Safety Boots: What You Need To Know

Safety Boots: What You Need To Know

Oct 20, 2023

Many types of jobs require the use of boots for safety purposes.  Some jobs just need regular boots while others require steel or composite toes.

Toe Composition

Steel toe boots have a steel cap over the toe to prevent your feet from being crushed by objects falling on them or rolling over them.  Composite toe boots can have toes made of Kevlar, carbon fiber, fiberglass or carbon nanocomposites (composite cylinders arranged in beehive pattern mixed with fiber resin).  Composite toes don’t conduct heat, cold, nor electricity, and are thicker but lighter weight than a steel toed boot.  They are not as impact-resistant. There are also alloy toe boots such as aluminum or titanium.  These are a little less protective but lighter weight than steel toe boots.  They can be a little more expensive as well.

Best Practices

  • Always buy boots that meet ASTM standards for impact and compression and always buy the types of boots your company recommends or requires. Your company has conducted formal PPE assessments to determine the safest types of boots for the work you do.
  • Always wear the proper socks. Moisture wicking socks are better than cotton socks because cotton socks will tend to create moisture  leading to uncomfortableness, foot pain and faster damage to the inside of your boots.
  • Keep the insides of your boots dry and maintain the waterproofing on the outsides of them.
  • Remove mud, dirt, clay, and gunk—they’ll dry out the leather.
  • You can increase the life span of your boots by using premade orthotic insoles.

Checking the Wear

Worn out boots not only are uncomfortable, but they are unsafe.  Not replacing them when they’re worn out can cause foot/back/leg pain, foot stress and ingrown toenails and can increase your chances of falling, especially in slippery environments. Check for wear by looking at:

  • Soles, outsides of the heels, and balls of the shoe for wear. Are soles separating?  Sole separation can cause instability, reduce shock absorption and let moisture or chemicals in.
  • Tears, holes, cracks and external damage—Damage like this can make them less electrical and chemical resistant and more susceptible to foot punctures
  • Internal damage-Look at the inside, the tongue and look for the stitching. Torn insulation can let in moisture and chemicals. The instep shouldn’t be bunching up.

Finding and Trying on Boots

  • Wear the socks you’ll be wearing with the boots when you try them on
  • Your heel shouldn’t come up out of the boot or rub on the back. It shouldn’t move more than a quarter of an inch. As leather conforms to your foot, it will mold to your heel and slight slippage will reduce.
  • You should have an inch of room in your toes but your toes shouldn’t slide forward when you walk.
  • The boot should be secure on the sides and top of your foot but not be painful.
  • Make sure the inner stitching nor the tongue rub on your foot.
  • When trying them on put them through their paces because you want to make sure they’re right for you: walk, run, hop, do knee raises, stand in place, flex your foot, and carefully roll your ankles and stand on the sides of your foot to test ankle support. If you have red spots on your feet after trying them on, those are the places where the shoe will rub.
  • Always try on boots on both of your feet. Your feet change sizes throughout the day, so try boots on in the afternoon when your feet tend to be bigger.
  • If your feet are two different sizes, purchase the boot to fit your larger foot and wear a heel insert for your smaller foot.
  • If you have flat feet, taller boots with stronger insoles may fit better.
  • Boot companies traditionally have you order 1/2 size smaller than your sneaker size. For steel toe boots, you may need to order the same size as your sneaker size, or even a 1/2 size larger than your normal shoe size. If you wear thick socks, the larger boot sizes will be needed to accommodate those.

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The One Where You Must Post the Whole Standard

The One Where You Must Post the Whole Standard

Oct 13, 2023

iSi’s consulting team recently provided a presentation to the annual Kansas Safety and Health Conference about OSHA’s top poorly written regulations.  We gave the audience a chance to vote at the end and one of the top vote getters was found in standard 1910.95.  This is the occupational noise exposure standard.  More specifically, 1910.95(l)(1).

A Unique Requirement

The noise exposure standard aims to protect workers against the effects of noise exposure when sound levels exceed a certain scale pictured in the standard.  This is also where instructions on the rules for and how to develop a Hearing Conservation Program can be found.  Section K of the standard discusses the importance of training, what topics need to be covered, and the requirement that the training be repeated annually.

In the next section we find something very unique.  Section L covers access to information and training materials.  The very first requirement states “The employer shall make available to affected employees or their representatives copies of this standard and shall also post a copy in the workplace.”  What??  A copy of the standard?  Post a copy of the entire standard?

Yes, it means what it says.  This is the only standard OSHA has that requires you to take a copy of the standard and post it.  OSHA feels it’s important that in addition to training, employees have the chance to read the standard on their own without having to ask for it.  It must be centrally posted and at no charge.

