matter.

Currently, emissions for these are reported as an annual, not daily, emissions value and only if they’re located at a point source.  If they’re not located at a point source, they aren’t tracked at all.  The new rule would track all of them at all facilities.

Prescribed Fire Data

The proposed rule would also add the requirement for state, local and tribal forestry agencies to report daily activities associated with prescribed fires on state, tribe, private, or military lands.  This would include fires affecting more than 50 acres where there is forest canopy present (understory fire) or where there is little forest canopy like a grassland or oak woodland fire (broadcast fire), or pile burns of 25 acres or more.

Agricultural fires, land clearance fires and construction fires would not be included.

Comments Period

The public is invited to comment on the proposed rule up until October 18, 2023.  You can find the entire rule HERE.

Need Help Sorting This Out?

If you have questions about air emissions reporting in general, anything discussed in this article or this proposed rule, or need help getting your environmental reporting taken care of, we’re here to help!  Contact iSi today!

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OSHA Issues New National Emphasis Programs for Warehousing, Distribution Centers and Certain Retail Stores

OSHA Issues New National Emphasis Programs for Warehousing, Distribution Centers and Certain Retail Stores

OSHA’s latest National Emphasis Program (NEP) is targeting warehousing and distribution center operations, mail/postal processing and distribution centers, parcel delivery/courier services and certain retail stores with high injury rates.

An NEP is a temporary inspection emphasis based on a particular hazard that is typically targeted to specific NAICS codes where certain hazards are most prevalent or in safety areas showing a trend towards high hazards.  NEP inspections can be scheduled on their own, or OSHA can tack one on at an inspection if they see something that applies. So, if OSHA is onsite to investigate a complaint and they see something that could fall under an NEP, they can inspect for that too while they are there.

Who’s Covered in this NEP and Why?

OSHA recognizes a warehousing and distribution growth boom and an increased DART rate compared to other industries.  In 2011 there were 668,900 warehousing and distribution centers, and in 2021 that number was 1,713,900.  DART rates and total recordables for the industries covered in this NEP were over twice that of all private industry, some were more than three times the private industry rate from 2017-2021.

These are the NAICS Codes that will fall under the NEP:

  • 491110 Postal Service (Processing & Distribution Centers only)
  • 492110 Couriers and Express Delivery Services
  • 492210 Local Messengers and Local Delivery
  • 493110 General Warehousing and Storage
  • 493120 Refrigerated Warehousing and Storage
  • 493130 Farm Product Warehousing and Storage
  • 493190 Other Warehousing and Storage

The following warehouse-type retail stores are included because they have been found to have issues in loading and storage areas and have higher than average DART (Days Away; Restricted; Transfer) rates:

  • 444110 Home Centers
  • 444130 Hardware Stores
  • 444190 Other Building Material Dealers
  • 445110 Supermarkets and Other Grocery Stores
  • 452311 Warehouse Clubs and Supercenters

This retail list will change each calendar year based on which related establishments have the highest DART rates.

What Will Inspectors Look For?

Inspectors will be looking at these program areas:

  • Powered Industrial Vehicles (already an emphasis program in several regions)
  • Material Handling and Storage
  • Walking-Working Surfaces
  • Means of Egress
  • Fire Protection
  • Heat (already a National Emphasis Program)
  • Ergonomic Hazards

For heat, inspectors will review injury and illness records, ask about it during worker interviews, and look for these in the walkthrough.  If inspectors see exposures to heat-related hazards or if they find your NAICS code already falls under the Heat NEP, they will expand the scope of the inspection to include the Heat NEP.   Read more about what that inspection entails here.  Heat is a big emphasis right now with OSHA because it helps them meet their responsibilities in complying with the Presidential directive on climate change.

If inspectors see ergonomic hazards in their reviews of records, worker interviews and the walkthrough, they can also expand the scope to ergonomics and open a health inspection in addition to the safety inspection.

Read the full NEP documentation here.

Questions?  Need Assistance?

iSi can help answer questions you may have about this NEP or any others, as well as conduct a mock OSHA inspection to see where you stand if OSHA were to conduct this inspection at your facility today.  Contact us!

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OSHA Issues Final Rule Which Updates Electronic Injury and Illness Reporting, Adds Industries and More Requirements

OSHA Issues Final Rule Which Updates Electronic Injury and Illness Reporting, Adds Industries and More Requirements

OSHA has issued a final rule changing some of the requirements for electronic injury and illness reporting, adding some new companies and increasing some of the reporting requirements.

What’s New

Companies with 20-249 employees whose NAICS codes were listed on Appendix A of the standard were required to submit their 300A electronically.  This has not changed, however a new appendix, Appendix B, has been created for companies with 100 or more employees.  This will require many more industries to report electronically.  In addition to submitting the 300A, the 100+ employee companies who fall under Appendix B will also need to submit their 300 and 301 forms.

As with 300A information, data from the 300 and 301 logs will be published on the OSHA website.  Personally identifiable information from the 301, such as fields 1, 2, 6 and 7: employee name, employee address, physician name, and treatment facility name and address will not be collected.

The rules have not changed for all companies with 250 or more employees.  All companies, regardless of NAICS code, will need to submit their 300A forms.  Those with 19 or fewer employees will still not be required to report.

Another change includes making inclusion of your company’s legal name required.  Right now, only the Tax Identification number is required.

See Appendix A Here

See Appendix B Here

Industries Moved from Appendix A to Appendix B

Some NAICS codes were moved from Appendix A to Appendix B due to increased fatalities or increases in DART (Days Away; Restricted; Transfer) rates.  Those companies with 20-249 employees who had been submitting only the 300A will now be required to submit the 300 and 301.  These include:

  • NAICS 1133-Logging
  • NAICS 1142-Hunting and Trapping
  • NAICS 3379-Other Furniture Related Product Manufacturing
  • NAICS 4239-Miscellaneous Durable Goods Merchant Wholesalers
  • NAICS 4853-Taxi and Limousine Service
  • NAICS 4889-Other Support Activities for Transportation

Why They Are Requiring the 300 and 301 Log for Some Industries

Besides finding additional industry data on increased injuries, DART rate and fatalities, OSHA’s intent is to collect more accurate and detailed information for injuries and illnesses to help ultimately make workplaces safer.  The detailed information is meant to help make statistics more accurate and to help identify trends that are relevant to industries and types of workers.  The only time OSHA was able to get detailed information was through inspections.  The type of data they will be gathering allows for different kinds of statistical analyses and to help determine where initiatives are successful, are failing, or need to be developed.

OSHA sees gathering 300 and 301 information as a benefit not only to themselves, but by posting it online it can be beneficial information to industries, employers, employees, safety consultants like iSi, and to the general public.

Some examples of this that they used in their final rule document include:

  • 300A information only tells how many of each type of incident on that form are occurring. Now they will be able to see the different kinds of injuries and what they are.  For example, “respiratory conditions” could mean as a result of chemical exposure, COVID, TB, or Legionnaires.
  • Now data can be pulled by roles within any type of company. For example, injuries for nurses aides vs. nurses vs. doctors in medical facilities.
  • The Presidential directive on climate change has OSHA them focused on heat hazards. The new information will help them figure out what kinds of injuries and illnesses are attributed to heat.
  • This will help give employers another resource to consult besides industry groups and insurance to benchmark themselves against others in their industry. For example, the state of Michigan independently researched and found that bath refinishing contractors had 13 deaths in the span of 12 yrs.  From that information, they found it was because of the chemical strippers that were being used. As a result, safety guidance and training was sent to those companies to help improve safety and to alert them of those hazards in order to reduce the deaths.
  • Another employer in New York researched all injuries from their multiple worksites and found that there had been 11,000 lost workdays because of ladders. To reduce those numbers, they increased training in that area, making injuries drop to close to none.  With publicly available information, research like that can be done by multiple parties to help find ways to strengthen workplace safety.

Need Advice?

If you need help navigating this standard, or have questions about it, contact us today!

 

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iSi Summer Toolbox Topics:  Fireworks Safety

iSi Summer Toolbox Topics: Fireworks Safety

One of the favorite events of the 4th of July holiday for many people is shooting fireworks.  Contrary to what we may have seen and done in our teenage years, fireworks can actually be pretty dangerous.  Here are some tips to remember and share for a safe holiday:

  • Know your local laws regarding the use of fireworks such as where you are allowed to shoot them, which types are not allowed and at what times you can shoot them.
  • If you’re not allowed to shoot them in your home area and need to go across city or county lines, make sure you have the permission of the owner of where you’re going to shoot them.

The Setup

  • Always use fireworks OUTSIDE within a clear area. Stay way from buildings and vehicles.
  • Stay away from trees, bushes, and other dry vegetation.
  • Adults should supervise all firework activities.
  • Alcohol and fireworks do not mix.  Save your alcohol for after the show.
  • Always have a bucket of water and a water hose nearby.

Shooting the Fireworks

  • Before you begin, know your fireworks: read the caution labels and performance descriptions before igniting.
  • Wear safety glasses when shooting fireworks.
  • Light one firework at a time and then quickly move away.
  • Sparklers look harmless, but they can burn at 2000 degrees and quickly ignite clothing. Make sure anyone using them has their shoes on and that they hold them out away from their clothes and skin.
  • Never relight a “dud” firework.  Wait 20 minutes and then soak it in a bucket of water.
  • Never carry fireworks in your POCKET or shoot them into METAL or GLASS containers.
  • Old fireworks can be a safety hazard—make sure they haven’t gotten wet and that the fuse is intact before using.

Disposal

  • Smoldering fireworks can cause a fire in a trash can.
  • Soak used and dud fireworks in a bucket of water for at least 20 minutes, or overnight which is even better.
  • If you find old fireworks that are damaged or you don’t want to light them, don’t just throw them away. Soak them in a bucket of water until fully wet.
  • Wrap the wet fireworks in Ziploc bags, trash bags or plastic wrap so they won’t dry out—especially the unused ones that still contain the explosives within them. Dry fireworks can become unstable.

Fireworks and Pets

  • Don’t bring your pets to a fireworks display, even a small one.
  • If fireworks are being used near your home, put your pet in a safe, interior room to avoid exposure to the sound.
  • Treat toys filled with their favorites such as pumpkin, peanut butter or applesauce may be a good distraction to keep their minds busy.
  • Make sure your pet has an identification tag, in case it runs off during a fireworks display.

We hope you have a safe and wonderful Independence Day holiday!

.One of the favorite events of the 4th of July holiday for many people is shooting fireworks.  Contrary to what we may have seen and done in our teenage years, fireworks can actually be pretty dangerous.  Here are some tips to remember and share for a safe holiday:

  • Know your local laws regarding the use of fireworks such as where you are allowed to shoot them, which types are not allowed and at what times you can shoot them.
  • If you’re not allowed to shoot them in your home area and need to go across city or county lines, make sure you have the permission of the owner of where you’re going to shoot them.

The Setup

  • Always use fireworks OUTSIDE within a clear area. Stay way from buildings and vehicles.
  • Stay away from trees, bushes, and other dry vegetation.
  • Adults should supervise all firework activities. 
  • Alcohol and fireworks do not mix.  Save your alcohol for after the show.
  • Always have a bucket of water and a water hose nearby.

Shooting the Fireworks

  • Before you begin, know your fireworks: read the caution labels and performance descriptions before igniting.
  • Wear safety glasses when shooting fireworks.
  • Light one firework at a time and then quickly move away.
  • Sparklers look harmless, but they can burn at 2000 degrees and quickly ignite clothing. Make sure anyone using them has their shoes on and that they hold them out away from their clothes and skin.
  • Never relight a “dud” firework.  Wait 20 minutes and then soak it in a bucket of water.
  • Never carry fireworks in your POCKET or shoot them into METAL or GLASS containers.
  • Old fireworks can be a safety hazard—make sure they haven’t gotten wet and that the fuse is intact before using.

Disposal

  • Smoldering fireworks can cause a fire in a trash can.
  • Soak used and dud fireworks in a bucket of water for at least 20 minutes, or overnight which is even better. 
  • If you find old fireworks that are damaged or you don’t want to light them, don’t just throw them away. Soak them in a bucket of water until fully wet.
  • Wrap the wet fireworks in Ziploc bags, trash bags or plastic wrap so they won’t dry out—especially the unused ones that still contain the explosives within them. Dry fireworks can become unstable.

Fireworks and Pets

  • Don’t bring your pets to a fireworks display, even a small one.
  • If fireworks are being used near your home, put your pet in a safe, interior room to avoid exposure to the sound.
  • Treat toys filled with their favorites such as pumpkin, peanut butter or applesauce may be a good distraction to keep their minds busy.
  • Make sure your pet has an identification tag, in case it runs off during a fireworks display.

We hope you have a safe and wonderful Independence Day holiday! 

 

Questions?

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OSHA’s Heat-Related Hazards National Emphasis Program

OSHA’s Heat-Related Hazards National Emphasis Program

OSHA has issued a new NEP on heat-related hazards. In this article, we’ll discuss what it includes, which companies will be targeted and what OSHA inspectors will be looking for in their inspections.

What’s an NEP?

A National Emphasis Program, or NEP, is a temporary inspection emphasis based on a particular hazard that is typically are targeted to specific industry groups or NAICS codes where those hazards are most prevalent.  Companies within those NAICS codes are randomly chosen for these inspections and others can be chosen because of past violations or certain circumstances.  NEP inspections can be scheduled on their own, or companies can have them added to other OSHA inspections. For example, if someone at your facility has complained to OSHA about one hazard, OSHA can conduct an inspection on that complaint issue and then if they see something else onsite that’s covered by an NEP or a regional or local emphasis program, they can inspect for that too while they are there.

OSHA’s Heat Hazard NEP

The heat NEP covers both indoor and outdoor heat hazards.  OSHA has had heat initiatives and heat awareness campaigns since 2021 and there has been debate in Congress about having a heat standard.  This NEP is also a response to President Biden’s Executive Order to “Tackle the Climate Crisis at Home and Abroad.”  The Secretary of Labor developed a Climate Action Plan with a goal of reducing heat-related illnesses and this is one of the ways they are going about that.

For purposes of measurement, OSHA considers a heat priority day to be one when the temperature is 80° F or higher.  Programmed, targeted NEP inspections will be conducted on days when the National Weather Service has issued a heat advisory or warning, including a Heat Advisory, Heat Wave, Excessive Heat Outlook, Excessive Heat Watch and an Excessive Heat Warning.

Which Companies Are Affected?

Of course, construction companies whose workers work out in the heat are affected.  There are other non-construction companies who have been targeted as well as other industries who can be targeted at your OSHA Area Office’s discretion.

The list was too long to include in this article, but you can find a PDF copy of that here.

Farming is included on this list, however farms with 10 or less employees (not counting family members who work on the farm), who have stayed at or below that number for the past 12 months, and have not had any temporary labor camps in the past 12 months will be exempt from the NEP.

What Triggers an Inspection for this NEP?

You can end up on the inspection list for this in several different ways:

  • You have a heat-illness related fatality, or have had a heat-illness related fatality that OSHA would like to follow up on;
  • There’s an employee complaint about heat-illness hazards;
  • Your company operates under one of the NAICS codes from the target list, you have been picked by OSHA’s random number generator and it’s a day when the National Weather Service has issued a heat alert;
  • OSHA inspectors are already onsite, and they find a heat-related illness on OSHA 300 logs, observe hazardous heat conditions, an employee brings a heat-related hazard to the attention of the inspector, or it’s a heat priority day. Inspectors have been encouraged to ask about your heat-illness prevention program on heat priority days;
  • OSHA previously cited you for a lack of a heat-illness prevention program and you still haven’t implemented one; or,
  • Your company has been added to the list by your Area Office based on a referral by another agency such as the Wage and Hour Division, the EPA, or the U.S. Department of Agriculture, they saw a media report about your company which shows there may be a heat issue onsite, or from the Area Office consulting other reference directories to find potential companies to inspect.

What Will Inspectors Look For?

  • Records Review – Inspectors will look at your OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illnesses and will review any records of heat-related emergency room visits and/or ambulance transports even if there were no hospitalizations.
  • Employee Interviews – Interviews of current employees, new employees and employees who were away from the worksite and recently returned to work will be conducted. Inspectors will be asking for symptoms of headache, dizziness, fainting, dehydration or other conditions that may indicate heat-related illness.
  • Program Review – Next the inspector will look at your program. First, do you even have a written program? How do you monitor ambient temperatures and levels of work exertion at the worksite? Are you conducting calculations using a particular method suggested by NIOSH or ACGIH?  Is there unlimited cool water that’s easily accessible and are you requiring additional hydration and rest breaks?  Is there access to shade?  What do you do to acclimatize new and returning workers? Do you have a buddy system for hot days?  What kinds of administrative controls are used?  Is work scheduled during cooler periods of the day?  Do you have a screening program to identify health hazards? What does your training program contain?
  • Documentation of Conditions – The inspector is to document any conditions they find relevant to heat hazards such as heat index, heat alerts, information they get from the OSHA-NIOSH Heat Safety Tool App and/or Wet Bulb Globe Temperature (WGBT) measurements. If they are there because of an incident, they’ll be looking at current conditions such as wind speed, relative humidity, dry bulb temperatures both at the workplace and in the shaded rest areas, WGBT, percentage of cloud cover and heat alerts.
  • Observation of Heat-Related Hazards – Inspectors will be looking for potential sources of heat-related hazards such as exposure to sun, hot air or hot equipment. What PPE is being used, that is, it bulky and heavy or does is deflect heat?  What tasks are being conducted and what’s the level of exertion being used to conduct those?  How long are employees conducting these tasks and how long are they continuously conducting moderate to strenuous activities?

Which Standards Will Get Cited?