Updates to the Rule

This rule was written in 1983 and has not been updated since then.  OSHA held firm on its stance in an interpretation letter written in 1988 from someone questioning posting the whole thing, but in 2016 OSHA decided to become a little more user friendly.  In 2016 someone sent OSHA a letter requesting electronic posting.  OSHA’s answer said they realized the internet was not around in the 80s, and thus, declared that with this letter, they were updating the policy to allow for electronic posting, but only under these certain conditions:

  • Your Hearing Conservation training program covers specific information to your employees on where and how to access the entire standard electronically;
  • The link you provide to employees does not go to a generic web page such as to your company’s website, a folder on your intranet or Sharepoint, or the home page for OSHA. It must go to the exact standard located here; and,
  • Computers must be located in all affected employees’ work areas so that they can have access to the standard at any time without having to request access to a computer or without having to ask for assistance on where to find it electronically.

Citations

It may be low risk that you’ll get fined for just this item unless the inspector has a special place in their heart for this standard.  However, it IS likely that it becomes an easy tack-on citation along with other citations of the noise exposure standard.

For example, in the state of Tennessee, this item is one of the most often items cited for this standard, but so are:

  • Lack of training or lack of training program;
  • Did not administer a continuing hearing conservation program when workplace noise levels indicated it was required;
  • Lack of a monitoring program when information indicated the exposure levels may equal or exceed the limits;
  • No audiometric testing program or audiometric testing;
  • Did not establish a baseline audiogram within 6 months of an employee’s first exposure at or above the action level; and
  • Not giving employees the opportunity to select their hearing protectors from a variety of suitable hearing protectors provided by the employer.

Where Do You Stand on Noise?

When was the last time you had your workplace AND your workers tested for noise exposure?  iSi conducts noise sampling, helps write programs, provides training and much more assistance for noise exposure issues.  Contact us today!

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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?

Sep 22, 2023

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

Aug 18, 2023

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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Does this new change pertain to your company? Our team can help you figure it out and can help with other air compliance issues.

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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

Jul 28, 2023

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

Jul 21, 2023

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.

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iSi Summer Toolbox Topics: Fireworks Safety

iSi Summer Toolbox Topics: Fireworks Safety

Jun 29, 2023

isi fireworks safety
Download Article in Shareable Safety Sheet

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! 

 

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OSHA’s Heat-Related Hazards National Emphasis Program

OSHA’s Heat-Related Hazards National Emphasis Program

Jun 16, 2023

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?

May 19, 2023

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

Apr 21, 2023

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

Mar 31, 2023

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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What Will Inspectors Look for in Combustible Dust Inspections?

What Will Inspectors Look for in Combustible Dust Inspections?

Mar 17, 2023

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

Mar 10, 2023

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?

Mar 3, 2023

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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OSHA Injury Posting Requirements

OSHA Injury Posting Requirements

Jan 30, 2023

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

Dec 15, 2022

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

Dec 1, 2022

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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OSHA Considering Changes and Updates to the PSM Standard

OSHA Considering Changes and Updates to the PSM Standard

Nov 17, 2022

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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Hazmat Employee Training Requirements Every Employer Must Know

Hazmat Employee Training Requirements Every Employer Must Know

Oct 22, 2022

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What does HAZMAT stand for?

Hazmat stands for HAZardous MATerials, and is a term commonly used to refer to materials that could be dangerous to people, the environment or property. These types of materials may include explosives, flammable liquids, radioactive substances and infectious agents.

It is important for individuals who handle, dispose, and transport hazardous materials to have the proper training and certifications in order to ensure the safety of themselves, others and the environment. Hazmat personnel must also be aware of any applicable laws regarding the transportation and handling of haz materials in order to stay compliant with regulations.

The term is used across multiple industries, including healthcare, construction, manufacturing and mining. The HAZMAT designation can help save lives and reduce potential damage from hazardous materials.

What defines a hazmat employee?

A hazmat employee is any person who is responsible for the transport, storage, and handling of hazardous materials in accordance with all applicable laws and regulations. Hazmat employees must be trained to recognize and respond to hazards posed by hazardous materials they may encounter on the job.

They must also possess knowledge about safe practices related to identification, packaging, labeling, documentation, shipping papers, and emergency response. In order to ensure safety, hazmat employees must pass tests regarding hazardous materials regulations and complete refresher courses on a regular basis.

Furthermore, they are expected to follow all applicable laws and regulations to the letter in order to protect public health and the environment. By having an accurate understanding of what it takes to be a responsible hazmat employee, businesses can ensure that their operations remain safe and in compliance.

Hazmat Training Requirements:

Hazmat training is an important part of safety and awareness for anyone who works with potentially hazardous materials or substances. The US Department of Transportation (DOT) requires that all hazmat personnel receive specialized hazardous materials transportation safety training before they are allowed to handle such materials, as well as periodic retraining every three years.

This includes general awareness/familiarization training, transporting hazardous material training, in depth security training, safety training, function-specific training, security training and in-depth safety training. All employees with hazardous materials responsibilities must have the necessary knowledge and skills to safely handle these materials and be knowledgeable about the applicable regulations.

Hazardous Materials Handler certification is also required for any personnel involved in packaging, labeling, marking or loading of hazardous material shipments.

What are the required categories of hazmat employee training?

The four required categories of hazardous materials employee training include: General Awareness/Familiarization, Function-Specific Training, Safety Training and Security Awareness. All employees who handle hazmat must understand basic safety rules and procedures related to the hazardous materials they handle, as well as emergency response protocols that could arise should an incident occur.

Additionally, personnel involved in loading and unloading operations must understand applicable regulations to ensure safe, secure and compliant operations. Function-specific training is also mandatory for employees who perform activities related to the identification, packaging, labeling, marking, handling, storage and transportation of hazardous materials.

How often do hazmat employees need to be trained?

Hazmat employees are required to complete initial training within 90 days of hire and annually thereafter. Initial training must include topics such as hazard recognition, basic containment principles, emergency response, proper handling and storage of haz materials, and personal protection equipment.

Hazmat employees should also receive additional training whenever there is a change in job duties or when they are exposed to new hazards.

Hazmat Employee Training (49 CFR 172.704)

Hazmat employee training (49 CFR 172.704) is an important part of the hazardous materials transportation regulations mandated by the U.S. Department of Transportation.

Hazmat training must be completed by all employees involved in transporting dangerous goods and hazardous materials, including those who prepare shipments, load/unload, package, mark/label containers or placards, provide emergency response information, and perform any related duties.

Training must include instruction in the applicable regulations, safety precautions, emergency response procedures, how to recognize and respond to haz materials incidents, and other related topics as necessary. Hazardous materials employee training must be provided before initial job assignment and at least once every three years thereafter.

Employers are responsible for ensuring that hazmat employees remain qualified and are knowledgeable about the haz materials they handle. Hazmat employee training is an important factor in ensuring the safe transportation of hazardous materials and preventing accidents related to their transportation.

Is proof of training required?

When it comes to the question of whether proof of training is required for Hazmat Employees, the answer depends on the severity and potential hazards associated with the job. Generally, employers must provide proof that their employees are knowledgeable about hazardous materials regulations and understand how to safely handle haz materials before they can be allowed access to any facilities where hazardous materials may be stored or used.

This proof can take the form of certificate programs, refresher courses, or a written test. Additionally, employers may need to show that their employees have participated in emergency response drills and are knowledgeable about proper procedures for responding to spills and other haz materials incidents. In some cases, additional safety protocols such as wearing personal protective equipment and maintaining adequate ventilation may also be required.

Security Awareness Training (49 CFR 172.704(a)(4))

Security Awareness Training is an important part of any organization’s security plan. As mandated by the Transportation Security Administration (TSA), 49 CFR 172.704(a)(4) requires all personnel who work in regulated environments to complete appropriate training prior to performing their duties.

This training helps ensure that employees are aware of their roles and responsibilities when it comes to safeguarding sensitive information. Additionally, security awareness training helps to ensure that personnel are familiar with the threats and vulnerabilities associated with their role, as well as how to appropriately respond in the event of a breach or other security incident.

This type of safety training is an essential element of any organization’s overall security strategy and should not be overlooked.

The Importance of Hazardous Materials Training

Hazardous materials training is incredibly important for workers who are exposed to hazardous substances. It helps to ensure that they have the right knowledge and understanding of safe and proper methods of handling, transporting, storing, and disposing of such potentially dangerous materials.

Hazardous material trainings can also help prevent accidents or other incidents involving haz materials from occurring by equipping workers with the skills to identify hazardous materials, assess the risks associated with them, and take appropriate steps to mitigate those risks.

Ultimately, hazardous material training is essential for protecting workers and the environment by providing a good understanding of the potential dangers that could be encountered while working with these substances.

It is also important for employers to provide regular hazmaterials trainings in order to stay up-to-date with the latest regulations and safety protocols concerning hazardous materials. By doing so, employers can ensure that their workers are properly informed about how to handle these materials correctly and safely.

Need Help?

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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Fit Testing Questions Answered

Fit Testing Questions Answered

Sep 23, 2022

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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Lithium Batteries: Safety Hazards and Their Impact on Businesses

Lithium Batteries: Safety Hazards and Their Impact on Businesses

Aug 12, 2022

More lithium and lithium-ion batteries are being used in products today and just like any material, if we understand how to use it safely, it should not pose any problem. (Note: Lithium batteries are single-use batteries and lithium-ion batteries are the rechargeable kind.)

Lithium-containing batteries, when damaged. defective or used improperly, can present a fire and/or an explosion hazard.  Small items such as a laptop can typically have 6 lithium cells in them, while an electric vehicle can use 7,000 lithium-ion cells. This change in size greatly increases the risk and effects of a fire. If an electric vehicle catches on fire in your garage, you most likely do not have a way to deal with a 3,632° F fire.

Should I Really Worry About My Battery Catching on Fire?

If your battery stays intact, and does not allow moisture to get inside, or as long as there is not an issue with overcharging where the temperature runs away, you should be fine. The issue is that lithium and water don’t like each other. In fact, in its pure form, water causes lithium to react, sometimes violently, creating sparks and lots of heat, as well as hydrogen gas.