Most citations for these inspections will fall under the General Duty Clause.  Other citations that could be tacked on, depending on the findings, could include:

  • Recordkeeping – If the employee became unconscious or needed oxygen and it wasn’t recorded you could be cited here.
  • Sanitation – Regulations in 1910.141 and 1926.51 specify your company is required to provide cool, potable water.
  • Construction Safety Training and Education – Under 1926.20 and 1926.21, construction companies are required to have a safety and health program.

A New Standard on the Horizon

OSHA has a standard called Heat Illness Prevention in Outdoor and Indoor Work Settings already in the Prerule stage.  They have passed the comment stages from their Advanced Notice of Proposed Rulemaking and are scheduled to next go to the Small Business Regulatory Enforcement Fairness study.  In the meantime, there are several states with their own heat illness rules.  In the state of California there are already requirements for outdoor workers, and the California legislature asked Cal-OSHA back in 2016 to come up with a standard for indoor workers.  They have been working on that and are expected to have something in 2024.  What’s caused the delay is the issue of determining the exact thresholds that can be feasible for all industries since so many indoor workplaces can be different.

What’s in a Heat Illness Prevention Program?

Stay tuned here to our blog for our upcoming article featuring OSHA’s suggestions for what should be included in your heat-illness prevention program.

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What the Haz?

What the Haz?

A Deeper Dive Into the “Haz” Words in OSHA, EPA and DOT and Where They Can Crossover

Every once in a while, we will get a call from someone looking for “Hazmat” training.   To you, the word hazmat may mean one thing, but we guarantee to someone else it probably means something completely different.

iSi’s mission is to help companies navigate compliance with EPA, OSHA and DOT regulations.  Once you start familiarizing yourself with those regulations, you will find that the definition of hazmat can be different for different agencies and different situations.   You will also see that there are a number of words that include “haz” that can creep into the picture and be used interchangeably.  An even deeper dive will show that each agency will either make up their own definition or borrow from one another.

Each Agency Has Its Own Focus

Regulations and their definitions are typically written in the perspective of the focus of the agency.  Each agency has its own role to play in the workplace and how they use their haz words will often be reflective of that.

  • OSHA – OSHA’s focus is safe and healthful working conditions for workers
  • EPA – EPA’s focus is on human health and the condition of the environment
  • DOT – DOT’s focus is on the safe, efficient, sustainable and equitable movement of people and goods

Once you know the perspective for each, that will help you be able to better understand regulations when they crossover or refer to one another.

Hazmat

Hazmat is a shortened version of “hazardous materials.”  Each agency refers to hazardous materials a little differently.

In OSHA, the term hazmat can refer to hazardous materials or hazmat teams.  OSHA says a hazardous material is something that can be a health hazard or a physical hazard.  However, a hazmat team is an organized group of employees who perform work to handle and control spills or leaks of hazardous substances.  Individually trained members of the hazmat team are called hazardous materials technicians.  Later we’ll look at the OSHA HAZWOPER standard where many of these definitions are found.

To DOT, hazmat means “a substance or material capable of posing an unreasonable risk to health, safety, and property when transported in commerce…”  It also can include hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials listed in the Hazardous Materials Table, and materials meeting their criteria for hazard classes and divisions. The term Hazmat employee in the regulations are those persons who package or prepare, physically transport, load, unload, design or makes packages for, fills out paperwork for or ensures the safe transportation of hazardous materials.

To EPA, a hazardous material is any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

From the definitions, you can see that OSHA was focused on people, DOT was focused on transportation and EPA was focused on the environment.

HazCom

Another shortened haz word is HazCom.  This is short for the OSHA Hazard Communication Standard.  This standard is all about hazardous chemicals, that is, any chemicals that are a physical or health hazard. The HazCom Standard deals with Safety Data Sheets (SDS), labeling, markings, training and more.

EPA’s Emergency Planning and Community Right to Know Act, or EPCRA, regulations refer to OSHA’s hazardous chemicals when it comes to which chemicals apply to the EPCRA regulation.  Those which fall under the HazCom standard and have SDSs associated with them are included in EPCRA reporting requirements.  Some companies also refer to HazCom training by the term Employee Right to Know training.

Hazardous Waste

Another haz is hazardous waste. The term hazardous waste comes from EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.  There’s a lengthy determination process one must go through to even determine if something can be defined to be a hazardous waste.  You’ll see all of those criteria and the roadmap in the definition of hazardous waste at 40 CFR 261.2.

EPA’s website says, “Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and may come in many forms, including liquids, solids gases, and sludges.”

Hazardous waste must be discarded and must be a solid waste.  To be a solid waste, it must be a material that has been abandoned, recycled, is inherently waste-like or is a military munition.

Once you determine that it’s discarded and a solid waste, there are another set of questions to ask to make the determination if a waste is hazardous or not.  This process is quite important and is required to be completed and documented for each of your wastes.

OSHA mentions hazardous waste in their HAZWOPER standard, calling hazardous waste anything that’s found to be a hazardous waste by the EPA definition or anything that DOT calls a hazardous waste in their definition.

In DOT regulations, DOT says hazardous waste is defined under EPA’s definition and that to ship hazardous waste a hazardous waste manifest is required.  Hazardous waste is a hazardous material that is regulated for transportation. So when a vendor comes to pick up your hazardous waste, your company is the one technically shipping it and are therefore subject to all of the DOT hazmat regulations the same as if you were shipping any other hazardous material.

Hazardous Substances

All 3 agencies use the term hazardous substance.

In EPA, a hazardous substance is “Any substance, other than oil, which, when discharged in any quantities into waters of the U.S., presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, shellfish, wildlife, shorelines and beaches (Section 311 of the Clean Water Act); identified by EPA as the pollutants listed under 40 CFR Part 116.”  Hazardous substances are referred to in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, aka Superfund), the Clean Water Act (CWA), the Clean Air Act (CAA), the RCRA hazardous waste regulations, and the Toxic Substances Control Act (TSCA).

OSHA makes it easy.  They say a hazardous substance is whatever EPA CERCLA says it is, whatever DOT says are hazardous materials, whatever EPA says a hazardous waste is, or any other biological or disease-causing agent that could lead to things like death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions or physical deformations in such persons or their offspring.

DOT says a hazardous substance is a hazardous material when that material is listed in their Appendix A and when its single package exceeds the reportable quantity listed in the Appendix. They also have other considerations if it’s a mixture or solution or a radionuclide.

HAZWOPER

And finally, there’s HAZWOPER.  Although it’s one of our more popularly discussed haz words, we left this for the end because this regulation actually uses all of the haz words in one place and seems to be one standard that incorporates so many different requirements from all 3 agencies within it.

HAZWOPER stands for Hazardous Waste Operations and Emergency Response.  HAZWOPER is found in the 1910 General Industry Standards under Subpart H, Hazardous Materials.  An identical copy can be found under a different subpart in the 1926 Construction Standards.

There are 3 main pieces or goals to HAZWOPER:

  1. Rules for conducting cleanup operations at sites determined to be EPA RCRA hazardous waste cleanup sites, cleanup operations at sites contaminated by hazardous substances on uncontrolled hazardous waste sites that EPA or another government agency have required to be cleaned up, or conducting voluntary cleanups at those same types of uncontrolled waste sites;
  2. Operations at treatment, storage and disposal facilities (TSD) regulated by EPA RCRA; and,
  3. Emergency response to releases of hazardous substances at any facility, any location.

Being an OSHA regulation, HAZWOPER is all about protecting the worker and the public during the cleanup, so all the guidance centers around preparing for and safely cleaning up hazardous substances.

The regulation mentions the term Hazmat teams in relation to those responding to the emergency responses found in part 3 of the standard.

HAZWOPER says any materials cleaned up and containerized into drums must meet appropriate regulatory requirements for DOT transportation, RCRA hazardous waste and OSHA safety regulations.  Waste must be transported per DOT regulations while self-contained breathing apparatuses used by workers to protect themselves during work are to comply with DOT standards.

The DOT’s Emergency Response Guidebook is mentioned and often consulted for emergency response information and guidance.

If a company has prepared a contingency plan per EPA requirements and that plan includes emergency response information, the company can use that contingency plan as part of its emergency response plan so that efforts are not duplicated.

On the EPA side, because OSHA regulations don’t apply to local and state governments, EPA has adopted the HAZWOPER standard into 40 CFR 311 to apply to those local and state governments and any of those not covered by a state OSHA-approved plan.

Also in EPA, emergency spills trigger a whole host of reporting requirements as well as emergency response plans and training to protect the environment from hazardous waste spills, oil spills, pipeline leaks and chemical releases to water, air or land.

Conclusion

This is not an exhaustive list of haz references or examples where all 3 agencies cross over, but hopefully it gave you an idea of how these terms and the rules related to them can be so different in some cases, but so intertwined in others.  The haz words used can differ depending on the situation.

So, if you call us asking for hazmat training, you’re likely to get a lot of questions from us about your end goal.

What haz words have you come across?  What examples did we miss?  We’ll be posting this on our Facebook, LinkedIn, Twitter and Instagram pages.  We’d love to hear from you!  

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CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

The Chemical Safety Board (CSB) has issued a safety alert regarding emergency pressure relief systems as the agency is continuing to see them playing their part in major chemical incidents.

Who is the CSB?

The CSB is an independent federal agency who investigates the root causes of chemical incidents at industrial sites such as chemical plants, refineries, and manufacturing facilities.  They are not a regulatory agency, but their teams of investigators make recommendations to OSHA and EPA, industry groups and the facilities they investigate.

In addition to investigation reports and root cause analyses, CSB issues safety videos on both their website and YouTube that summarize the important findings from their investigations in order to help prevent similar accidents from reoccurring.

Emergency Pressure Relief System Issues

In its investigations, CSB is continuing to find issues with the safety of emergency pressure relief systems.  In several of their investigations these systems were found to be discharging toxic or flammable materials to areas which were not safe for workers or the public.

Emergency pressure relief systems are devices installed on storage tanks, silos, vessels and processing plant equipment to help relieve the excessive pressure caused by fire, process failure, equipment failure or some other change in condition. The pressure relief device is supposed to prevent the equipment it’s installed on from rupturing or exploding.

One of the most well-known accidents involving an emergency pressure relief system was the Union Carbide disaster in Bhopal, India in the 1980s.  A runaway reaction generated high pressure conditions in a storage tank and a methyl isocyanate cloud escaped from the pressure relief system, killing 3,800 people, and injuring or creating long-term illnesses for tens of thousands.

Three Key CSB Suggestions

CSB recommends that rather than discharge into the air or back into the plant, emergency relief systems should discharge to a flare or a scrubber system.

CSB offers three key lessons from its findings:

  1. Follow Existing Good Practice Guidance

Use API 521, Pressure-relieving and Depressuring Systems as a standard guidance. CSB says this document “…addresses many concerns about releasing flammable vapors directly into the atmosphere and generally requires using inherently safer alternatives for toxic release scenarios or when the potential exists for a flammable vapor cloud.”

CSB also recommends documents published by the Center for Chemical Process Safety (CCPS) called Guidelines for Pressure-relief and Effluent Handling Systems and Safe Design and Operation of Process Vents and Emission Control Systems as well as viewing American Institute of Chemical Engineers (AIChE) presentations and courses on Venting and Emergency Relief.

  1. Evaluate Whether the Atmosphere is the Appropriate Discharge Location or if There May Be Safer Alternatives

CSB typically recommends flaring is safer than atmospheric vent stacks when venting flammable vapor into the atmosphere.  Something like flammable hydrocarbons can cause a fire or a vapor cloud explosion when they are vented into the atmosphere.  CSB recognizes flaring is safer, but does allow for venting into the atmosphere in special cases, especially when that venting will not put workers or the public at risk.

  1. Ensure Hazardous Chemicals Vented Into the Atmosphere Discharge to a Safe Location

Where are the discharge points on your emergency pressure relief systems?  Are they at areas where they can harm workers within its proximity at ground level or on walkways or platforms?   Are they near building intakes?  If your company is subject to Process Safety Management (PSM) requirements, CSB says the required periodic reviews would be a good time to evaluate these issues as well as other audits or incident investigations.

Read the Report

Find CSB’s report, along with four case studies and their resulting recommendations at https://www.csb.gov/assets/1/6/csb_eprs_alert.pdf.

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OSHA Memo to Affect Way Agency Issues Certain Penalties, With Potential for Significant Increases

OSHA Memo to Affect Way Agency Issues Certain Penalties, With Potential for Significant Increases

OSHA’s Director of Enforcement and Director of Construction have joined together to issue two memos to its Regional Administrators and State Plan Designees to alert them on how to interpret penalties in certain cases.

Instance-by-Instance Citations

First, the memo “Application of Instance-by-Instance Penalty Adjustments” adds more circumstances in which these types of penalties can be charged.  Instance-by-Instance penalties are fines for every single instance that the violation occurs, such as penalties by machine, by entry, by location, or by employee.

The memo says that high-gravity serious violations of the following standards can now be subject to Instance-by-Instance penalties:

  • Fall Protection
  • Trenching
  • Machine Guarding
  • Respiratory Protection
  • Permit-Required Confined Spaces
  • Lockout/Tagout
  • Other-than-serious violations of the recordkeeping standard

Only those standards that have text which allows for violations of individualized duties rather than general course of conduct can be used to find incident-by-incident penalties.  For example, if machines are missing guards or if employees do not put lockout/tagout devices on each energy isolating device, you could be fined per instance because they are needed on each machine.

Memo guidance says discretion can be used for Instance-by-Instance penalties when penalty adjustments don’t advance the deterrent goal.  The following factors are to be considered:

  • Willful, repeat, or failure to abate violations within the past five years where that classification is current;
  • Failure to report a fatality, inpatient hospitalization, amputation, or loss of an eye;
  • The proposed citations are related to a fatality/catastrophe; or
  • The proposed recordkeeping citations are related to injury or illness(es) that occurred as a result of a serious hazard.

Penalty evidence and justification must be documented and the Regional Office of the Solicitor must be consulted before these will be issued.

Grouping Penalties

Next, the memo “Exercising Discretion When Not to Group Violations” reminds Regional Administrators and Area Directors that they have the discretion to NOT group violations together in instances where it could help create a deterrent.  Grouping is allowed when:

  • Two or more serious or other-than-serious violations are so closely related they constitute a single hazardous condition (then they are grouped based on the most serious item);
  • Two or more violations are found which, if considered individually, represent other-than-serious violations but together could create a substantial probability of death or serious physical harm (then the violations are grouped as a serious violation); and,
  • When several other-than-serious violations are found (then they are grouped to create a high gravity other-than serious violation).

The memo is reminding that violations don’t have to be grouped if it doesn’t elevate the gravity/classification of the citation when the evidence could allow for multiple citations.  That is, if OSHA can find evidence that the violations could have different abatement methods, if each one could have resulted in death or serious harm, or if each violation condition could expose workers to different hazards, then they can charge each violation separately without grouping them.

In addition, guidance in the OSHA Field Operations Manual says violations are not to be grouped when:

  • Violations are found in separate inspections on more than one day;
  • The same violations are found at multiple sites, but at different locations. If your company is inspected at different branches/locations/sites and you violate the same standard at each place, then you are fined separately at each place;
  • Separate sections of the General Duty Clause are violated. Separate sections of the General Duty Clause cannot be grouped together, but a General Duty Clause section can be grouped with a related regulation; and,
  • Violations are so egregious that they trigger OSHA’s Instance-by-Instance Penalties.

OSHA Fines Increased

Dollar amounts on OSHA fines also were increased at the beginning of the year.  The maximum penalty amounts in 2023 are $15,625 per violation for serious, other-than-serious, posting requirement, and failure to abate violations, and $156,259 per violation for willful and repeat violations. This is an increase in 7.5%, which is the biggest year to year increase since 2016.

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The Importance of Water Audits: A Comprehensive Guide

The Importance of Water Audits: A Comprehensive Guide

What Is a Water Audit?

A water audit is a systematic examination of all aspects related to water use and efficiency in a given facility. It involves measuring, monitoring, and analyzing water use patterns to identify opportunities for improved water efficiency. This term is often used by water auditors, professionals who specialize in conducting these assessments.

The Role of the International Water Association (IWA)

The IWA is a global network of water professionals striving towards a water-wise world. They advocate for effective water management practices, including the need for regular water audits. They emphasize that understanding water usage patterns is key to achieving sustainable water management.

Why Are Water Audits Important?

Water audits are essential tools for commercial and institutional facilities seeking to conserve water and reduce costs. They provide valuable insights into a facility’s water use, helping to identify inefficiencies and opportunities for improvement.

The Role of a Certified Landscape Irrigation Auditor

A certified landscape irrigation auditor is a professional who evaluates irrigation systems to ensure they are operating efficiently. They play a crucial role in the annual water audit, particularly for facilities with extensive landscapes.

Understanding Regional Water Resources Agencies

Regional water resources agencies are responsible for managing and protecting local water resources. They often provide free water audit software to help businesses and organizations conduct their own audits. These tools can be invaluable for entities attempting to improve their water efficiency.

Achieving Water Efficiency through Water Audits

Water audits are a critical step towards achieving water efficiency. By identifying leaks, inefficient appliances, and wasteful behaviors, audits enable facilities to take targeted action to reduce water use.

Landscape Irrigation Water Use

Landscape irrigation can be a significant contributor to a facility’s water use. A basic irrigation schedule, recommended by the Irrigation Association, can help manage landscape irrigation water use effectively.

The Role of Water Utilities

Water utilities are responsible for supplying clean, safe water to the community. They often offer a water loss control program to help customers reduce their water usage and lower their bills.

Digging into Water Audit Data

Water audit data provides a wealth of information about a facility’s water use. This data can reveal patterns and trends, helping to identify areas where water efficiency can be improved.

Understanding the Water Audit Method

The water audit method involves collecting data on water use, analyzing this data, identifying inefficiencies, and recommending improvements. This method can be carried out by a professional water auditor or using free water audit tools provided by water utilities.