Lithium-ion batteries are a little different than the pure form of lithium in that they are filled with a lithium compound, and not pure lithium. Because of this, the material in many batteries are not quite as active with water. But when you have 7,000 cells in one place, if one catches on fire, a chain reaction can occur that you cannot control. Also fighting that fire with water may not be the best solution when water can cause it to react more.

This can be the same for industry. Lithium-ion batteries are being used in everything from pumps and instruments, to cars and equipment, hand tools, computer servers, and so many more products. Even your wireless mouse may have lithium-ion batteries.

If you just throw that away in the trash, not only are you potentially violating waste regulations and DOT shipping regulations, you may also be creating a fire hazard for the waste removal truck the landfill that it goes to.

DOT Issues Advisory Warning for Lithium-Containing Batteries

Recently DOT has found the issue with shipping lithium-containing batteries for recycle or waste has gotten out of hand. The Pipeline Hazardous Materials and Safety Administration (PHMSA), which is the HazMat division of the DOT, has issued a safety advisory on the dangers to help people out. The advisory warns that shippers and carriers need to take extra (and sometimes different) precautions when shipping damaged, defective or recalled lithium-containing batteries.

During recent compliance inspections, DOT inspectors have been finding improperly packaged and shipped lithium-containing batteries for disposal or recycling.  Some examples include:

  • Not packaging to prevent short circuiting
  • Mixing damaged batteries with others in the same packaging for recycling/disposal
  • Shipping pallets of batteries in boxes and drums with inappropriate package identifications

From a hazardous waste perspective, EPA recommends that lithium batteries be managed under the Universal Waste regulations.

Battery Disposal Rules – for Consumers

Regular citizens should take used, damaged, defective or recalled lithium-containing batteries to recycling facilities geared for accepting them, or your local household hazardous waste collection point. Do NOT throw them away with your other garbage.  If there is an item that’s recalled that has the battery in it, follow the manufacturer’s safety instructions and disposal instructions. Pay attention to any warnings.

Find an authorized provider to ship any lithium-containing batteries because they are considered to be hazardous materials.  When the post office asks if you are shipping hazardous materials, lithium-containing batteries makes that answer yes.

Battery Shipping and Disposal Rules – for Businesses

If you are a business, there are a number of regulations you need to follow to properly deal with lithium-containing batteries.  First, they can only be shipped by ground methods, so that’s by truck, rail or vessel. Overnight shipments or any shipment that could potential go via air methods are out of the question.

There are also specific regulations and procedures you need to follow to properly package, label and ship them.  There are regulations about the type of box you send them in because those packages must have special permits for this role.   There are special labels and markings that need to go on the packages and special ways they need to be packaged. Workers who will be participating in any function of the process are required to have proper training specific to their role, and that training is required every 3 years.  Emergency response information must also be included in the package process.

Training and Consulting Resource

iSi conducts hazardous materials shipping for businesses as well as conducts training to properly ship hazardous materials via ground, air, and vessel.  If you are a business that has question about how to deal with your lithium-containing batteries or if your workers need training, contact us today!

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Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

As a former corporate environmental, health and safety manager, Ryan has a vast experience in working with both environmental and safety compliance issues in multiple states.  His specialties include national and international dangerous goods transportation, hazardous waste, environmental compliance, industrial hygiene and safety compliance. He is also an ISO 14001 Lead Auditor.

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iSi’s Top 12 General Industry Safety Audit Findings

iSi’s Top 12 General Industry Safety Audit Findings

Aug 11, 2022

Safety regulations are enforced by OSHA, and in some states such as California and Indiana, by a state safety agency. How do you make sure you have your bases covered? A safety audit can determine your current status and what your vulnerabilities are. iSi’s general industry safety audits are conducted like a mock OSHA inspection for the 29 CFR 1910 general industry regulations. There is a wall-to-wall walkthrough, a records review of written programs, training programs, and past inspections, and interviews with employees.

Some of the below cited items start in the OSHA regulations, but detailed actions are prescribed by other regulations such as the National Fire Protection Association (NFPA) or American National Standards Institute (ANSI) Standards. Others are based on items we see our clients cited for in OSHA inspections which we have added to our audits.

The following are our top 12 specific findings we see most when we do our general industry safety audit.

12. Safety Showers and Eyewash Stations

Facility safety showers and eyewash stations are not being inspected on a regular basis.  1910.151(c) discusses suitable facilities, but ANSI standard Z358.1-2014 specifies weekly visual inspections of both showers and eyewash stations.

11. Lifting Slings

We find that often there is no formal program in place to conduct a periodic inspection of all lifting slings. This must be conducted annually. 1910.184 includes guidance on the use of slings and item (d) covers inspections.

10.  Machines

At number 10 is fixed machines. We find fixed machines are not securely mounted to the floor or the bench top to prevent them from “walking.” 1910.212 is the standard for all machines and machine guarding. Item (b) covers the anchoring requirements.

9.  Personal Protective Equipment (PPE)

PPE evaluations and hazard assessments must be conducted for each task. We find that these are either not conducted or not documented. The potential for workplace hazards must first be assessed and if PPE is needed, PPE must be selected, communication decisions must be communicated to affected employees and PPE must be fitted to each employee.

A written certification must be created which identifies the workplace evaluated, the person certifying the evaluation, the date the assessment was conducted, and signification that the document is a certification of hazard assessment.

These rules are found in 1910.132(d).

8. Fire Extinguishers

Are your fire extinguishers mounted too high, not mounted at all or are they blocked from access? 1910.157(c) is the standard which covers this issue.

7.  Emergency Lighting

Emergency lighting, in many locations, is not being tested every 30 days for 30 seconds or for 1.5 hours annually. Lighting can be found in Subpart E, Means of Egress, Maintenance, Safeguards, and Operational Features for Exit Routes, 1910.37(a)(4) and the NFPA 101 Life Safety Code 7.9.3.1.

6.  Lamps

We find that lamps less than 8 feet from the floor are not protected from accidental contact. Lamps need to be guarded and protected from accidental contact. This can be found in 1910.305(a)(2)(ix). Although a particular height requirement is not specified in this regulation, you should consider the reach of your tallest employees and length of the parts and/or tools being used in the area.

5.  Forklifts 

We see many issues with forklifts. The most common issue we find with forklifts no documentation of daily inspections, or no inspections being conducted. However, more recently we have been seeing issues with employees not wearing seatbelts, controls where the labeling has worn off, the use of non-factory attachments, and not updating data plates, tags and decals with revised capacity, and operation and maintenance data. Forklift standards are found in 1910.178.

4.  Grinder Wheels 

Machine guarding issues are a common item we see. One of the most prevalent ones relates to grinder wheels. The gap between the grinder wheels and the work rest plate should not be more than the maximum allowed 1/8 inch. The adjustable tongue guards shouldn’t be more than the maximum allowed 1/4 inch from the tongue guard. These regulations can be found in Subpart O, Abrasive Wheel Machinery, 1910.215(a)(4) and (b)(9).

3.  Electrical Panels 

With electrical panels, we often see the minimum required areas of clear space around the panels is not being maintained. Sufficient access must be maintained for safe operation, access, and maintenance. The rules, including a distance chart to help you determine proper clearances can be found in Subpart S, 1910.303(g).

2.  Hazard Communication

Within the hazard communication (hazcom) standard, there are requirements for secondary containers. We find many secondary containers of hazardous chemicals are not labeled correctly or have illegible writing on them. The regulation comes under the “labeling” section of 1910.1200. All containers, either primary or secondary, need to be labeled and contain product identifier and words, pictures, symbols or a combination of them. Portable containers, that is, containers you transfer chemicals to and intend for immediate use are not covered by this requirement.

1.  Access to Medical Records

The number one item we find in our audits relates to access to medical records. Employees are required to receive information on their access to medical records. This is required initially upon hire, and then annually thereafter. The regulations can be found in 1910.120(g)(1). Included with this requirement is notifying employees the existence, location and availability of records covered by 1910.120, the person responsible for maintaining and providing access to records, and each employer’s rights to access those records. As an employer, you need to keep a copy of 1910.120 and its appendices and make copies readily available, upon request, to employees.

This information can be covered within your annual training classes, or can be a written notice of information in an email, or a memo that is posted with your OSHA logs and other OSHA-required notices. The important part is that you document that you completed this requirement and how.

Where Do You Go From Here?

iSi can help you get a baseline on your safety compliance status by conducting a walkthrough. From there, we will create a matrix of issues we see with the corresponding regulatory standard. We can also help you prioritize the ones which are most critical to be taken care of.

Request a quote for a general industry safety audit today! Need more information about these issues?  Contact us at (888) 264-7050 or email us!

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OSHA Safe + Sound Site Provides Free Resources for Your Safety Program

OSHA Safe + Sound Site Provides Free Resources for Your Safety Program

Aug 3, 2022

OSHA's ssafe+sound week logo

What is Safe + Sound Week?

OSHA has designated August 15-19, 2022 as Safe + Sound Week.  It’s held each August to recognize workplace safety and health programs and to create awareness for worker safety, and OSHA provides a wide variety of resources, social media tools and other information to help you celebrate.

The Safe + Sound effort is focused on encouraging workplaces to have a safety and health program.  It says that your program needs to have three main goals:  Worker Participation, Management Leadership and a process for Finding and Fixing Hazards.  OSHA provides a wide variety of resources on its Safe + Sound website for each one of these areas to help you reach this goal.  These tools are available all throughout the year.  The Safe + Sound Week is an opportunity to highlight the successes you have been able to accomplish, and at the very least, give you a way to promote safety to your company and to the public.

Below is a list of tools available both to help you bring awareness during Safe + Sound week, and to help you strengthen your program throughout the year.