The Benefits of a Free Water Audit

Many water utilities offer free water audits to their customers. These audits can provide valuable insights into a facility’s water use and identify opportunities for cost savings.

Managing an Irrigation Project

An irrigation project, such as upgrading an existing system or installing a new one, can significantly impact a facility’s water use. An audit can ensure that the project is designed and implemented with water efficiency in mind.

The Future of Water Audits

As water scarcity becomes an increasingly pressing issue worldwide, the importance of water audits is set to grow. With the support of organizations like the IWA and regional water resources agencies, water audits will continue to play a key role in promoting sustainable water use.

In conclusion, water audits are a vital tool for managing water use effectively. By identifying areas of inefficiency and recommending targeted improvements, they enable facilities to conserve water, reduce costs, and contribute to a more sustainable future.

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What Will Inspectors Look for in Combustible Dust Inspections?

What Will Inspectors Look for in Combustible Dust Inspections?

We recently discussed in this blog OSHA’s revised Combustible Dust National Emphasis Program.  Along with that revision OSHA’s shared its instructions to inspectors on what how to conduct the inspection, what to look for, how to build a case for a citation and which standards they could cite in a citation.

In this article, we’ll list out exactly what an inspector will be looking for if they arrive to your site for a combustible dust inspection, the information you’ll need to provide, and which standards you can be cited under.  There is no official OSHA combustible dust standard, so inspection instructions can help serve as a guidance to help you determine what you need to have in place not only to do well in an inspection, but to keep your people safe.

How Will OSHA Determine Who Gets Inspected?

First, will you be on the target list?

The NAICS codes who are likely to have combustible dust hazards are gathered together on Appendix B of the emphasis program.  OSHA will pull a list of all companies who qualify and generate a random order list.  Each company will be assigned a number and OSHA inspectors who have had specialized training in combustible dust hazards will be assigned to conduct inspections. This list will remain active for 3 years before a new one is generated. Between 2013 and 2017, OSHA conducted approximately 500-600 per year between programmed (planned) and unplanned inspections.

Your company can be deleted off the list if you have been inspected within the past 5 fiscal years, were inspected for combustible dust hazards and no citations were issued, or if you were inspected for combustible dust hazards, was cited but a follow-up inspection verified you did abate the hazards. Also, if you are a VPP or SHARP company, you can be deleted off the list.

If you’re not on the list for programmed inspections, you can still be inspected if there has been a complaint or if you have had a fatality or catastrophic incident related to combustible dust.

What Will Inspectors Be Looking for in a Combustible Dust Inspection?

This is the list of items that OSHA will be evaluating and the potential documentation they will be looking for:

  1. History of Fires and Explosions

Inspectors will be determining if your plant has a history of fires, flash fires, deflagrations of process vessels and inside buildings, and explosions of vessels.  They’ll be conducting employee interviews, looking at OSHA logs, looking at insurance claims, accessing local fire department records, and conducting onsite visual inspections to look at the condition of your equipment.  They’ll be placing special attention to discoloration, bulging, repairs and missing/damaged pieces or appendages of your equipment.

  1. Safety Data Sheets (SDSs)

Inspectors will go through your SDSs, looking for combustible dusts.

  1. Electrical Area Classification Drawings/Documents

Inspectors will be looking at your classification documents to find areas marked Class II, Division 1 or 2 to ensure electrical equipment is approved for that hazardous location.

You are required to have these drawings per 29 CFR 1910.307, which is the Hazardous (Classified) Locations Standard.

  1. Dust Hazard Analysis

Inspectors have been instructed to do a dust hazard analysis toward the end of the inspection to help them in determining your citation, rather than at the beginning of the inspection to determine the scope.  This analysis includes observations of all areas of the facility for accumulation issues to determine overall potential for fire, flash fire or explosion.

They’ll be looking at:

  • Horizontal structures
  • Conduits and pipe racks
  • Cable trays
  • Floors
  • Above suspended ceilings
  • On or around equipment, especially on elevated horizontal surfaces

They will be taking measurements of depth, determining physical area sizes, and may be bringing cameras and video cameras on poles to help take photos of high places.

  1. Control and Suppression Systems

Inspectors will be looking to ensure:

  • Dust collectors and dust handling equipment has explosion prevention/suppression systems and deflagration propagation prevention devices;
  • Dust systems that return clean air to buildings have proper protections;
  • There are no hazardous levels of combustible dust accumulations outside of equipment;
  • Number and sizes of horizontal surfaces are minimized and designed to prevent dust accumulation;
  • Equipment that produces, transports, stores or handles dust (mixers, silos, mills, ducts, dust collectors, etc.) are designed and maintained to prevent dust leakage/escape/clouds;
  • Material transport systems (conveyors, elevators) are designed to prevent dust leakage/escape/clouds;
  • The method of cleaning and the tools you use to clean are proper. Are you using specialized vacuums to clean up combustible dusts, what are you doing to clean up dust, and if you use compressed air is it under 30 psi with the right chip guards and PPE?
  • Electrical equipment and lights are proper for use in those areas;
  • Powered industrial trucks are approved for use in those locations;
  • Hot work, welding, cutting and grinding is not performed in those areas;
  • Ductwork from dust generation, handling and collecting systems is conductive, bonded and properly grounded to dissipate static accumulation;
  • Maintenance of mechanical equipment is conducted to prevent generation of heat and sparks;
  • Process systems have magnetic separators and/or tramp metal separators installed;
  • Your ductwork has proper transport velocity to prevent accumulation in the ducts and that ducts have inspection and cleanout ports/hatches;
  • Housekeeping procedures are in place; and,
  • You have ignition control programs for:
    • Hot work and hot surfaces
    • Bearings
    • Self-heating materials
    • Open flames
    • Fuel-fired equipment
    • Heated process equipment
    • Heated air
    • Frictional sparks
    • Impact sparks
    • Electrical equipment
    • Electrostatics or other similar sources in dust handling equipment.
  1. Sampling Results

Inspectors will be collecting dust samples from each area they believe has a potential for a combustible dust hazard.  This could be from elevated surfaces, horizontal surfaces as high overhead as possible, floors and equipment surfaces, dust collection equipment and within process equipment.  They are not allowed to enter into your confined spaces, but they can use a non-spark producing scope or scoop on an extension pole to collect their sample.

Samples will be sent to the OSHA Salt Lake Technical Center which has specialized knowledge and experience with combustible dust hazards.

A good practice with all OSHA inspections is to make sure you conduct your own side-by-side sampling, that is, you sample what they sample and get your own independent results.  Be advised, combustible dust samples are going to be considerably more expensive samples to have analyzed by a laboratory than other types of materials.

  1. Other Documentation

Inspectors will be gathering all kinds of other information including:

  • How your equipment is connected and how the process flows;
  • Piping and process diagrams;
  • They’ll take photographs, videos and make diagrams or sketches documenting extent and depth of dust and condition of equipment;
  • Room dimensions;
  • Engineering controls used;
  • Design information, make, model, serial numbers of dust collectors;
  • Date of installation and operator manuals for dust collection system;
  • Dirty and clean size/volumes for dust collection system;
  • Warning signs and alerts on equipment regarding combustible dust;
  • External ignition sources; and,
  • Internal ignition sources.

What are Some Potential Standards You Could be Cited Under?

OSHA does not have its own dedicated combustible dust standard, but it can use a wide variety of other standards to cite you for these hazards.  These include:

Housekeeping Standard (Non-Storage Areas) – 29 CFR 1910.22

A little dust here and there wouldn’t be enough.  You can be cited under this standard if you have a visible volume of combustible dust in the workplace.  This is where that dust hazard analysis comes in.  They will use their measurements and observations for extent, depth and calculations of area.  If you have dust everywhere and it’s pretty significant, expect a violation of this standard.

Housekeeping Standard (Storage Areas) – 29 CFR 1910.176(c)

This is from the Handling Materials – General standard which says that storage areas need to be free from accumulation of materials that constitute hazards including explosion and fire.

General Duty Clause – Section 5(a)(1)

As with a lot of other cases, usually there’s always something within the tried-and-true General Duty Clause that could be included. In this case it will be related to the dust collection system or your dryers, mixers, material storage, bucket elevators and mills.  In addition to reviewing your safety and maintenance manuals, inspectors may do some research into your industry to find potentials for combustible dust hazards and also use NFPA 65 or other NFPA standards to find issues.

Some ideas for citations under the General Duty Clause listed for inspectors in their inspection guidance include:

  • Problems with dust collectors;
  • Ductwork-related problems;
  • Improperly designed deflagration venting;
  • Unprotected processing and material handling equipment (no deflagration suppression); and,
  • Improperly designed or maintained blowers, collection systems and exhaust systems used at sawmills.

Ventilation – 29 CFR 1910.94

Paragraph (a) of this standard deals with abrasive blasting including fire and explosion hazards.  If your ventilation equipment is not constructed in accordance to NFPA 91 and 68, then you can be cited here.

PPE – 29 CFR 1910.132(a)

If employees are not wearing FR (flame-resistant) clothing around combustible dust areas where they could receive burn injuries from flash fires, you can be cited under the PPE standard.

Hazardous (Classified Locations) – 29 CFR 1910.307

This is in the Electrical Subpart S area of the standards.  If sample results show you have combustible dust in a Class II area and it’s not safe for it to be there, you would be cited under this one.  They can also cite Class I and III electrical-related issues here too if they find them along the way.

Powered Industrial Trucks – 29 CFR 1910.178

If you have a forklift that’s not rated an EX (explosion proof) in the area where there’s combustible dust, you can be cited here.  Also be aware that many jurisdictions still have Powered Industrial Truck emphasis programs so they can conduct an additional separate inspection regarding your trucks while they are there for combustible dusts.

Welding, Cutting and Brazing – 29 CFR 1910.252

Under the general requirements, if you are conducting cutting and welding in explosive atmospheres, you can be cited here.

Warning Signs – 29 CFR 1910.145

This comes from the standard for Specifications for Accident Prevention Signs and Tags under Subpart J, General Environmental Controls.  If you have safety instruction signs missing from equipment or missing from entrances where there are explosive atmospheres, expect a citation here.

Hazard Communication – 29 CFR 1910.1200

Did you know that combustible dust is considered a hazardous chemical?  This needs to be incorporated into your hazcom program.   All equipment containing combustible dusts, including drums and containers used to collect dusts from dust collectors and cyclones must be properly labeled just like any other hazcom container.

You should also document notifying and training employees on its hazards.

SDSs are now supposed to include combustible dust as a not otherwise classified hazard with the signal word “warning” and the hazard statement “may form combustible dust concentrations in the air.”

Others and Specialty Standards

  • Means of Egress – 29 CFR Subpart E
  • Portable Fire Extinguishers – 29 CFR 1910.157 (no emergency action plan or fire prevention plan)
  • Fire Brigades – 29 CFR 1910.156
  • Spray Finishing – 29 CFR 1910.107
  • Bakery Equipment – 29 CFR 1910.263
  • Sawmills – 29 CFR 1910.265
  • Pulp and Paper Mills – 29 CFR 1910.261

Do you need help with combustible dust?  iSi can help with programs, audits and hazard assessments, sampling, PPE determinations, training and more.  Contact us today!

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OSHA Updates Its Combustible Dust National Emphasis Program

OSHA Updates Its Combustible Dust National Emphasis Program

In 2007, after a number of combustible dust incidents, OSHA issued its National Emphasis Program on Combustible Dusts.  After years of inspections and gained knowledge about combustible dusts in industry, OSHA maintains this National Emphasis Program is now updating it to better target those industries they are finding are having the most issues.

What Are Combustible Dusts?

Combustible dusts are organic or metal dusts ground into very small particles, fibers,  flakes, chips, or chunks which makes them more likely to cause fire, flash fire, deflagration and explosion hazards.  They can be found in process equipment, dust collectors, electrical equipment, and all around the building.

Some typical combustible dusts include:

  • Metal dusts like aluminum, magnesium and iron
  • Wood dusts
  • Coal, carbon and carbon black
  • Plastic dusts, phenolic resins and additives
  • Rubber dust
  • Biosolids
  • Organic dusts like sugar, flour, paper, soap and dried blood
  • Textile dusts

Grain handling dusts are also combustible, however, due to the incidents and explosions involving grain handling facilities, they have their own emphasis program.  The combustible dust emphasis program looks at all other dusts or those facilities that may not qualify to be inspected under the grain handling emphasis.

Affected Industries

The combustible dust emphasis program has listed quite a few NAICS codes targeted for programmed inspections in its Appendix B.  Some of these include:

  • Wood products
  • Forest and furniture
  • Chemicals
  • Metal processing
  • Agriculture and food (human and animal)
  • Rubber and Tire
  • Paper products
  • Textiles
  • 3-D printing
  • Pharmaceuticals
  • Wastewater treatment
  • Recycling
  • Coal dust handling and processing

Through its inspections since 2007, OSHA found:

The Top 5 Industries with the Most Combustible Dust Hazards

  • Farm suppliers
  • Institutional furniture manufacturers
  • Metal window and door manufacturers
  • Sheet metal work
  • Furniture and upholstery repair

The Industries With the Most Fatalities and Catastrophes:

  • Animal food manufacturing
  • Sawmills and lumber production
  • Wood manufacturing and processing
  • Agriculture processing

New Industries Added to Appendix B to Be Inspected

Through inspection data it was found that certain industries needed to be added to Appendix B because they were more likely to have combustible dust hazards or the number of combustible dust-related fatalities or catastrophes had went up.  These include:

  • Commercial bakeries
  • Printing ink manufacturing
  • Cut stock, resawing lumber, and planing
  • Leather and hide tanning and finishing
  • Truss manufacturing
  • Grain and field bean merchant wholesalers

Industries Removed from Appendix B

Those industries that OSHA found were less likely to have combustible dust hazards or who had low incidents and violations were removed from Appendix B and are no longer on the target list for programmed inspections.  These include:

  • Fossil fuel electric power generation
  • Cookie and cracker manufacturing
  • Pharmaceutical preparation manufacturing
  • Unlaminated plastic profile shape manufacturing
  • Noncurrent carrying wire device manufacturing
  • Blind and shade manufacturing

How Will OSHA Determine Who Gets Inspected?

OSHA will pull a list of all companies whose NAICS codes fall under those listed in Appendix B to generate a random number list.  Each company will be assigned a number and OSHA inspectors who have had specialized training in combustible dust hazards will be assigned to conduct inspections. This list will remain active for 3 years before a new one is generated. Between 2013 and 2017, OSHA conducted approximately 500-600 per year between programmed (planned) and unplanned inspections.

Your company can be deleted off the list if you have been inspected within the past 5 fiscal years, were inspected for combustible dust hazards and no citations were issued, or if you were inspected for combustible dust hazards and were cited but a follow-up inspection verified you did abate the hazards. If you are a VPP or SHARP company, you also will be deleted off the list.

Even if you’re not on the list for programmed inspections or in Appendix B, you can still be inspected if there has been a complaint or if you have had a fatality or catastrophic incident related to combustible dust.

There is no OSHA combustible dust standard, so what will an inspector be looking for when they come onsite for one of these inspections?  Stay tuned for our next blog article, “What Will Inspectors be Looking for in Combustible Dust Inspections?”

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Making Changes to Equipment or Operations?  Do You Need a Construction Air Permit?

Making Changes to Equipment or Operations? Do You Need a Construction Air Permit?

What Are Construction Air Permits and How Do We Determine If We Need One?

Whenever you plan on making changes to equipment or operations, before you ever get started, your company should always determine whether or not you will need to obtain a construction air permit from your state (or local) environmental agency.

Air Permit Regulations

The Clean Air Act sets standards to prevent significant deterioration (PSD) of the air quality for an area.  This is a federal regulation and EPA has the regulatory authority to enforce it, but it can also delegate authority to individual states by approving the state’s plans to enforce these regulations.

Air permits are required any time a company will exceed criteria for six different criteria pollutants (sulfur dioxide, carbon monoxide, particulate matter, lead, nitrous oxides, and ozone (volatile organic compounds)) or from a list of 187 hazardous air pollutants. Permits outline the emission sources at a facility and can include emission limitations, equipment maintenance requirements, and reference applicable Maximum Achievable Control Technology (MACT) standards and New Source Performance Standards (NSPS).

What Kinds of Activities May Need an Air Permit?

Some examples of equipment or processes that may produce emissions that may require an air permit may include:

  • Compressors
  • Paint Booths
  • Degassing Vessels or Lines
  • Engines
  • Generators
  • Ovens
  • Incinerators
  • Boilers

Some activities that may produce emissions to require an air permit may include:

  • Loading/Unloading Operations
  • Material Storage/Transfer
  • Painting
  • Solid Wastes
  • Tank Loading/Unloading
  • Truck Loading/Unloading
  • Valves, Vents, Vessels and Tanks
  • Wastewater Treatment
  • Welding
  • Asphalt Mixing/Rock Crushing

Operating Permits vs. Construction Permits

Air permits required for regular operations are called operating permits.  They are applicable to the entire facility.  There are different types of operating air permits based on whether or not you are located in an EPA area of nonattainment, how you much you will be emitting, and what you’ll be emitting.

Air permits can also be required for specific projects where you’re going to be making changes or additions, and these are called construction permits/approvals.  Even though the word construction is used, you don’t have to technically be doing “construction” activities.  In this instance, it means the process of making any change to an operation.  Once the change has been made, that change then becomes part of the operating permit because it becomes part of the facility operations.

Depending on the state, sometimes operating and construction permits are done at the same time to prevent time loss between making the change and getting the new operation up and running.  Some states do them separately.  Some states require construction permits be incorporated into the facility’s operating permit, and other states will issue combined construction/operating permits.

Construction Permits/Approvals

Except in limited situations, air construction permits must be received BEFORE your construction or change can commence.