Resources:  Safe + Sound Week

OSHA’s Safe + Sound Week website gives you a wide variety of resources to help plan, promote and celebrate Safe + Sound Week to your employees and to the public.

Some of these resources include:

  • Register your company nationally as a participant and see who else from your state is participating
  • Examples of workplace events and activities to have at your facility
  • Shareable logos and badges
  • Social media toolkits and photo and content frames
  • Safety and Health Matters to Me thought bubbles for employees to complete
  • Banners for Facebook, Twitter and LinkedIn
  • Virtual meeting (Zoom) backgrounds
  • Shareable images that can be used for posters, bulletin board posts, or inclusion in your safety newsletters

Resources:  Strengthening Your Program Throughout the Year

OSHA’s Safe + Sound campaign website offers a number of educational flyers and guidance documents to help you strengthen your program throughout the year.   Some of these include:

  • Free webinars
  • OSHA Safety and Health Program Recommended Practices manual
  • ASSP Guidance Manual:  Keep Your People Safe in Smaller Organizations
  • Guidance documents and ideas
  • Worker participation worksheets and Better Safety Conversations worksheet
  • Leadership worksheets and challenge activities
  • Management safety pledge
  • Find and fix hazard identification tools

Certificate of Completion 

If your company would like to participate in Safe + Sound Week, you can sign up at https://www.osha.gov/safeandsoundweek/.  Your company will be added to the list of participating companies for your state.  Afterwards, you can download a certificate and a virtual challenge coin to recognize your organization.

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Sustainability Software

Sustainability Software

Jul 16, 2022

Sustainability software is a powerful tool for businesses and organizations that are looking to become more sustainable and reduce their carbon footprint. This type of software collects data on energy usage, waste disposal, water consumption, and other environmental factors in order to measure the sustainability performance of an organization or business.

It can provide detailed reports showing which areas need improvement as well as suggest ways to reduce emissions and optimize resource use. By collecting this data, companies can set goals and reach them with greater accuracy and efficiency than ever before.

With sustainability programs, organizations have the power to make a real difference in the world around them while also saving money in the long run by reducing their energy costs. In short, it’s a win-win proposition for everyone involved.

Sustainability software is an important tool in the fight against climate change. By taking a more holistic view of sustainability, companies can make decisions that will benefit everyone – from individuals to corporations, and even entire nations.

The data provided by these solutions helps organizations and businesses understand where they stand with regards to their ESG goals and objectives, while also providing them with the tools they need to achieve their desired results. With the right software in place, organizations are well on their way towards making sustainable progress for years to come.

What is Sustainability Software?

Sustainability software is a type of technology that helps organizations reduce their environmental footprint. It provides tools and resources for companies to track, monitor, and improve the sustainability performance of their operations. By utilizing data-driven insights, businesses can make informed decisions about how to reduce waste, increase energy efficiency, and ultimately create a sustainable future.

Sustainability software also helps organizations stay in compliance with regulatory bodies by providing visibility into their current eco-friendly initiatives. With this kind of software available, it’s never been easier for businesses to make meaningful changes toward creating a more sustainable world.

10 sustainability management software providers to consider:

  1. IBM

  2. Metrio

  3. Microsoft

  4. FigBytes

  5. Ecometrica

  6. Benchmark Digital Partners

  7. Diligent ESG

  8. OneTrust

  9. Persefoni

  10. SAP

Sustainability and ESG Data & Reporting

Sustainability data and ESG (Environmental, Social, and Governance) data are an increasingly important part of corporate responsibility. Companies are now under pressure to demonstrate their commitment to upholding the highest standards of ethical conduct in all of their operations. As a result, sustainability reporting and ESG reporting have become key components of effective corporate governance.

Companies must be able to clearly articulate the steps they are taking to reduce their environmental impact, address issues related to employee welfare, or improve governance structures. By doing so, companies can help ensure that stakeholders have faith in their commitment to responsible business practices and set themselves up for long-term success, especially with ESG and sustainability reporting.

Not only does this type of reporting help ensure that a company is adhering to best practices but it also helps them stand out in the market and attract more customers. In today’s globalized economy, businesses must prioritize sustainability reporting and ESG reporting if they want to thrive in an ever-changing landscape. These should act as your company’s reporting solutions which will generate reports that drive data reliability and sustainability goals.

Key features in sustainability management software

Sustainability management software is designed to help businesses and organizations track, measure, and manage their sustainability efforts. The key features in this type of software include data collection capabilities, reporting metrics tools, visualization dashboards, risk analysis tools, and integration with other systems.

Data collection allows organizations to collate information from numerous sources including internal business operations, external environmental sources, and more. Reporting metrics provide insights into the organization’s sustainability performance and how it can be improved.

Visualization dashboards allow users to easily comprehend complex data in an interactive format. Risk analysis tools offer more sophisticated insights into potential risks associated with a business or organization.

Lastly, integration with other systems allows for seamless integration of various data sources and a unified view of sustainability performance. With all these features, organizations can better understand the impacts of their sustainability initiatives and how to improve them.