Some changes to your facility that could require a construction permit include:

  • Installation of new process equipment;
  • Modification to existing process equipment;
  • Installation of or change in an emission control device;
  • Debottlenecking of a process that allows for increased production; or,
  • Increases to throughput or operating hours (if currently limited by an operating permit).

Determining If You Need a Construction Air Permit

As with operating permits, for a construction air permit one of the first things you’ll need to do is determine how this change will affect your Potential to Emit (PTE).  This is the maximum design capacity of a stationary source to emit a pollutant under its physical and operational design.  Calculate the PTE for each pollutant associated with this source.  There are several different ways to do this calculation and your state may have a preference on which one you use to determine your PTE.

Once the PTE for the project or modification has been calculated, compare it to the construction permitting thresholds.  Please note that in some cases, you may still need to have a construction air permit even if potential emissions are lower than the construction approval thresholds.  For examples, what type of equipment it is or what type of process it is may affect its status.  Check your state’s rules on what their guidelines are.

Obtaining the Permit

If your calculations tell you the project requires an air construction permit, the customary application must be submitted for approval.  If a project is going to make such a difference that it will now trigger Major Source or Major Modification thresholds, you may need to obtain a Federal Air Permit.  This is a lengthy application, and approval can take quite a long time, from several months to well over a year or two, depending on your state and the workload.  So, it’s very, very important you try to do this well ahead of the time you plan on making the change.

If you already have an operating permit, be aware that your change that you are looking at getting permitted under the construction permit may cause changes to your operating permit at the same time.  Know exactly what the conditions of your operating permit are and see how these changes will affect it so that if you are in a state which does operating and construction permits separately, you can get started on making changes to your operating permit now so that you can operate the results of the construction.

Some states have a streamlined construction permit application process for certain equipment such as emergency generators or boilers.  These applications are short and sweet and typically receive agency approval quickly.

If the project meets the exemption from air construction permitting, retain all documentation for your files.  Even if exempt from permitting, state or federal regulations may have requirements for the source, and you still may need to complete some state paperwork.

With all air permits, both construction and operating permits, once you have turned in your application, be prepared to wait.  The state agency will check for the completeness of your application and may have questions.  Once any issues have been resolved, you should receive a draft of your permit to review and comment on. If it’s not in your state’s policy to send a draft, ask for one, especially if it’s a combined operating/construction permit.

Make sure you read this draft!  You will be held to what this permit says.  Make sure everything about the permit is correct, including any equipment details, inconsistencies, unclear language, typos, etc.  Remove or clarify any ambiguities to make the conditions as broad as possible. Any errors could cause you issues later when being inspected, leading to an inspector thinking you are doing something differently than what’s allowed in the permit.

Once the draft has been approved, there may be a public notice period depending on state policy, and then after that you should receive your permit.

Please note, your construction permit could take several months to be approved, so make sure you plan accordingly.  And also remember…construction permits must be obtained BEFORE construction can be started.

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What is a Phase II Environmental Site Assessment?

What is a Phase II Environmental Site Assessment?

What is a Phase II?

A Phase II Environmental Site Assessment (ESA) is an in-depth procedure conducted by a environmental professional to confirm the presence or absence of suspected contaminants.

This assessment typically follows a Phase I ESA and involves more intensive methods such as soil, groundwater, or building materials sampling and laboratory analysis.

Phase II ESAs are essential when dealing with properties that may have been affected by hazardous substances. The environmental site assessment process provide a detailed understanding of the environmental conditions at a site and act as a critical tool in managing potential liabilities associated with contamination. Conducting an environmental site assessment is a staple of a companies environmental due diligence.

What’s the Difference Between a Phase I Environmental Site Assessment and Phase II Environmental Site Assessment?

While both assessments aim to evaluate potential environmental risks associated with a property, their methodologies differ significantly.

Phase I environmental site assessments are essentially a preliminary study. It involves a detailed review of historical records and a visual inspection of the property to identify potential environmental risks. This phase does not involve any physical testing or sampling.

Instead, it focuses on identifying ‘Recognized Environmental Conditions’ (RECs) that indicate the possible presence of contamination on the site.

On the other hand, a Phase II assessment is a more detailed and hands-on investigation. It is triggered when RECs are identified during the Phase I assessment. Phase II involves actual sampling and testing of soil, groundwater, or building materials to confirm if suspected contaminants exist at concentrations above regulatory limits.

When Do I Need a Limited Phase II ESA?

A Limited Phase II ESA is often required when the Phase I ESA identifies potential environmental risks, but the suspected contamination is localized to specific areas of the site.

This more focused assessment is less extensive — and thus less costly — than a full Phase II ESA but still provides valuable insight into potential environmental liabilities. It involves targeted sampling and analysis based on the findings from the Phase I ESA.

Who Pays For A Phase 2 ESA?

Typically, the party who stands to benefit from the information generated by a Phase II ESA is responsible for its cost.

This could be a prospective buyer who wants to ensure they are not acquiring contaminated property, a current property owner seeking to understand their liability, or a lender requiring assurance on the environmental status of a property before approving a loan.

In some cases, the cost may also be negotiated between the buyer and seller as part of the property transaction process.

How Long Does a Phase 2 ESA Take?

The duration of a Phase 2 ESA can vary depending on several factors. These include the size and complexity of the site, the number of samples taken, and laboratory turnaround times for sample analysis. On average, a Phase II ESA can take anywhere from a few weeks to a couple of months to complete.

How Much Does a Phase 2 Environmental Study Cost?

The cost of a Phase 2 ESA varies widely based on the scope of work required. Factors influencing the cost include the size and complexity of the site, the type and number of samples, and the analytical methods used. It can range from a few thousand dollars for a Limited Phase II ESA to tens of thousands for a more complex site.

What Is The Final Goal of a Phase 2 Assessment?

The ultimate goal of a Phase 2 Assessment is to provide a clear understanding of the environmental conditions at a site. The findings from a Phase II ESA can significantly impact property transactions, lending decisions, and redevelopment plans.

If contamination is confirmed, it may necessitate remediation under local, state, or federal regulations. By identifying these issues early, businesses can proactively manage potential liabilities and avoid unexpected costs and delays.

Conclusion:

In conclusion, a Phase II Environmental Site Assessment is a critical tool in managing environmental risks. This environmental assessment provides a detailed understanding of the recognized environmental condition at a site, helping stakeholders make informed decisions and potentially avoid significant future liabilities.

Although the process may seem daunting, it is a crucial step towards ensuring the safe and responsible use of land.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance.

We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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EPCRA Tier II: Does the March 1 Deadline Apply to Your Facility?

EPCRA Tier II: Does the March 1 Deadline Apply to Your Facility?

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. This is a federal requirement, but each state has its own nuances in method of submittal, what’s required with the submission and who to send it to. For reporting, EPCRA has a Tier I form and a Tier II form. The Tier II has all of the information Tier I does, but with more detail, so many states just require the more complete Tier II form.

Does This Apply to My Facility?

First, all chemicals you’re required to keep a Safety Data Sheet (SDS) for per OSHA requirements are subject to reporting. Next, determine if the quantities on-site at any one time last year met the threshholds for reporting.

Extremely Hazardous Substances listed in 40 CFR part 355 Appendix A and Appendix B, the reporting quantity is 500 pounds or the amount of the Threshold Planning Quantity (TPQ), (whichever is lower). Gasoline and diesel fuel at retail gas stations have their own individual requirements. For all other hazardous chemicals, the threshold is 10,000 pounds.

There are a few exclusions per EPCRA for food, food additives, drugs, cosmetics, substances for general/household purposes for use by the general public, fertilizer sold to farmers, and substances used by research labs and hospitals.

Information Collected

Each state has its own requirements, but the information reported is very similar. Some examples of information you’ll need to gather include:

  • SDS for Each Chemical
  • Facility Information
  • Emergency Contacts and Contacts Knowledgeable of Tier II Information
  • Physical and Health Hazards
  • Chemical Descriptions
  • Maximum Amount Present on any Single Day During Reporting Period
  • Average Daily Amounts (Weights)
  • Number of Days Onsite
  • Storage Types, Conditions and Locations

Reporting

Each state varies on how the information is reported then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1.

Need Help?

iSi can help you determine your applicability, what your state requires and then help you complete the Tier II reporting elements. Contact us today for a pricing quote!

Need Help?

Mar. 1 will be here soon — Let iSi take care of this requirement for you!

Need Help?

Mar. 1 will be here soon — Let iSi take care of this requirement for you!

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. This is a federal requirement, but each state has its own nuances in method of submittal, what’s required with the submission and who to send it to. For reporting, EPCRA has a Tier I form and a Tier II form. The Tier II has all of the information Tier I does, but with more detail, so many states just require the more complete Tier II form.

Does This Apply to My Facility?

First, all chemicals you’re required to keep a Safety Data Sheet (SDS) for per OSHA requirements are subject to reporting. Next, determine if the quantities on-site at any one time last year met the threshholds for reporting.

Extremely Hazardous Substances listed in 40 CFR part 355 Appendix A and Appendix B, the reporting quantity is 500 pounds or the amount of the Threshold Planning Quantity (TPQ), (whichever is lower). Gasoline and diesel fuel at retail gas stations have their own individual requirements. For all other hazardous chemicals, the threshold is 10,000 pounds.

There are a few exclusions per EPCRA for food, food additives, drugs, cosmetics, substances for general/household purposes for use by the general public, fertilizer sold to farmers, and substances used by research labs and hospitals.

Information Collected

Each state has its own requirements, but the information reported is very similar. Some examples of information you’ll need to gather include:

  • SDS for Each Chemical
  • Facility Information
  • Emergency Contacts and Contacts Knowledgeable of Tier II Information
  • Physical and Health Hazards
  • Chemical Descriptions
  • Maximum Amount Present on any Single Day During Reporting Period
  • Average Daily Amounts (Weights)
  • Number of Days Onsite
  • Storage Types, Conditions and Locations

Reporting

Each state varies on how the information is reported then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1.

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OSHA Injury Posting Requirements

OSHA Injury Posting Requirements

It’s that time of year again when employers need to post and submit last year’s injury and illness data.  Here is a list of timeframes and more information about which companies this affects:

Posting Injury and Illness Data

All employers who are required to maintain OSHA logs must post a copy of their OSHA 300A log from February 1 through April 30.  This needs to be placed in a common area where an employee can easily see it.  Make sure you have a company executive sign and certify it before posting.


Electronic Submittals to OSHA

osha injury reporting recordkeeping compliance chart for 2023

Employers with more than 250 employees and employers with 20-249 employees under certain NAICS codes are required to submit their 300As to OSHA’s Injury Tracking Application (ITA) website.  Here’s a list of those special industries covered by the recordkeeping rule:  Covered Industries.

In order to post to the website, you’ll need two separate accounts.  First is an account with the Injury Tracking Application website.  The other, new as of October 2022, you’ll have to have an account at Login.gov, a secure website the federal government uses for many different applications.   You need to make sure you use the same email address for both so that the records can be connected.

Information can be manually uploaded, uploaded via a CSV file (available as a template from the OSHA ITA website), or transmit it electronically through an API.

If your company has multiple locations, or establishments as they are referred to, you need to report for each establishment, but can use the same ITA account to do it.  A third party can help do this for you, but accuracy and completeness of data is still your company’s responsibility.

Even if you have 0 recordables, you still need to report, and if you miss the March 2 deadline, you can still submit at any time of the year.  Just be aware you’re not compliant until you do.  If you submit early and find out there was an injury last year that became recordable, they would like for you to update the information, but it’s not required.

What’s Recordable, What’s Not?

If you have questions or need help in determining what’s recordable and what’s not, iSi can help.  We can advise on a case-by-case basis, and we have conducted presentations that cover some of the trickier examples that we can provide through our training program.  Contact us for pricing on either of those.

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EPA Proposes Changes to Air Permitting Regulations for New Sources

EPA Proposes Changes to Air Permitting Regulations for New Sources

Companies with operations subject to the Clean Air Act are required to submit their plans for any operational or physical changes before they occur to see if they’ll have a significant affect on air quality.  This program is called the New Source Review preconstruction permitting program, or NSR program.  EPA is making some changes in the way fugitive emissions are figured into the equation to determine if the changes to existing sources will be considered a major modification to the company’s air permit.

 

The NSR Program

EPA’s NSR program wants to make sure that a company’s changes will not significantly affect air quality of the area.  In the U.S., there are cities and regions that have air quality levels that are above EPA’s National Ambient Air Quality Standards. These areas are called “non attainment” areas and industries in those areas have additional rules, regulations and restrictions they need to follow as a result.  In other cities and regions that are still below the national standards, EPA wants to make sure a company’s changes don’t significantly deteriorate the area’s compliance so that they can stay below non attainment.  This program is called the Prevention of Significant Deterioration, or PSD program.

The NSR program looks to see if your new operations will become a new major source of air pollution, or if any changes to your current major source permit would be considered a major modification, depending on certain thresholds.

 

Fugitive Emissions

When making this determination, EPA counts fugitive and stack (non-fugitive) emissions.  A fugitive emission is one that could not reasonably pass through a stack, chimney, vent, or similar opening.

Historically, for new sources to become new major sources, only certain type of sources belonging to a specific list would have to count fugitive emissions toward the threshold.

Existing sources would have to count both fugitive and non-fugitive (stack) emissions.  However, in 2008, EPA finalized a rule for existing sources that would also allow them to only count fugitive emissions only for certain types of major sources belonging to specific categories.

 

The Proposed Changes

The specific categories of sources that had to count fugitive emissions were petroleum refineries, large fossil fuel-fired steam electric plants, and Portland cement manufacturers.  Everyone else was not required to include fugitive emissions.

However, EPA wants to repeal that 2008 rule for major modifications.  Now, all existing major sources would need to count fugitive emissions toward the major modification thresholds.

Anytime a company’s changes are considered a major modification, they need to obtain a major NSR permit before moving forward with construction. The permit will require emission control measure to ensure that changes won’t degrade air quality.

Another change that EPA is proposing is to remove a provision established in 1980 that exempts certain stationary sources from substantive major NSR requirements if the only reason the change is considered a “major modification’ is because fugitive emissions are included.

 

Upcoming Changes at Your Facility? What’s Your Air Compliance Status?

Are you considering a major change to your operations or equipment that will affect your air compliance status?  Do you need help with construction air permitting or making determinations on what your air quality compliance requirements are?  Let our team of air permitting experts assist you!  Contact us today!

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EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

EPA has issued Final Rule updates to 40 CFR Part 63, subpart HHHHHH, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.  This NESHAP standard applies to companies coating miscellaneous parts/products made of metal, plastic or a combination, anyone stripping paint using methylene chloride, or conducting motor vehicle/mobile equipment refinishing.

EPA issued the changes as part of its technology review.  They didn’t find any new developments in practices, processes or controls that warranted changing existing rules, but they did decide to take the opportunity to update and clarify some of the items in the current requirements.

Here is a summary of what has changed in the regulation:

Electronic Reporting

Rather than mailing reports to EPA, you will now be required to be submit electronically through the CEDRI/CDX platform.  This includes initial notifications, notifications of compliance status changes, annual notification of changes reports and the report required in 40 CFR 63.11176(b).

HAP Content

EPA updated the definition of a “target HAP containing coating” to clarify that compliance is based on the hazardous air pollutant (HAP) content of the coating applied to the part, not the content purchased.

Spray Gun Cups and Liners

For spray guns with disposable cap liners, EPA amended “spray-applied coating operations” to clarify that the allowance to use spray guns outside of a spray booth is based on the volume of the spray gun cup liner, not volume of the cup itself.  They also clarified that repeatedly refilling and reusing the 3.0 fl. oz. cup or cup liner, and/or using multiple liners for a single spray-applied coating operation will be considered trying to circumvent the regulation and you can be fined for this.

Exemptions Became Easier

If motor vehicle/mobile equipment spray coating operations don’t spray apply coatings that contain the target HAP, rather than the current petition for exemption process, the rule now allows companies to submit notifications to the Administrator.  This process is meant to be simplified and easier.  All records to support the notification shall still be kept as a backup to support the notification, but those records don’t need to be sent to the administrator.

Military Equipment: Tanks and Submarines

The NESHAP no longer applies to surface coating or paint stripping on tanks and submarines when that work is conducted onsite at military installations, NASA, or at the National Nuclear Security Administration.  It also doesn’t apply when conducted offsite where military munitions or equipment are manufactured by or for the Armed Forces and that equipment is directly and exclusively used for the purposes of transporting military munitions.

OSHA Carcinogen References

EPA removed references to OSHA’s carcinogens because OSHA no longer spells out what those are.  Instead, EPA will be putting in their own list.  These will include target HAPs that must be counted if they’re present at 0.1% by mass or greater.  All other HAPs will be counted if present at 1.0% or greater by mass.

No Non-HAP Solvents

The term “Non-HAP solvent” will be removed because there’s no requirement in the standard to use them and there is no other place where this is used.

Filter Test Method

EPA updated the spray booth filter test method to the most recent ASHRAE method, ANSI/ASHRAE Standard 52.2-2017 Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size.  The standard also now includes a reference to EPA Method 319-Determination of Filtration Efficiency for Paint Overspray Arrestors as an alternative method.  EPA Method 319 is the same one referenced in the NESHAP for Aerospace Manufacturing and Rework to test paint spray booth filters for hexavalent chromium emissions.

For more information about changes to the rule, you can find the final rule in its entirety here.

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Chemical Hygiene Plan: What You Need To Know

Chemical Hygiene Plan: What You Need To Know

 

What is a chemical hygiene plan?

A Chemical Hygiene Plan (CHP) is a written document required by the Occupational Safety and Health Administration (OSHA). It outlines specific safety procedures that workers must follow while working with hazardous chemicals, in order to minimize risk of exposure to potentially dangerous substances.

The CHP covers topics such as personal protective equipment, engineering controls, safe work practices, health and hygiene, medical surveillance, chemical labeling and storage, spill response plans, hazardous waste disposal and more. It is important to have a comprehensive and up-to-date CHP in place as it ensures that workers are aware of the hazards associated with their job duties and how to protect themselves against them.

What are the objectives of a chemical hygiene plan?

A Chemical Hygiene Plan (CHP) is an organized and comprehensive plan designed to protect laboratory workers from the potential health hazards posed by hazardous chemicals in the work environment. It outlines safety protocols for working with hazardous materials, identifies any special procedures or precautions that need to be taken when dealing with them, and provides guidance on how to safely handle common laboratory operations such as waste disposal and emergency response.

A CHP establishes the safety procedures that must be followed in order to ensure that laboratory personnel are adequately protected from hazardous chemical exposure, while also ensuring compliance with relevant laws and regulations.

The main objectives of a CHP include minimizing employee exposure to hazardous chemicals, reducing the potential for accidental spills or exposures, identifying appropriate personal protective equipment (PPE) for each type of operation, and providing training for personnel on the appropriate use of hazardous materials.

What should a chemical hygiene plan include?

A CHP should include a written policy outlining the responsibilities of personnel, recommendation on protective clothing and equipment, training requirements for workers, methods for labeling and storing chemicals, emergency procedures in case of spills or other incidents, and equipment maintenance protocols.

In addition, the CHP should document any hazardous chemical exposures that have occurred. By following these guidelines, workplaces can ensure that personnel are adequately protected from exposure to hazardous substances and minimize the risk of injury or illness due to chemical use.

What does a chemical hygiene officer do?

A Chemical Hygiene Officer (CHO) is an important role in any organization that works with hazardous chemicals. Their primary responsibility is to ensure the safety of personnel and protect the environment by designing and implementing chemical safety programs, policies, standards, and procedures.

The chemical hygiene officers also oversee compliance with all applicable laws related to health and safety in the workplace. They are responsible for monitoring chemical use, storage, and disposal; performing safety audits; conducting safety training; and providing expert advice on safe chemical handling practices.

In addition to these core duties, the CHO may coordinate with other departments such as Human Resources and Environmental Health & Safety in order to ensure compliance across the organization and present health and safety requirements.

 

What is the OSHA chemical safety plan?

The OSHA Chemical Safety Plan is a set of steps that employers must take to ensure the safety and health of their workers, as well as the workplace itself, when handling hazardous chemicals. It outlines the preventive measures that employers should implement in order to protect employees from exposure to hazardous materials.

This plan includes training for workers on proper handling and storage of chemicals; personal protective equipment (PPE); emergency response plans; and other safety measures. Proper implementation of the OSHA Chemical Safety Plan can help to reduce incidents and injuries caused by hazardous chemicals, as well as ensure a safe environment for all employees. The plan also serves to keep businesses compliant with federal regulations set forth by the Occupational Safety and Health Administration.

What is the OSHA laboratory standard for chemical exposure?

The Occupational Safety and Health Administration (OSHA) sets a standard for chemical exposure and protective laboratory practices in the workplace. This includes keeping employees safe from any kind of hazardous chemical, whether it be by inhalation, ingestion or skin contact. OSHA enforces this standard through its Hazard Communication Standard, which requires employers to provide workers with information about the chemicals they use, including proper storage, labeling and handling instructions.

The OSHA lab standard also sets limits on the amount of exposure an employee can have to certain chemicals, ensuring that workers remain safe from any potential harm. To make sure these standards are met, employers must provide adequate training and ensure that employees follow safety protocols when working with hazardous materials.

What are the 10 steps to chemical safety?

Chemical safety is an important part of any workplace environment. Knowing and understanding the 10 steps to chemical safety can help ensure that all employees are safe while handling hazardous materials.

  1. The first step to chemical safety is to identify potential hazards by reviewing the Material Safety Data Sheet (MSDS). The MSDS includes detailed information about the properties of a given chemical, including its health hazards, protective measures, and emergency response information.

  2. The second step is to use the right personal protective equipment (PPE) when working with hazardous materials. This may include safety glasses, respirators, gloves, lab coats, and other items that are necessary for safe handling of chemicals.

  3. Thirdly, it’s important to keep all containers of chemicals labeled and sealed properly. Labels should include the name of the chemical, concentration, date prepared, and appropriate hazard warnings.

  4. The fourth step is to practice good housekeeping in the lab or work area by keeping all areas clean and free from debris that might contaminate products. All spilled materials must be removed from the work area as soon as possible.

  5. The fifth step is to make sure that all employees are trained on the proper handling of chemicals in their work area. This includes understanding how to use protective equipment and safety measures to reduce exposure.

  6. The sixth step is to provide good ventilation in the lab or work area. Poor ventilation can increase exposure to hazardous materials, so it’s important to keep areas well-ventilated.

  7. Seventhly, emergency equipment should be readily available in case of an incident. This includes items like fire extinguishers, eye wash stations, and spill kits to contain hazardous materials.

  8. The eighth step is to create a culture of safety by ensuring that all employees are aware of the dangers associated with handling hazardous materials. All workers should understand the proper safety procedures, and regular training should be conducted to reinforce these procedures.

  9. The ninth step is to monitor employee exposure levels by providing personal protective equipment and conducting periodic air quality tests. This will help ensure that all workers remain safe while working with hazardous materials.

  10. Finally, the tenth step is to document all safety measures taken in a detailed hazard assessment report. This report should include a description of the potential hazard, control measures taken to limit exposure, and any additional safety precautions that were implemented.

By following these 10 steps to chemical safety, employers can ensure that their employees remain safe while handling hazardous materials in the workplace.

 

What are 4 hazardous chemicals?

Chemical safety is an important topic in any work environment, as exposure to hazardous chemicals can have serious effects on a person’s health and wellbeing. To protect workers and customers alike, it is essential that businesses identify the potential risks associated with their products or services, and take steps to minimize them. One way to do this is by identifying the four main classes of hazardous chemicals: corrosives, flammables, oxidizers, and toxic materials.

Corrosives are substances that can cause severe damage to the skin or eyes upon contact. These can include acids, alkalis, and other caustic materials. Flammables are extremely combustible liquids or gases that can ignite easily and burn rapidly under certain conditions. Oxidizers are substances that can cause rapid or spontaneous combustion when they come into contact with flammable materials. Finally, toxic materials are substances that can cause chronic or acute health problems if ingested, inhaled, or absorbed through the skin.

What are the five rules of chemical safety?

Chemical safety is a critical part of all standard operating procedures. It helps ensure the safety and health of personnel, as well as protects equipment and materials from potential hazards. There are five basic rules of chemical safety that must be followed in order to minimize risk and maintain a safe working environment.

  • Read the labels and material safety data sheets (MSDSs) for any chemicals that you plan to use. Be sure to understand the hazards of each chemical as well as the proper disposal or storage requirements.
  • Wear the appropriate protective clothing and equipment when working with dangerous chemicals. This includes gloves, goggles, and an apron or lab coat. Additionally, it is important to ensure that your work area is well-ventilated.
  • Never mix chemicals, even if they are similar. This can lead to unpredictable and potentially hazardous reactions.
  • Store chemicals properly in order to prevent spills or other accidents. Always follow the manufacturers’ instructions regarding recommended storage temperatures and containers.
  • Always clean up any spills immediately and properly dispose of all chemicals after use. This includes cleaning any equipment or surfaces that may have been exposed to hazardous materials.

Adhering to these five basic rules of chemical safety can help ensure a safe working environment for everyone in your laboratory.

What is a common hazardous chemical in healthcare?

Healthcare workers are exposed to all kinds of hazardous substances. These can range from pesticides used in the garden, to chemical cleaners used in bathrooms and kitchens, to toxic drugs and medicines. One of the most common hazardous chemicals found in healthcare is formaldehyde.

Formaldehyde is a colorless, odorless gas that has many industrial uses such as preserving specimens for research laboratories and embalming. It can also be found in some furniture, carpets, cleaning supplies and even cosmetics.

In healthcare settings, formaldehyde is often used as a disinfectant to prevent the spread of infections. Exposure to high levels of formaldehyde can cause respiratory irritation, headaches and nausea. Healthcare workers must take extra precautions to protect themselves from exposure by wearing personal protective equipment such as respirators, eye protection and gloves.

Additionally, employers should use ventilation systems to reduce exposure levels in the workplace. By following these simple steps, healthcare workers can help protect themselves from dangerous chemical hazards and potentially hazardous chemicals.

Another hazardous chemical that is often found in healthcare is ethylene oxide. Ethylene oxide is a colorless gas with a sweet odor and bitter taste. It is used in healthcare as a sterilizing agent for medical equipment and supplies.

However, exposure to high levels of ethylene oxide can cause skin irritation, headaches and dizziness. Healthcare workers must take precautions to protect themselves from any potential health risks associated with this chemical by wearing protective clothing such as respirators, masks and gloves when handling ethylene oxide. Proper chemical hygiene training and a chemical hygiene plan are crucial for employee safety.

What are 5 top laboratory hazards?

Laboratories are places for experimentation and research, but they can also be dangerous. Understanding the potential hazards that exist in a laboratory is essential to ensure safety. The five top laboratory hazards include chemical exposure, fire, radiation, biological agents, and electrical shock.

Chemical exposure is a significant hazard in any laboratory situation due to the use of hazardous materials such as acids, solvents, and other hazardous compounds. It is important to wear the appropriate protective gear such as safety glasses, gloves, and an apron when working with chemicals to reduce potential exposure.

Fire can cause serious damage in any laboratory setting due to the presence of volatile materials. Laboratories should be equipped with fire extinguishers and personnel should be trained on how to use them. In addition, flammable materials should be stored in proper containers and away from direct sources of heat.

Radiation is a potential hazard in laboratories that use radioactive materials or radiation-generating devices such as X-ray machines. It is important for personnel using these devices to wear protective gear such as lead aprons and glasses, and follow safety protocols.

Biological agents can also be a hazard in certain laboratory settings. It is important to wear protective clothing when working with biological materials and to practice proper hygiene such as washing hands regularly and avoiding contact with eyes, nose, or mouth. Additionally, it’s important to dispose of infectious waste properly and use safe disposal methods for sharp objects such as needles.

What are the 10 lab safety rules?

It is important to understand the 10 lab safety rules in order to ensure a safe and productive laboratory environment. The 10 lab safety rules are:

  1. Wear proper protective gear – including clothing, eye protection, and gloves – whenever handling chemicals or working with equipment that generates heat, sparks, and open flames.
  2. Read labels carefully before using any chemical or equipment.
  3. Follow the instructions provided and adhere to safety protocols in the lab and laboratory safety manual.
  4. Keep chemicals away from sources of heat, ignition, and open flames.
  5. Know how to properly handle and dispose of hazardous materials according to safety protocol.
  6. Know the location of emergency exits, fire extinguishers, spill kits, eyewash stations, and first aid kits.
  7. Never work alone in the lab; always ensure that someone else is present in case of an emergency.
  8. Do not touch or taste any chemicals without permission from a qualified supervisor.
  9. Report any accidents or spills to your supervisor immediately.
  10. Clean up all equipment and materials after use and before leaving the laboratory with prior approval.

Adhering to these 10 lab safety rules is essential for ensuring a safe and productive workplace in any laboratory setting. Always be aware of the potential hazards and use caution when handling hazardous materials or working with dangerous equipment.

How often should a workplace or laboratory chemical inventory conducted?

It is important to conduct a workplace or laboratory chemical inventory at least once a year. This helps to ensure that all chemicals stored onsite are accounted for, and any expired or unwanted materials can be safely disposed of. Additionally, employers should update the list as soon as a new container of hazardous material is received.

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OSHA Considering Changes and Updates to the PSM Standard

OSHA Considering Changes and Updates to the PSM Standard

OSHA Considering Changes and Updates to the PSM Standard

 

OSHA has been accepting comments on several proposed changes to its Process Safety Management, or PSM standard.

PSM is an OSHA regulation that is concerned with processes at your facility that use highly hazardous chemicals.  PSM provides a compliance framework to evaluate each process with the end goal of no spills, fires, explosions, reactions, releases or other incidents arise from their use.  The official standard can be found at 29 CFR 1910.119.

PSM hasn’t been updated since its creation in 1992.  OSHA has been reevaluating PSM, and EPA has been similarly been reevaluating their Risk Management Plan, or RMP standard since the 2013 West, Texas fertilizer storage facility explosion.  Just like the difference between OSHA and EPA, PSM is meant to protect workers while RMP is meant to protect the environment.

Potential changes to PSM could include:

  • Clarifying the exemption for atmospheric storage tanks;
  • Strengthening employee participation and stop work authority;
  • Requiring the development of written procedures for all elements specified in the standard, identification of records required by the standard, and a records retention policy (previously referred to as “Written PSM Management Systems”);
  • Including oil-well and gas-well drilling and servicing as part of the standard and resuming enforcement for oil and gas production facilities;
  • Expanding coverage and requirements for reactive chemical hazards;
  • Updating and expanding the list of highly hazardous chemicals in Appendix A;
  • Requiring continuous updating of collected information (paragraph (d));
  • Requiring formal resolution of Process Hazard Analysis team recommendations that are not utilized;
  • Better defining what critical equipment means, what equipment deficiencies are, and expanding paragraph (j) to cover the mechanical integrity of critical equipment;
  • Clarifying the scope of the retail facilities exemption;
  • Defining the limits of a PSM-covered process;
  • Better defining recognized and generally accepted as good engineering practices (RAGAGEP) and requiring evaluations of any updates to them;
  • Requiring safer technology and alternatives analysis;
  • Requiring consideration of natural disasters and extreme temperatures;
  • Amending paragraph (k) of the Explosives and Blasting Agents Standard to cover dismantling and disposal of explosives and pyrotechnics;
  • Clarifying that paragraph (l) covers organizational changes;
  • Amending paragraph (m) to require root cause analysis;
  • Requiring coordination of emergency planning with local emergency-response authorities;
  • Requiring third-party compliance audits; and,
  • Including requirements for employers to develop a system for periodic review of and necessary revisions to their PSM management systems (previously referred to as “Evaluation and Corrective Action”).

This action is currently in the comments stage, and stakeholder meetings were held in October 2022 with comments accepted through mid-November 2022.  We will keep you updated when anything final is published.

Do you need help with PSM?  Does this apply to you?  iSi can help!  Contact us today for more information.

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The Comprehensive Guide to an Environmental Audit Checklist

The Comprehensive Guide to an Environmental Audit Checklist

In an era where environmental consciousness is at the forefront, businesses must ensure they meet and exceed environmental compliance norms. As leaders in Environmental, Health, and Safety (EHS) services, iSi is committed to guiding you through the intricacies of environmental compliance.

Decoding Environmental Compliance

Environmental compliance refers to the adherence to environmental laws, environmental regulations, standards, and other requirements such as site permits to operate. Non-compliance can lead to severe penalties, including substantial fines and potential operational shutdowns.

The Importance of Environmental Audit Reports

Environmental audit reports are essential tools for assessing a company’s environmental performance. These reports provide a comprehensive picture of how well a business adheres to environmental rules, helping identify possible environmental issues and areas for improvement.

The Role of an Environmental Compliance Audit

An environmental compliance audit evaluates a company’s adherence to environmental laws and regulations. It assesses the effectiveness of the company’s environmental management systems, providing a detailed overview of the company’s environmental impact.

Unpacking the Audit Checklist

Creating an audit checklist for an environmental audit can be daunting due to the extensive range of factors involved. However, our expertise allows us to distill this process into key areas that should be your primary focus:

1. Regulatory Requirements: Ensure your business is aware of and complies with all relevant local, state, and federal environmental laws and regulations. This includes rules related to air quality, water quality, waste management, and hazardous materials.

2. Environmental Permits: Verify that all necessary environmentally focused permits are current and that operations are within permit conditions. This could include discharge permits, emission permits, or waste disposal permits.

3. Waste Management: Review waste management practices to ensure hazardous and non-hazardous waste is correctly identified, stored, transported, and disposed of. This is particularly important under acts like the Toxic Substances Control Act.

4. Emissions Control: Check that all emission control systems are functioning correctly and comply with required standards.

5. Record Keeping: Ensure all necessary records, reports, and documentation related to environmental compliance, including employee training records, are properly maintained and readily accessible.

6. Employee Training: Confirm that all employees have received appropriate training regarding environmental compliance responsibilities.

7. Emergency Preparedness: Evaluate your company’s preparedness for environmental emergencies and ensure there is an emergency response plan in place.

The Depth of Functional Environmental Audits

Functional environmental audits assess the effectiveness of a company’s environmental management system. These audits evaluate various aspects, such as air quality monitoring, wastewater management, materials management, and compliance monitoring.

Understanding Environmental Laws

Environmental laws are designed to mitigate environmental harm by regulating activities that impact the environment. They cover a broad range of areas, from air and water quality to waste disposal and hazardous materials.

The Role of Regulatory Agencies

Regulatory agencies enforce these laws and regulations. They play a crucial role in issuing environmental permits, monitoring compliance, and taking enforcement action when necessary.

The Impact of a Company’s Environmental Performance

A company’s environmental performance has significant implications for its reputation and bottom line. High environmental performance can lead to cost savings, improved stakeholder relations, and enhanced market opportunities.

The Importance of a Detailed Regulatory Checklist

A detailed regulatory checklist is an invaluable tool for ensuring compliance with environmental rules and regulations. This checklist provides a structured approach to identifying potential compliance issues and addressing them effectively.

Final Thoughts on Environmental Compliance

In conclusion, an environmental compliance audit is not just a formality but a vital part of your business’s sustainability strategy. With this comprehensive checklist and iSi by your side, you can navigate the complexities of environmental compliance with confidence and ease.