Benefits From Professional Sustainability Management Solutions

Leading sustainability software providers can help businesses achieve their environmental and social objectives, as well as reduce costs. These solutions provide businesses with tools to improve their efficiency and reduce energy consumption, thus reducing their carbon emissions and overall carbon footprint.

Additionally, by understanding the impacts of their operations and taking appropriate action, businesses are able to increase the value of their products or services more sustainably. Furthermore, sustainability management solutions can help businesses with their public relations, as they demonstrate a commitment to social responsibility.

With Metrio sustainability reporting software, you can easily collect, analyze, disclose, report and communicate your ESG data. Our software enables organizations to compare and save data in a centralized platform, enabling better decision-making and improved corporate sustainability performance.

Finally, by understanding the current and potential impacts of their operations, businesses can create positive relationships with stakeholders by implementing responsible strategies for long-term sustainability which ultimately empowers organizations.

Sustainability Progress – The Need is High, But Progress is Slow

Sustainability Progress is an integral part of achieving a more sustainable global future. It involves making changes to our lifestyles, businesses, and communities that promote environmental responsibility and long-term economic growth.

Through setting and monitoring progress goals with specific targets, companies can track their own performance while demonstrating commitment to corporate sustainability objectives. Stakeholders are able to assess and evaluate a company’s commitments to sustainability, enabling better decision-making and improved corporate transparency.

Net-Zero Emissions Targets are a Top Priority

Net-Zero Emissions is an important concept in the global effort to reduce greenhouse gas emissions and prevent further climate change. This goal seeks to achieve a balance between releasing carbon into the atmosphere and removing it from the atmosphere by using strategies such as renewable energy production, carbon accounting, energy efficiency measures, and carbon capture and storage technologies. This can help campnys measure and manage their portfolio exposure to climate risks and financed emissions as they navigate the risks and opportunities in the net-zero transition.

The ultimate aim is for society to reach a point where the level of greenhouse gas emissions released is equal to the amount that is taken out, thus creating a cycle of zero net emissions. Emissions management software can help achieve this goal.

Tackle your Scope 3 Challenge

As with any challenge, the first step to success is understanding the problem. When it comes to tackling Scope 3 emissions, this means gaining an in-depth knowledge of your business’s sources of emissions and the different strategies you can use for reducing them. Once you have a clear picture of what needs to be done, you can start mapping out your Scope 3 emissions reduction plan, taking into account all of the relevant stakeholders and resources.

Ultimately, as part of a good sustainability strategy, you’ll need to develop a comprehensive action plan for reducing emissions, based on the best practices for energy efficiency and low-carbon operations. Setting targets and timelines will help you stay focused and motivated towards achieving your goals.

Finally, consider how you can collaborate with other companies in order to share expertise and resources, which will make it easier to reduce emissions across your entire supply chain. With careful planning and commitment, you can make strides towards meeting your Scope 3 emission reduction objectives.

Are you ready to start your Corporate Sustainability journey?

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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iSi’s Top 8 Gaps Found in Environmental Audits

iSi’s Top 8 Gaps Found in Environmental Audits

Jul 16, 2022

​Environmental regulations are enforced by federal, state and local governments. How do you make sure you have your bases covered? An environmental audit can determine your current status and what your vulnerabilities are.

iSi’s environmental audits cover air, wastewater, stormwater, waste, spill prevention, tanks, DOT and emergency planning (EPCRA) requirements. They are a mock regulatory audit, looking at all aspects of your program through data gathering, walkthroughs and records reviews.

The following are our top 8 areas of compliance we see issues with when we do our audits.

Inaccurate Permits, Registrations & Notifications

What your facility does will determine which of these you need.  For example, have you notified the proper agencies regarding your spraying, blasting, emitting, generating, collecting, storing, disposing, dumping and discharging operations?

When do your permits expire?  Do your permits reflect the operations you’re conducting now?

Notifications may need to be made to EPA, your state authority, and in some cases, municipal authorities.  Many times there will need to be notifications made BEFORE you do these operations in addition to during and after.

Have you made determinations on what category of air emissions source you are or what classification of hazardous waste generator you are?  Who do your storage tanks need to be registered with?

Inaccurate/Incomplete Facility Plans

Specific written plans are required depending on what you do or have onsite. Which apply to you? Are they updated on the frequency required?  Some examples include:

  • Operations and Maintenance (O&M) Plans
  • Work Practice Implementation Plans (WPIP)
  • Storm Water Pollutions Prevention Plans (SWP3)
  • Spill Prevention, Control and Countermeasure (SPCC) Plans
  • Facility Response Plans (FRP)
  • Emergency Response Action Plans (ERAP)
  • DOT Security Plans
  • Hazardous Waste Contingency Plans
Missing/Incomplete Facility Inspections

Are you conducting the inspections which apply to you, on the frequency required?  What documentation is required?  Some typical issues we see missing inspections include:

  • Air
  • SWP3
  • SPCC
  • FRP
  • DOT
  • Hazardous Waste
Missing/Incomplete Facility Tracking

Are you tracking your air emissions correctly? What about waste generation? Tier II or Form R chemicals?  In many cases what you purchase and how much you use need to be tracked.  What do your permits require?  Are you past the usage allowed?  Have you changed a process which was not accounted for in the permit?