At iSi, our focus is not just on helping businesses meet environmental standards but also on fostering a culture of sustainability and responsibility. We believe that environmental compliance is not just a box-ticking exercise but a commitment to our planet and future generations.

Choose iSi for your environmental auditing needs, and let’s work together to create a safer, healthier, and more sustainable world. Contact us today to learn how we can help you achieve EHS excellence.

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Process Safety Management (PSM) Compliance Audit: What You Need To Know

Process Safety Management (PSM) Compliance Audit: What You Need To Know

Organizations that handle highly hazardous chemicals must have a comprehensive safety management program to ensure their employees, contractors, and members of the public are protected from potentially catastrophic incidents.

Organizations should regularly audit their operations to identify any potential gaps or areas of improvement in their safety management program.

What does PSM stand for?

PSM stands for Process Safety Management.

The Process Safety Management system should include policies and procedures for identifying, evaluating, controlling, and monitoring all risks associated with working with these materials.

It should also include training on safe work practices as well as emergency preparedness and response plans to ensure that personnel are adequately trained and equipped to handle emergencies and unexpected releases with hazards involved.

What is a PSM audit?

A PSM audit assists companies in determining whether they are doing what is required for compliance against OSHA’s PSM mandate.

An audit of Process Safety Management compliance is an important and necessary step for companies to ensure they are meeting OSHA’s regulations and guidelines.

These audits help identify any gaps in PSM implementation or areas where further training may be needed, enabling organizations to take corrective action quickly.

How often is a PSM audit required?

Recommended, once every three years.

The process safety management audit must include an audit of the PSM program that covers all components, including management commitment and employee participation, process safety information, process hazard analysis, operating procedures, training programs, contractor selection/management, pre-startup safety review procedures, mechanical integrity of equipment associated with the process systems being used by the company and incident investigation.

What is the OSHA standard for PSM?

OSHA developed the Process Safety Management (PSM) standard (issued in 1992) designed to prevent catastrophic events, such as explosions and releases of toxic substances, from occurring by requiring employers to identify and assess the risks associated with the hazardous materials and processes.

Employers must also develop safe operating procedures for activities that involve these chemicals or processes, as well as provide training for employees on proper use of equipment and safe work practices. In addition, employers must implement an emergency response plan and monitor the safety system to ensure that it remains effective.

The Osha’s process safety management applies to processes involving threshold quantities of flammable liquids and gasses (10,000 lbs) as well as 137 listed highly hazardous chemicals. It also covers the manufacturing of explosives. Osha PSM requirements and safety programs help maintain safe and healthy workplaces.

Occupational safety, emergency procedures and emergency planning are just a few ways Osha is assisting companies protect the safety and health of their employees.

What are 4 areas that a compliance audit examines?

The 4 areas compliance audits examine are compliance preparations, security policies and procedures, user access controls, and risk management procedures.

An effective audit is essential to any organization’s success. It helps ensure that the organization adheres to all applicable regulations and best practices, protects its assets, reduces risk, and maintains the trust of its stakeholders.

The audit should assess an organization’s compliance standards, policies and procedures, access controls, security measures, written procedures, user activity monitoring systems, and incident response plans.

It should also identify any areas where the organization may be failing to meet its obligations, and provide recommendations for improvement. A successful audit will enable an enterprise to better protect itself against legal, financial, and reputational risks.

Additionally, a thorough audit can help ensure that the organization remains compliant with all applicable laws and regulations.

What are the 14 Process Safety Management (PSM) elements?

  1. Process Safety Information
  2. Process Hazard Analysis
  3. Operating Procedures & Safety Procedures
  4. Hot Work Permits
  5. Emergency Preparedness & Emergency Shutdown Systems
  6. Mechanical Integrity
  7. Pre-startup Safety management
  8. Training Management
  9. Change Management
  10. Incident Investigation
  11. Contractors
  12. Compliance Audits and Compliance evaluations
  13. Employee Involvement and Employee Safety
  14. Trade Secrets

Companies can use these 14 elements to determine and analyze data in near real-time to automatically identify potential hazards before they become a problem.

This allows them to quickly respond and address problems before any harm is done, mitigating the risk of a catastrophic event.

In addition, automation can be used to streamline process safety operations, providing more accurate and timely data to improve decision-making.

How Can We Help? Ask a Question or Request Info or Pricing

Do you need an idea of where you stand with EPA or OSHA regulations?  Do you need full-time or temporary personnel to manage the day-to-day compliance tasks?  Would your employees benefit from onsite environmental training?  Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!

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Mining Testing

Mining Testing

What is it?

Mining testing is a process that helps evaluate the safety, productivity, and environmental impact of mining operations, mining services, and the mine site. It involves collecting data from various sources such as geological surveys, graphical analysis, borehole drilling tests, hydrogeological studies, geophysical surveys and laboratory testing to ensure the quality and sustainability of mining projects.

This type of testing helps identify potential risks before proceeding with large-scale mining operations, helping to ensure that the safety of miners and environment is protected in the mining industry. Additionally, it also helps identify resources that are economically viable for extraction.

Mining testing is an essential part of any successful mining venture and is carried out by experienced professionals with specialized knowledge in order to maximize success. This testing should be used in any mine planning as any good mining engineering professional would advise.

What are the different types of mining tests?

Mining tests are used to assess potential mining sites and the quality of ore they contain. These tests can identify if a particular rock or mineral is economically viable for extraction, as well as provide information about the environmental impact of a particular mining operation.

There are several types of tests commonly used in the industry including geophysical surveys, chemical analyses, drill core sampling, and exploratory mining. Geophysical surveys use various techniques such as magnetometers, gravimeters, and seismic reflection to identify subsurface structures that may contain economically valuable ore. Chemical analyses involve taking samples from the site for laboratory analysis to determine the mineral content of an ore body.

Drill core sampling involves taking cylindrical samples of rock from different depths in order to determine the grade of ore as well as to determine overall mineral composition and structure. Exploratory mining or underground mining proposed by exploration companies involves digging trial pits or tunnels in order to gain a better understanding of the deposits present at a particular site. Each of these tests can provide important information for successful mining operations, allowing companies to make decisions that will maximize their profits while minimizing environmental impacts.

How do you test for mineral content?

Mineral content in water is tested using a variety of methods. A common method is to use colorimetry, which involves measuring the amount of light absorbed by different chemical compounds in the sample being tested. Another way to test mineral content is through ion-selective electrodes, which measure the electrical potential between two points and can be used to identify certain ions or minerals present in the sample.

X-ray fluorescence spectroscopy is also used to detect and quantify minerals in water samples, as it looks for the presence of specific chemical elements. Finally, Inductively Coupled Plasma Mass Spectrometry (ICP-MS) can be used to measure trace levels of minerals in a sample by analyzing the frequencies emitted by different particles.

What do MSHA (Mine Safety & Health Administration) inspectors look for?

MSHA inspectors are responsible for ensuring the safety and health of miners in the workplace. They look for a variety of conditions to ensure miners are following safety regulations, such as checking ventilation systems, guarding against hazardous machinery, inspecting electrical equipment, and monitoring fire risks. They also take into account worker practices like wearing personal protective equipment, using approved methods for lifting heavy objects, and following all regulations and guidance. This work practices should be spearheaded by company management which provides extensive training for employees.

Furthermore, MSHA inspectors review records of workplace illnesses and injuries to identify underlying safety issues that need to be addressed. Finally, they observe work areas to make sure miners are aware of hazards and have the necessary tools and equipment to do their jobs safely. MSHA inspectors play an important role in safeguarding the health and safety of miners.

What does a mining consultant do?

A mining consultant, also known as a mineral engineer or natural resources specialist, is responsible for helping companies and organizations extract the maximum value from their mining operations. They work closely with clients to assess and analyze geological data in order to develop cost-effective production plans that take into account environmental protection decisions. Mining consultants may also be tasked with developing mine reclamation plans, assisting with feasibility studies, monitoring safety and compliance issues, and providing expert testimony in legal proceedings.

In addition, they may be called upon to provide environmental consulting services for mining projects, advise on policy development related to the industry, and conduct research on new technologies and processes that could improve extraction practices. As such, mining consultants play an important role in helping organizations maximize their returns while promoting sustainable mining practices.

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Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

When it comes to environmental health and safety (EHS) audits, having a comprehensive checklist is essential. Audits are designed to show the effectiveness of an organization’s existing EHS management system as well as identify any areas that need improvement. A good audit will be comprehensive in scope and include elements such as environmental compliance, risk assessment, occupational safety, air quality monitoring, and emergency preparedness.

The challenge for many organizations is creating or finding an EHS audit checklist that covers all the necessary elements. To help get you started, we’ve put together a comprehensive guide to mastering the essential EHS audit checklist. This guide will provide you with everything you need to know about best practices and key components of successful EHS audits.

First, you’ll want to make sure that your EHS audit checklist is aligned with the organization’s goals and objectives. A comprehensive checklist should include all of the basic elements that are required by law or identified within the scope of an organization’s operations. This includes ensuring compliance with national and local environmental regulations, assessing workplace safety risks, monitoring air quality on site, and preparing for emergency situations.

Next, you’ll need to consider how often audits will be conducted. Depending on the size and complexity of the organization’s operations, this could range from once a year to multiple times per year. It may also be necessary to conduct periodic follow-up audits in order to ensure that any changes or improvements made since the last audit are still in place.

Finally, when conducting an audit it’s important to document everything that is found. This includes any potential hazards and exposures, compliance issues, and recommendations for improvement. Having a comprehensive audit report is essential for making sure that all corrective actions are properly implemented and tracked over time.

By following the above steps and having a detailed EHS Audit checklist in place, you can ensure that your organization is meeting all of the necessary standards for environmental health and safety. With the proper preparation and planning, you can have confidence that your audits will yield accurate results and provide you with the actionable insights needed to make improvements where necessary.

EHS Audit Checklist Templates

EHS audit checklists are an invaluable tool for organizations to ensure their health and safety processes are in line with industry standards. They help organizations identify potential risks, areas of improvement, and areas that need additional attention. EHS audit checklist templates provide a consistent structure for conducting audits and allow the organization to easily evaluate compliance across multiple departments and locations.

With the use of these templates, organizations can quickly identify which areas require further action or review. In addition, using an EHS audit checklist template ensures that all essential elements required for a successful safety program are included in the assessment process. This helps to ensure that any issues identified during the audit can be addressed in a timely fashion and prevents any unnecessary delays that could put workers at risk.

Who needs to use a health and safety audit?

A health and safety audit is necessary for any workplace, no matter the size or industry. It is important to make all employees aware of what measures need to be taken to reduce risks in the workplace.

Employers and business owners should use audit findings to ensure that their employees are safe from potential hazards. Additionally, supervisors and managers should also regularly monitor the implementation of safety protocols as part of a comprehensive risk management plan. The ultimate goal is to create an environment where everyone can work productively with minimal risks and hazard exposure. This includes providing appropriate protective gear for all employees as well as have all employees trained on safety policies.

By conducting regular audits, employers not only make sure their workers are well protected but also demonstrate good corporate citizenship towards regulatory authorities. Furthermore, these reviews may help identify areas of improvement so that effective preventive measures can be put in place. In sum, anyone with a stake in the safety and well-being of employees should incorporate health and safety audits into their overall risk management strategy.

EHS Audit Software:

EHS Audit Software is an essential tool for Environmental Health and Safety (EHS) professionals to monitor and ensure compliance with regulations. It automates the auditing process, providing insight into risk areas and helping organizations improve their processes.

EHS Management Software provides a comprehensive interface to facilitate efficient data collection, tracking and reporting of regulatory compliance-related activities. This makes it easier to identify deficiencies in safety protocols, quickly address potential hazards, and take proactive steps to mitigate future risks.

With the help of this software, organizations can ensure that they provide a safe workplace environment for all employees while minimizing both environmental impacts and financial costs associated with non-compliance.

EHS Audit Management Software Benefits

EHS Audit Management Software Benefits provides organizations with powerful tools to streamline their environmental, health and safety auditing processes. It helps them save time and resources while ensuring compliance with local regulations, industry standards, and best practices.

The software allows for automatic scheduling of audits and tracking of results, which can help identify gaps in safety protocols more quickly. This ultimately helps to reduce the risk of accidents, environmental damage, and costly fines. With centralized data storage and reporting capabilities, it also enables organizations to track their compliance progress over time, enabling them to continually strive for excellence in safety.

EHS Audit Management Software Benefits is a powerful tool that can help organizations protect their employees, customers, and environment while ensuring compliance with all relevant regulations.

Pre-Audit Phase

The Pre-EHS Audit Phase or audit planning is an important part of the overall Environmental, Health & Safety (EHS) audit process. During this phase, a company will assess its current EHS operations and compliance in order to identify any areas that may present possible risks or noncompliance issues.

This helps ensure the organization meets all applicable regulations and safety requirements, and helps reduce potential liability risks when an EHS auditor arrives. During the Pre-EHS Audit Phase, organizations often review their compliance records and processes, evaluate current systems, develop new procedures and protocols as needed, and produce a detailed report of findings.

This helps ensure the organization is properly prepared for the actual EHS audit itself. The Pre-EHS Audit Phase is essential to ensuring organizational safety and compliance with all applicable laws and regulations.

An effective Pre-EHS Audit Phase also helps an organization identify potential risks and areas of improvement before the actual audit begins. Through this assessment, organizations can develop specific strategies to improve their safety and compliance operations going forward, as well as develop plans for problems that may arise during the EHS audit itself.

What should be included in a health and safety audit checklist?

A health and safety audit checklist should include items that are relevant to the particular work environment being audited. This can vary depending on whether the workplace is an office, factory, warehouse, or other premises.

Generally, items that should be included in a health and safety audit checklist would be physical hazards such as trip/slip risks, poor lighting conditions, inadequate ventilation, and hazardous substances. Additionally, potential health risks such as noise levels, temperature/humidity levels, ergonomics, and the availability of safety wear should be considered.

All employees should also have access to first-aid kits and emergency procedures in case of accidents or incidents. Finally, employers should consider if necessary protective measures are in place to protect employees from violence or harassment. By including these items in a health and safety audit checklist, employers can ensure that their workplace is safe and compliant with relevant regulations.

What is a health and safety audit?

A health and safety audit is an independent assessment of a workplace to assess how well it complies with relevant laws, regulations, and industry standards. It evaluates existing practices and procedures in the workplace to make sure they are working properly and efficiently.

The aim of a health and safety audit is to identify any potential hazards or risks that could lead to injury or illness, as well as any areas where improvement is needed. A health and safety audit can help organizations meet their legal obligations and ensure the workplace remains safe and healthy for everyone.

It can also provide important data that can be used to develop effective strategies to reduce accidents, incidents, and other risks in the workplace.

Deficiencies and Corrective Actions

EHS corrective actions are an important part of creating a safe and healthy working environment. These corrective steps involve identifying workplace health and safety hazards, addressing the risks associated with those hazards, and taking steps to eliminate or mitigate any potential harm to workers and the environment caused by these hazards.

Corrective actions can include changing procedures, providing additional training, implementing new rules or regulations, or carrying out engineering modifications to equipment and machinery.

It’s important for employers to take corrective steps in order to protect their workforce, comply with regulations, and ensure a safe working environment. By taking corrective actions, employers can reduce the risk of injury and illness caused by workplace hazards.

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Health and Safety Consultants

Health and Safety Consultants

Consultants provide essential services to businesses, organizations, and individuals. They help ensure workplace safety by providing advice on health and safety regulations and policies, developing risk assessments, inspecting equipment or premises for safety hazards, conducting staff training sessions and developing emergency response plans.

These are knowledgeable in areas such as occupational health and safety regulation compliance, industrial hygiene principles, ergonomics, hazardous material management, fire protection engineering, accident investigations, construction site hazard recognition and more. Their expertise helps mitigate the risk of injury or illness within a work environment.

Additionally they can assist organizations in meeting all legal requirements for health & safety legislation in their respective countries or regions. Ultimately their work helps protect workers from potential hazards that may arise from working conditions.

Furthermore, safety consultants and safety professionals can provide a valuable service to businesses looking to expand or introduce new processes or practices. They can provide advice on the best practices for their particular industry, as well as how to best implement them with minimal risk of disruption to the operations.

Ultimately, this helps make sure that employees are working in an environment where their safety is paramount. Engaging with a qualified Health and Safety Consultant is essential for ensuring that an organization meets its legal obligations in terms of health and safety regulations and requirements.

Additionally, it allows companies to minimize risks, create a safe work environment for their staff, and ultimately protect their reputation should an incident occur.

OSHA Compliance Solutions

OSHA Compliance Solutions is a comprehensive suite of tools and services designed to help businesses stay in compliance with all applicable Occupational Safety and Health Administration (OSHA) regulations. The service includes access to the most up-to-date federal and state information, as well as an online library of safety training materials, safety programs, safety manuals, instructional videos, and other resources for your safety manager to use.

With these tools, businesses can easily create compliant work environments that protect employees from safety risks and injury. Additionally, OSHA Compliance Solutions can recommend a safety consulting company in which offers consulting services and technical assistance to further support companies’ compliance efforts.

These services include onsite visits for inspections or consultations, as well as identify workplace hazards and provide recommendations for corrective action plans when necessary. Your company will also be presented safety data sheets from these experienced safety professionals. OSHA Compliance Solutions helps businesses ensure their workplaces are safe, efficient, and in compliance with federal and regulations.

OSHA Training Solutions

OSHA Training Solutions is an industry leader in occupational safety and health training. With expertise on a wide range of topics related to workplace safety, OSHA Training Solutions provides comprehensive training courses, both online and in-person, to help employers meet their safety and health compliance requirements.

Their courses are designed to cover topics such as ergonomics, fall protection, hazardous materials handling, risk assessment, health programs, machine guarding, fire safety and more. They also offer a vast selection of online resources that provide easy access to up-to-date information on the ever changing regulations governing workplace safety. OSHA Training Solutions is committed to providing outstanding customer service and quality training solutions to ensure that workers stay safe while on the job.

With their commitment to excellence and dedication to helping employers protect their workforce from injury or illness, OSHA Training Solutions has become an industry leader in occupational safety and health training.

OSHA Compliance Evaluations

OSHA Compliance Evaluations are conducted in order to assess the safety and health conditions of a workplace and ensure that it is compliant with federal standards. During such evaluations, an inspector will look for potential hazards review company policies and procedures, inspect work areas, and verify compliance with OSHA regulations.

These evaluations also serve as an opportunity for employers to address any existing or potential safety risks before they become larger issues. Ultimately, OSHA Compliance Evaluations make workplaces safer places by identifying and preventing potentially dangerous situations.

Additionally, these evaluations can help employers save costs associated with employee injury or illness due to unsafe working conditions. By conducting assessments regularly, companies can protect the health and well-being of their workers while also avoiding violations of regulatory standards.

OSHA Inspection Guidance

The Occupational Safety and Health Administration (OSHA) provides inspection guidance to ensure compliance with federal safety standards. During OSHA inspections, OSHA inspectors conduct workplace inspections to assess compliance with safety regulations and identify any potential hazards that could cause harm to workers.

Inspectors may also speak with employers and employees during the inspection process in order to gather more information on working conditions. The inspector will then issue a report which includes recommendations for improvements or corrections based on their findings, along with a citation of violations if any were found. Employers must take the necessary steps to address the concerns raised in the report in order to come into full compliance with all applicable regulations.

By providing timely guidance and enforcement, OSHA helps keep workplaces safe from injury and illness, protecting both employers and employees.

Written OSHA Program Preparation

Written OSHA Program Preparation is an important part of any workplace safety program. It involves the development and implementation of policies and procedures for keeping workers safe from potential hazards. This includes identifying and addressing potential safety issues, training employees on safe practices, documenting all safety measures, and regularly auditing the system to ensure amenability with federal regulations. Taking these proactive steps helps to protect workers and create a safer work environment.

By setting up an effective written OSHA program, employers can ensure that their workplace is compliant with all applicable laws and regulations, while also protecting the safety and wellbeing of their employees. Written programs provide a roadmap for achieving workplace safety goals as well as creating an environment where employees understand the risks associated with their work and feel empowered to take action for protecting themselves and their colleagues.

Safety Data Sheet Preparation

A Safety Data Sheet (SDS) is a key document required by all employers to ensure the safety of workers in hazardous working conditions. SDSs are prepared to provide information about the properties of a particular substance or mixture, including its health and safety hazards, protective measures for handling, storing, using and disposing of it safely.

SDSs also include details on how to respond in case of an emergency involving the product. Preparation of SDSs requires knowledge of hazardous substances as well as knowledge of composition, toxicology and occupational health. Since many hazardous materials can exist in a number of different forms, it is important to ensure that the SDS accurately reflects the particular product’s characteristics. Furthermore, information must be regularly updated in line with changes in legislation and any new or revised hazard assessment data.

Health and Safety Program (HSP) Development

Health and Safety Program (HSP) Development is a comprehensive process that involves identifying potential risks, developing strategies to reduce risks and implementing those strategies in the workplace. A successful HSP requires proper planning, training, assessment and reporting of safety issues. The goal of HSP development is to protect workers from injury or illness associated with their job duties.

Emergency Response Plans

Emergency response plans are important to have in place for any organization, as they help to outline the steps that should be taken in the event of an emergency. These plans should include information about how to respond and evacuate a building safely, who is responsible for different aspects of the plan, and how to contact emergency services. This response plans should also consider potential risks, such as natural disasters or hazardous materials spills, and outline procedures for responding effectively.

Having a well-developed emergency response plan helps ensure employees are safe during an emergency situation, while also preventing costly damages if an incident occurs. Additionally, proper training on these plans allows staff members to become familiar with their roles so they can act quickly in the face of danger.

On-Site Health and Safety Management

On-site health and safety management is an essential part of any successful business. Effective management of workplace safety can help reduce risks, minimize injury and illness, protect employees’ rights to a safe work environment, and ensure that businesses meet all applicable safety regulations.

An effective on-site health and safety management system should include procedures for identifying hazards in the workplace, setting standards for worker protection, providing training for workers on how to safely conduct their job duties, responding quickly to reported or observed unsafe conditions or practices, conducting periodic inspections of the facility for potential hazards, and maintaining records documenting compliance with OSHA regulations.

LOTO Procedure Development

LOTO (Lock Out/Tag Out) Procedure Development is an essential element of workplace safety. Properly designed and implemented LOTO Procedures help to ensure that hazardous sources of energy are effectively isolated from equipment, thus preventing potential injuries or damages.

When creating a LOTO Procedure, it is important to accurately identify all potentially hazardous sources of energy, determine the proper type of lockout device needed for each source, and develop step-by-step instructions on how to properly de-energize and lock out the machine. Additionally, procedures should be regularly reviewed and updated as necessary in order to ensure they remain up-to-date and effective.

By following these steps in the development process, businesses can greatly reduce their risk exposure while also protecting their employees from potential hazards.

For more detailed information, businesses should consult OSHA regulations on LOTO Procedure Development as well as their own corporate safety policies. With the proper development and implementation of LOTO Procedures, businesses can ensure a safe and secure workplace environment while also adhering to all relevant safety regulations.

By investing in the proper protocols and procedures upfront, businesses can make sure that they are providing their employees with the necessary protection against hazardous energy sources. This is an important step toward ensuring a safe work environment for everyone involved.

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Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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Fit Testing Questions Answered

Fit Testing Questions Answered

Once you conduct an evaluation to determine what type of respirator your workers will be required to use to protect them from the contaminants around them (that is, what type, Assigned Protection Factor (APF) needed, what filters and/or cartridges are required, etc.), there are three general steps that come next: a medical evaluation to ensure they’re medically capable of wearing one, fit testing to determine which size most comfortably and accurately fits, and training.  In this blog, we dive into the fit testing side.

Respirator fit testing is conducted on tight-fitting respirators to make sure the respirator gets a good seal on the employee’s face so that no contaminants will leak into the mask.  They may not always be the most comfortable or convenient things to wear, but fit testing finds a balance of comfort and protection at the same time.

Qualitative or Quantitative?  What’s the Difference?

Fit-testing methods are referred to as qualitative or quantitative.

In qualitative fit-testing, once the person being fit tested has his/her mask on, the tester introduces items such as saccharine, Bittrex, banana oil or irritant smoke near the mask to see if the person can smell or sense it.  This method relies on the worker’s ability to sense odor or irritants. NIOSH currently doesn’t recommend irritant smoke for fit-testing.  Qualitative fit testing is only for half-face, full-face and N95 filtering facepiece respirators that have an APF of 10.  An APF is the level of protection the respirator will provide if it’s functioning and wore correctly.  For example, an APF of 10 means the user can expect to inhale no more than one tenth of the contaminant present. Qualitative fit-testing is easy, fast and fairly inexpensive.  It’s considered to be only a pass or fail type of test.

Quantitative respirator fit-testing uses a machine to measure pressure loss inside the mask or to count quantities of particles to calculate a fit factor.  Quantitative testing is considered more accurate than qualitative fit-testing.  Quantitative fit-testing must be conducted for respirators requiring an APF over 10.  Full-face tight fitting respirators that are quantitatively tested have an APF of 50.  An APF of 50 means the user can expect to inhale no more than one fiftieth of the contaminant present.

​When Do I Need to Fit-Test Someone?

Employers are to ensure employees wearing tight-fitting facepiece respirators are fit-tested:

  1. Before use
  2. Whenever a different respiratory facepiece is used (size, model, make, style)
  3. Annually

Why is Fit-Testing Required Each Year?

A study published by NIOSH has affirmed the need for OSHA’s annual requirement for fit-testing for filtering facepiece respirators and other tight-fitting respirators.

In its study, NIOSH followed 229 subjects over three years’ time, making fit and physical characteristic measurements every 6 months. It was found that after one year, 10% of the subjects had changes in fit. In two years it was 20%, and in the third year, it was up to 26%. OSHA’s intended threshold for fit changes, when it made its rules in 1998, was 7% annually.

NIOSH also found that subjects who had lost 20 or more pounds had respirator fit changes. The greater the weight loss, the higher the chance that the respirator fit changed. Thus, NIOSH recommends those persons who lose 20 or more pounds get priority fit-test scheduling, even it is less than a year since their last fit-test.

In addition to weight loss and gain, other events such as dental changes, facial scarring and cosmetic surgery can affect respirator fit as well.

Note: NIOSH’s study can be found at: https://blogs.cdc.gov/niosh-science-blog/2016/01/05/fit-testing/

What Difference Does Respirator Brand Make in Fit Testing?

Different brands also fit differently, so a size a worker may wear in one mask may not be the same size in another brand.  If the person wears glasses, hearing protection or other items around their head during the job, they must wear them during the fit test.

What Facial Hair is Acceptable in a Fit-Test?

Beards and facial hair on men are back in style, but beards and respirators do not get along.  Certain kinds and lengths of facial hair including beards, sideburns, some mustaches, and even a day or two of stubble can interfere with the seal.  According to NIOSH, presence of facial hair under the seal causes 20 to 100 times more leakage.  Gases, vapors and particles will take the path of least resistance and will flow right through the hair into the mask and into the lungs.

Our Physician is Booked Now, Can I Go Ahead and Do the Fit Test Before I Get My Respirator Physical?

No!  Respirator physicals (medical evaluations) need to be done before the fit test to ensure the person getting tested is even medically qualified to wear one.  Wearing a respirator can put a strain on the heart and lungs and it is very important that an employee has been evaluated by a medical professional to prevent causing any damage to the employee.

How Often is Respirator Training Required?

Respiratory protection training is required ANNUALLY, that is, within 12 months.  Doing this training around the same time as the physical and the fit testing can help reinforce proper care techniques for the respirator.  This training should cover how to properly don (put on) and doff (take off) them, their limitations and capabilities, why a respirator is needed, how to use them in an emergency or when they malfunction, how to inspect and remove the seals, how to clean and store it properly, how to recognize medical signs and symptoms that may limit or prevent its effective use, and the general requirements of the respiratory protection standard.

Additional training shall be conducted if there are any changes in your workplace, changes in respirator that would make previous training obsolete and when a worker’s actions show additional training is required to ensure their safe use.

What Documentation Do I Need to Keep?

Once you’ve had someone fit tested, you need to ensure you maintain records of the fit test.  The documentation needs to include:

  • The name of the person tested,
  • Type of test conducted
  • Specific make, model, style and size of respirator tested
  • Date of the test
  • Pass/fail results for qualitative fit testing, or the fit factor and strip chart recording from a quantitative fit test
  • A written copy of your Respirator Protection Program

Where Can I Find the Requirements for Fit-Testing? 

OSHA governs the usage of respirators and sets forth its standards in 29 CFR 1910.134 for general industry, and for construction, standard 29 CFR 1926.103 references back to the general industry standard, saying its requirements are identical.  The specific protocols and instructions on how to conduct a fit test are in Appendix A of that standard.

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SMETA Audits

SMETA Audits

SMETA AUDIT: What you need to know

What is a Smeta audit?

SMETA or Sedex Members Ethical Trade Audit is the leading global ethical audit and assurance methodology that helps companies to assess their suppliers’ performance against a set of criteria.

It covers labor, health & safety, environmental and ethics standards which are all important for responsible business practices. SMETA audits provide companies with an objective evaluation of supplier operations and highlight any areas for improvement. This helps

What are the 4 pillars of Smeta audit?

  1. Labor Standards

  2. Health and Safety

  3. Business Ethics

  4. Environmental Assessment

The 4-pillar SMETA audit, developed by the Sedex organization, is a globally accepted audit system used to assess a company’s ethical and sustainability practices. It requires organizations to adopt business practices beyond traditional labor standards in order to ensure that their operations are socially responsible.

The two mandatory pillars of the audit are Labor Standards and Health & Safety. Two additional pillars – Business Ethics and Environment – were introduced to further strengthen the social responsibility aspect of the audit.

Business Ethics encompasses areas such as anti-corruption, bribery, data protection, human trafficking prevention, gifts & entertainment and whistleblowing policy. These measures protect companies against unethical practices which can have serious reputational consequences for an organization if left unchecked. Ethical trading initiative and responsible business practice for all company’s is a necessity.

The Environmental pillar focuses on environmental management, renewable energy, efficient use of resources and waste minimization. Companies must demonstrate that they are taking all possible steps to minimize their impact on the environment and meet the expectations of society such as implementing sustainable business practices.

The 4-pillar SMETA audit is an effective way for companies to review their current practices around labor standards, health & safety, business ethics and environment. It provides a comprehensive view into a company’s social responsibility policies ensuring that operations are ethical, responsible and sustainable in the long run.

By completing this audit successfully, organizations can ensure that their products or services adhere to high levels of quality while also meeting sustainability benchmarks. This helps them build trust with partners, customers and other stakeholders while demonstrating corporate social responsibility.

How long is a Smeta audit valid for?

The SMETA audit report is a valuable tool for businesses to assess their ethical practices and ensure that their performance meets the highest standards. However, the validity of the audit report can vary depending on what timeframe the client decides upon.

Most clients opt for an annual audit cycle and set one year as the period of validity for the SMETA audit report.

How do I get a SMETA audit?

If you’re looking to complete a SMETA audit, the first step is registering and having an active account on the Sedex platform. With the right membership, your business can easily access the resources needed to successfully complete a SMETA audit.

What is the difference between Smeta audits and Sedex?

  1. Sedex is the name of the organization

  2. SMETA is the name of an audit methodology

Sedex’s SMETA audit methodology is widely regarded as the gold standard in ethical supply chain auditing. It is used by Sedex members and their suppliers to help them identify areas for improvement and ensure compliance with local laws, global standards, and corporate responsibility policies.

The audit consists of four sections (Labour Standards; Health & Safety; Environment; Business Ethics) that together provide a comprehensive view of supplier operations. Through SMETA audits, companies can identify and address potential risks in their supply chainsa as well as global supply chains quickly and efficiently.

By addressing any issues they find in their audits, companies can demonstrate commitment to responsible sourcing practices and mitigate business risk.

SMETA audits are conducted on-site by experienced auditors who assess the performance of suppliers in each of the four sections. During the audit, auditors review documents, interview staff, conduct physical inspections, and observe work practices to provide a comprehensive view of supplier operations. After the audit is complete, Sedex will provide a report that summarizes the findings and recommendations for improvement.

Who can conduct Smeta audit?

A SMETA audit will be conducted by an independent third-party auditor. The auditor will analyze the company’s management systems and practices, to ensure that they adhere to the ETI Base Code and local laws. The auditors will review internal policies, management processes, employee training records, and other documents related to labor rights and standards.

In addition, the auditor will observe activities in the workplace such as working hours, working conditions, fire safety regulations, payment of wages, etc., in order to identify any areas of potential non-compliance with ethical trading standards.

After the audit is complete, a report is generated which includes an assessment of compliance with ETI Base Code requirements. Companies who have passed an independent third-party audit typically can demonstrate that their workforce is protected under international labor rights and standards. This provides a degree of assurance to customers and other stakeholders that the company is committed to ethical trading practices.

The audit process helps companies identify areas for improvement, as well as provides an opportunity to address any malpractices that may exist in their supply chain as well as the global supply chain. It also ensures that companies are held accountable for their labor and work standards, helping them build trust with stakeholders and create a positive public image for the business. Furthermore, the successful completion of a audit can open up new opportunities for companies looking to do business abroad by demonstrating compliance with international labor rights and standards.

Conclusion:

SMETA audits, developed by Sedex Global, have become one of the most widely accepted ethical audit methods in the world. It is a comprehensive auditing system that provides an internationally recognized standard for assessing working practices within your supply chain. SMETA is based on four pillars: labor standards (including human rights), health and safety, environment, and business ethics.

The aim of this audit is to ensure compliance with any applicable laws and regulations as well as industry-accepted best practice standards including those related to CSR performance and sustainability initiatives. The audit helps you identify any potential risks or areas where improvement can be made in order to meet these standards and stay compliant with laws or regulations.

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Workplace Safety Audit Guides

Workplace Safety Audit Guides

Work Site Safety Audits

A Work Site Safety Audit is an important part of any workplace. It helps to identify potential hazards and risks, and ensures that all safety protocols are being followed. The audit includes a comprehensive review of the environment, as well as any equipment or materials used in the area. It can also include interviews with employees and other stakeholders to assess their understanding of safety policies and procedures.

Safety Audits vs. Safety Inspections: What’s the Difference?

Safety audits and safety inspections serve different purposes. Safety audits are more comprehensive and review the overall safety program of an organization, while safety inspections focus on specific worksites or processes.

Audits evaluate compliance across multiple areas such as employee training, equipment maintenance, hazardous materials management, accident investigation/reporting procedures, emergency response plans, etc., whereas inspections are conducted to ensure that existing regulations and requirements are being met in a particular area (e.g. confined space entry, machine guarding).

Safety audits provide organizations with valuable feedback on their current safety practices and allow them to identify any potential risks before they become significant issues. Inspections can help find violations quickly and lead to corrective actions when needed. Both types of assessments are important components of an effective safety management system.

3 Types of Safety Audits

There are three primary types of safety audits: administrative, environmental, and personal protective equipment (PPE). Administrative audits assess compliance with safety policies and procedures; environmental audits evaluate the physical environment for conditions that may pose a risk to personnel; and PPE audits review the effectiveness of an organization’s PPE program in providing adequate protection for workers.

All three types of safety audit provide valuable insight into the overall safety performance of a company, helping to ensure that it is meeting its commitment to providing safe working conditions.

How to conduct a safety audit?

Conducting a safety audit is an important step in improving the safety of any workplace. It allows organizations to assess their current protocols and identify areas for improvement. When conducting a safety audit, it is important to consider all potential hazards and develop safety regulations and safety procedures to eliminate or control hazards.

This can include everything from evaluating how equipment is used and maintained, to reviewing employee training programs and procedures. Additionally, health and safety audit companies should pay attention to the environment around the facility, ensuring that employees are working in safe conditions with reasonable access to emergency exits.

After identification of risk areas, action plans should be developed and implemented in order to make sure that all necessary steps have been taken in order to provide a safe working environment for everyone involved. Finally, employers should regularly review their safety audit report and audit data and make adjustments to ensure that the workplace remains safe for all workers.

By doing this, businesses can prevent major accidents from occurring and create a safer work environment for everyone. Through consistent safety audits, organizations can be sure that they are taking every measure to ensure the wellbeing of their employees.

The Steps of a Successful Safety Audit

A safety audit is an important part of any successful workplace safety program. It helps to identify risks and implement controls that protect workers and facilitate compliance with relevant legislation.

The steps involved in a successful audit include planning the review process, conducting interviews, collecting data, analyzing results, revising policies and procedures as needed, and finally reporting findings to key stakeholders. To ensure optimal results, it’s important to consult experts who have knowledge of applicable regulations and industry best practices.

With audit findings, workplaces can create safer environments for all personnel. Doing so will go a long way towards preventing accidents or injuries from occurring. Ultimately this leads to increased productivity and improved morale among employees.

The benefits of conducting regular audits are clear and there are many resources available to help employers ensure their workplace safety programs meet or exceed standards. With the right approach, any organization can benefit from a successful safety audit process.

By taking the steps necessary to conduct an effective safety audit, companies can have peace of mind that they are putting their employees first while complying with relevant laws and regulations. Additionally, an audit helps organizations identify areas of potential improvement in order to strengthen existing policies and procedures and create a more secure environment for workers.

This is essential to creating a culture of safety within any organization. Conducting regular audits helps ensure safe working conditions and ultimately better outcomes for everyone involved.

Prepare for the Audit

It is important to thoroughly prepare for an audit, as it will help ensure that the process runs smoothly. Start by gathering all relevant documents and financial statements in one place. It is also beneficial to have a checklist of items that need to be addressed during the audit.

Additionally, make sure you are aware of any applicable laws and regulations related to your industry and business operations.

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What are the Benefits of Performing a Safety Audit?

Performing a safety audit is an essential part of any workplace safety program. Regularly performing safety audits helps to identify potential risks, ensure compliance with industry standards and regulations, minimize accidents and injuries, and keep workers safe. Safety audits also help to reduce costs associated with legal fees, insurance premiums, medical expenses, lost time due to injuries or illness, and other related costs.

In addition to this financial benefit, regular safety audits can increase employee morale by demonstrating the commitment of management towards workplace safety. Overall, the benefits of performing a safety audit are clear – improved worker health and reduced potential liability for employers.

How frequently should safety audits be conducted?

When it comes to safety audits, the frequency of their execution can vary depending on a variety of factors. Generally speaking, these audits should be conducted at least once a year. However, this timeframe may need to be adjusted depending on the industry, environment and context of the business in question.

What Are the Best Practices in Conducting Safety Audits?

Safety audits are essential for any work environment, and there are best practices that should be followed when conducting them. First, safety audits should be conducted regularly to ensure all areas of the workplace are up-to-date on safety standards.

It’s also important to involve personnel who can provide a fresh perspective and spot potential hazards. Additionally, auditors should document their observations as they conduct the audit, which allows for an objective assessment of safety practices.

Finally, it’s important to take any corrective actions needed following the audit in order to ensure a safe and healthy work environment. Following these best practices can help create an effective safety audit that ensures all areas of the workplace are up-to-date on standards and that potential hazards are identified and addressed quickly.

What is a Compliance audit?

A Compliance audit is a systematic review of an organization’s policies, procedures, and operations to ensure that they are in alignment with legal and regulatory requirements. It is a comprehensive evaluation of the effectiveness of internal controls across all areas of the business.

The main goal of this audit is to identify potential risks or weaknesses in the processes so that corrective action can be taken accordingly.

Use Competent and Objective Auditors

Competent and objective auditors play an essential role in ensuring the accuracy of financial documents. Auditors are responsible for evaluating the accuracy of financial records, assessing internal controls, analyzing transactions to detect errors, and providing assurance that the financial statements present a fair view of the company’s performance.

They must have expertise in accounting principles and be able to assess potential risks with objectivity. Auditors must also be able to clearly communicate their findings and recommendations in a way that is understandable to management.

An effective auditor will use a range of different techniques, such as reviewing documents, interviewing staff, using electronic data analytics tools and performing testing procedures, to ensure accuracy and completeness of the financial records.

What Are the Key Elements of a Safety Audit?

A safety audit is an essential tool for any organization that wants to ensure the health and safety of its employees. The key elements of a safety audit are identifying potential hazards, assessing the risk associated with these hazards and determining how best to reduce or eliminate them. To do this, workers must be trained in hazard identification, risk assessment methods, and prevention techniques to control risks.

Additionally, policies and procedures must be created and enforced to reduce the chance of harm or injury occurring in the workplace. Finally, safety audits should include regular follow-up reviews to ensure that any changes have been effective in improving safety. By using a comprehensive approach to safety management through a safety audit, organizations can help protect their staff from potential hazards and prevent accidents from occurring.

What is the difference between an auditor and assessor?

The main difference between an auditor and an assessor is the purpose of their respective roles. An auditor is responsible for verifying that financial information or systems are accurate and in compliance with laws, regulations, and standards.

An assessor’s role is to measure or evaluate a system, process, project, or organization against a set of criteria. Additionally, auditors are usually outside third-party professionals, while assessors can be internal staff employed by the organization they are evaluating. Ultimately, an auditor is interested in determining the truth of a situation, while an assessor is focused on understanding how well it meets standards or criteria.

Both roles play a valuable role in ensuring that financial and operational information is accurate and meeting legal requirements.

Does OSHA require safety audits?

Yes, OSHA does require safety audits for employers to ensure that their workplaces are safe and in compliance with the Occupational Safety and Health Act (OSHA). By conducting regular safety audits, employers can identify potential hazards and take measures to reduce them.

This helps protect employees’ physical health by reducing the risk of workplace injuries, as well as their mental health by creating a positive working environment. OSHA safety audits allow employers to identify potential hazards and make sure that their workplace is in compliance with the OSHA standards, thus protecting both employees’ physical and mental well-being. Additionally, regular safety audits can help employers save on costs by reducing liability in case of an accident or injury.

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What Is Compliance Reporting & Why Is It Important?

What Is Compliance Reporting & Why Is It Important?

What is a Compliance Report?

A Compliance Report is a document that details the adherence to laws and regulations in a particular organization or industry. It outlines the measures taken by an entity to ensure that it is in compliance with all applicable rules and regulations. It can include information on audits performed, corrective action taken when violations are found, and the overall effectiveness of an entity’s compliance program. The report can be used by internal stakeholders to assess the company’s level of compliance, as well as by external stakeholders to ensure that the company is meeting all requirements. In the entire compliance process, compliance Reports are essential for any business or industry seeking to protect itself from liability and ensure its operations are compliant with industry best practices.

Regulatory Compliance Reporting vs. Internal Compliance Reporting

Regulatory compliance reporting and internal compliance reporting are both important parts of a business’s operations. Regulatory compliance reporting is the process by which organizations report data to various government agencies and other third parties, while internal compliance reporting is used to track an organization’s own policies and procedures. Regulatory compliance reports are required for certain industries, such as banking, healthcare, and finance, and must adhere to certain government regulations. Internal compliance reports are used within an organization in order to track it’s own internal procedures and ensure that they are being followed.

Both types of reporting can help a business stay organized and on top of their compliance obligations. However, it is important to remember that regulatory compliance reports must always be up-to-date and accurate in order to avoid potential fines or other legal repercussions. Internal compliance reports, while important, are not subject to the same regulations and can be used as a way to ensure that an organization’s policies are being properly followed. A thorough compliance report is important to a successful business, and understanding the differences between them is essential.

Why Compliance Reporting Is Important:

Compliance reporting is an essential part of any modern business. It ensures that organizations are abiding by the laws and regulations in place to protect consumers, workers, investors, and the environment. Compliance reporting allows companies to demonstrate their commitment to safety and sustainability, while also giving them a competitive edge in the marketplace. Additionally, it helps organizations identify potential risks before they become significant issues.

Compliance reports also provide stakeholders with a clear understanding of the company’s operations and performance and can be used to determine whether further action is necessary. Ultimately, compliance reporting helps organizations stay in line with government regulations while ensuring that their reporting practices are ethical and responsible.

What are the different types of compliance reports?

Compliance reports made by a compliance officer are documents that organizations use to document their adherence to regulations and laws. They provide insight into the procedures and processes in place to ensure legal compliance. There are many different types of compliance reports, including financial statement audits, environmental health and safety (EHS) audits, information security assessments, privacy impact assessments, and more.

Depending on the industry or type of organization, there may be additional types of compliance reports that are reviewed and issued. Companies with a well-documented compliance program should make sure that all types of compliance reports are up-to-date and accurate. By doing so, they can minimize the risk of non-compliance and any potential legal penalties.

What industries are often subject to compliance reporting?

Compliance reporting is a requirement for many industries, including but not limited to financial services, healthcare, and government agencies. Financial service providers are typically subject to compliance regulations related to banking and investing practices, while healthcare organizations must adhere to strict laws surrounding patient privacy and security. Government entities have their own set of rules that need to be followed in order to comply with local or federal laws.

All of these industries must adhere to certain standards in order to remain compliant with the law and protect consumer interests. Compliance reporting is also important for companies that handle sensitive data, such as customer information or confidential employee records. By adhering to compliance regulations, businesses can ensure their data is properly protected and not used for any malicious purposes. Additionally, it helps them remain transparent and accountable when it comes to how they use customer information. Compliance reporting is an important part of making sure businesses are operating fairly and ethically.

Benefits of Effective Compliance Reporting

Effective compliance reporting offers many benefits to businesses and organizations. Compliance reporting helps companies stay abreast of regulations in their industry and keep up with the constantly changing legal landscape. Having effectual compliance reporting also ensures that organizations are in line with local, state, and federal laws. It also allows for greater transparency, better communication between management and employees, and improved risk management.

With compliance reporting, businesses are better able to identify areas of risk and then take action accordingly. Additionally, effectual compliance reporting and compliance initiatives can help protect an organization from legal liability and minimize the risk of costly fines or penalties. By taking the time to develop a comprehensive compliance program, organizations benefit from increased efficiency, improved customer satisfaction, and higher employee morale.

What should a compliance report include?

A compliance report should include a summary of the organization’s activities to ensure it meets legal obligations, regulatory requirements, and contractual obligations. It should identify any current or potential gaps in compliance and provide recommendations to mitigate risks. The report should also highlight any changes that may have occurred since the last reporting period that could affect compliance. Additionally, the report should assess the effectiveness of existing processes and procedures and recommend actions to improve them, as well as describe any corrective actions taken in response to non-compliances.

General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) is an important piece of European Union legislation that sets out strict data protection rules for businesses. It provides a framework for individuals to have control over their personal data, and gives them the right to access, delete, or amend this information at any time. The GDPR also requires organizations to inform people about how their information will be used, how long it will be used and who it may be shared with. Furthermore, it imposes strict rules on organizations to ensure that they protect the data of their customers. With these measures in place, organizations can build greater trust in their services by demonstrating a commitment to respecting people’s privacy.

How to develop a robust compliance reporting process?

The development of a robust reporting process is essential for any organization that needs to comply with the law and adhere to internal policies. Such a process should include the regular review of existing compliance procedures, training on those procedures, adequate communication channels, and periodic audits or assessments. Additionally, organizations need to ensure they have sufficient resources in place to monitor all aspects of their compliance processes and report any non-compliance.

This should include a system of tracking changes in regulations or other requirements that could affect compliance, as well as procedures for reporting instances of non-compliance to the appropriate authorities. Finally, organizations or your chief compliance officer must invest in continual learning and development of their staff to ensure they are up-to-date on the latest compliance regulations and can effectively communicate them within the organization.

What are 3 financial reporting risks?

Financial reporting risks refer to the uncertainty that investors and creditors may face when trying to assess the performance of an entity. The risk of inaccurate reporting can arise from a variety of sources, including accounting errors, fraud, misstatements or omissions in documents and financial statements, inadequate internal control mechanisms, or incorrect assessment of market conditions. The three main financial reporting risks are 1) accuracy risk, 2) materiality risk, and 3) fraud risk.

Accuracy risk pertains to the possibility of accounting errors or incorrect statements made in financial documents. Materiality risk involves the potential for disclosures not being properly defined or presented in a meaningful way by management that could lead to an inaccurate assessment. Lastly, fraud risk is associated with intentional misstatements or omissions which are made to mislead investors or creditors. It is important to understand these financial reporting risks in order to make the right investment decisions and ensure a successful understanding of an entity’s performance.

What is misleading reporting?

Misleading compliance reporting is a practice where organizations act as if they are following applicable laws and regulations, but do not actually meet the required standards. Compliance reports aim to assess whether an organization has taken measures to ensure that it is adhering to pertinent legal rules and regulations. Unfortunately, there are cases in which these reports can be inaccurate or even deliberately misleading about the level of compliance achieved by the organization. In these cases, organizations may be falsely representing their compliance efforts to stakeholders, regulators, and other interested parties.

Misleading reporting can have serious repercussions, including legal ramifications and financial losses due to failure to meet standards or false representation. It is important for companies to ensure that all compliance-related information is accurate and up-to-date, to avoid any such issues. Failure to do so can result in significant penalties and other sanctions. Therefore, organizations must take measures to ensure that all compliance-related information is accurate and up-to-date in order to maintain an accurate record of their compliance efforts.

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Waste Disposal Facility Audit Checklist

Waste Disposal Facility Audit Checklist

What is a waste audit?

There are two types of audits: manual and automated.

A waste audit can be conducted in a variety of ways, depending on the organization and its goals. Generally, there are two types of audits: manual and automated. Manual waste audits involve sorting through garbage bags or dumpsters to determine what is being thrown away. Automated audits use sensors or other technology to track the types and quantities of waste that an organization produces.

The resulting data from waste audits can be used to develop a better understanding of the organization’s waste stream and how it can be improved. The data can also help organizations make informed decisions about their purchasing practices, lead to more efficient processes and identify cost-saving opportunities.

How do you plan a waste audit in an organization?

A waste audit is an analysis of a company’s waste stream where you inspect waste management and then implement waste management protocols. It gives insight into the types and amounts of materials that are being sent to landfill and helps inform strategies to reduce, reuse, and recycle more effectively.

What are the steps involved in a waste audit?

To plan a successful waste audit in an organization, there are several steps that should be added to your waste audit checklist:

1. Select your team and plan a date for the waste audit.
2. Gather your equipment.
3. Go through the garbage!
4. Calculate your diversion rate.
5. Communicate your results.

What is included in a waste audit?

Waste audits are useful for many reasons. They can provide facility managers and other stakeholders with important insights into the effectiveness of their current waste management practices and how they might be improved.

Waste audits can also help identify areas where more resources should be devoted to better manage waste, or where additional training or education is needed. By understanding the composition and volume of the waste generated, organizations can better understand how to reduce, reuse and recycle more efficiently and effectively.

Additionally, detailed audits can provide information about potential safety and health hazards within a facility’s regular waste stream.

What are the 7 principles of solid waste management?

The following are the seven principles that will effectively explain solid waste management:

  • Rethink
  • Refuse
  • Reduce
  • Reuse & recycle
  • Repurpose
  • Repair
  • Compost
  • Conclusion

Solid Waste Management is an important tool to reducing our environmental impact. By adding the 7 principles to the solid waste management checklist, we can begin to make a positive difference in the amount of waste generated and disposed of into the environment.

Rethinking how we purchase and use products, refusing those items that are not necessary, reducing the total amount of waste going into the environment, reusing and recycling items that can be either repurposed or repaired, and composting rather than throwing organic waste away are all effective methods of reducing our environmental impact without creating more waste.

By making small changes in our everyday lives, we can have a large impact on the amount of waste going into the environment. The way households and company disposes of waste will significantly aid in the improvement of the communities we live in as well as limit unnecessary waste in landfills.

What are the four criteria that the EPA uses to classify hazardous waste?

EPA’s (Environmental Protection Agency) regulations in the Code of Federal Regulations (40 CFR) identify four hazardous waste characteristic properties: ignitability, corrosivity, reactivity, or toxicity (see 40 CFR 261.21- 261.24).

As part of EPA compliance, company key members, facilities teams, and site management should identify, collect, and document all hazardous waste that is in their facility. Regular site visits and inspections helps determine is the hazardous waste management protocols are properly enforced and in good condition.

Steps following an waste disposal facility audit:

1. Determine whether the waste containers size and pickup frequency still match your needs. If your trash output changed, a different size or number of pickups could cost you less money.
2. Add recycling service to your plan. If you don’t have recycling bins as part of your waste removal plan, consider add it.
3. Set a goal for increasing your recycled waste rate.
4. Create recycling guidelines for meeting that goal and share them with your staff.
5. Set a goal for reducing the amount of waste in your largest categories.
6. Determine the steps to meet that goal and let your staff know. Implementation is key.
7. Identify any items you can reuse. For example, can you repair or recycle your electronics instead of purchasing new ones? Can you repurpose any of your packaging materials?
8. Decide on a timeline for meeting your recycling and reduction goals. One or two years usually makes sense. Plan to conduct another waste audit at that time to see if you met your goals.

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