These are the areas many companies do not track their usage:

  • Air Emissions
    • Volatile Organic Compounds
    • Hazardous Air Pollutants
    • Particulate Matter
  • Waste Generation
  • Tier II
  • Form R
Inaccurate/Incomplete Reporting

We see a lot of issues with inaccurate and incomplete reporting.  This affects all areas of environmental issues. Reports can be required to monthly, quarterly, semi-annually, and annually?  What does your state/city/county require vs. what’s required federally?

When you have a spill, who are you reporting that to?  There are federal and state regulations which require you to make phone calls to certain authorities based upon the quantity and location.  Besides 9-1-1 or your spill contractor, you may need to report a spill to local emergency planning, the National Response Center, your state authorities.  Do you have a plan for this?  Have you done this and is it documented?

Inaccurate/Undocumented Training

Have you conducted the training you are required to?  Are the right people trained?  In addition to environmental training, please keep in mind that some regulatory agencies cross over in their requirements.  Don’t assume that because you’ve had hazardous waste training, that will suffice for shipping hazardous materials, or if you’ve had OSHA HAZWOPER training that will work for hazardous waste.  There are differences between EPA, OSHA and Department of Transportation (DOT) regulations and the training required for each.

Annual training is required for hazardous waste and per many environmental plans.  Do you have a mechanism to track this?  Are you doing this and has your training been documented?

Do you have job descriptions on file for your people?

Incomplete/Inaccurate Records

Are you keeping required records? Where are they kept and for how long?  Documentation is critical and will save you from many hassles in an inspection.  Are you keeping records for onsite inspections, training, and notifications?  Are they easily accessible?

Poor Day-to-Day Facility Management

Is there a disconnect in the proper way to do something vs. how it’s actually being done?  Spot checks and walkthroughs are just as important for environmental issues as they are for safety.  Many times we see worksites where the same issues keep cropping up on a regular basis.  Are issues you’ve been cited for in the past still popping up at your facility?

For example, are your hazardous materials going into the proper containers?  Are the containers closed and sealed?  Are they properly labeled?  Have your hazardous waste containers been sitting onsite for past the allotted time frame?  What are you doing with your spent fluorescent bulbs?

Do you have proper containment around your tanks?  Are containments cracked or able to leak?

Where is your stormwater being directed?  Do you have vehicles or equipment which leak oils that could come into contact with rainwater where the oils could be transported offsite?

Some of the most common areas we see issues include:

  • Air Emissions
  • Stormwater
  • SPCC
  • Waste
  • DOT
Where Do You Go From Here?

iSi can help you get a baseline on your environmental compliance responsibilities and help you prioritize the ones which are most critical to be taken care of.  Request a quote for an environmental audit today!  Need more information about these issues?  Contact us at (888) 264-7050 or email us!

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OSHA’s Hexavalent Chromium Standard Case Study and Regs

OSHA’s Hexavalent Chromium Standard Case Study and Regs

Jul 8, 2022

iSi works with a number of different companies, and when we see results of regulatory inspections, we like to use them as examples to perhaps help give other companies some insight into what to do with their own compliance.  Quite a few companies are subject to OSHA’s Hexavalent Chromium Standard for either General Industry or Construction, so many that OSHA has had a National Emphasis Program for this for quite a few years.

The types of operations with hexavalent chromium exposures include:

  • Manufacturing of Aircraft, Stainless Steel, Paint, Chemicals, or Pre-Cast Concrete
  • Metal Finishing and Preparation
  • Electroplating
  • Painting or Sanding of Painted Parts
  • Welding of Stainless Steel
  • Iron and Steel Mills and Foundries
  • Printing
  • Construction
  • Chemical Mixing
  • Waste Handling
  • Tanning Leather
  • Handling Catalysts

OSHA Inspection Case Study

A metal finishing company that iSi works with has been working to comply with the hexavalent chromium standard, having iSi conduct their quarterly monitoring and issuing employee notices while the company handles the other elements of the program.  After an employee complaint, OSHA arrived onsite to look at hexavalent chromium compliance.   This is the type of company already on OSHA’s target list for the emphasis program.  The result of the inspection was three violations of the standard.

The first violation was for not having required change rooms.  The company did have a locker area for the employees to change at, and it was in a separate area behind their 3 paint booths.  OSHA found fault with this because there was no demarcation between where the paint booths ended, and the clean room began.  The contaminated portion wasn’t clearly marked.  There also wasn’t separate storage for protective clothing vs. street clothes, only the lockers.  A second violation was cited for this area because there was no sink in the immediate area for washing. OSHA decided the sink that was being used to clean up was too far causing potential contamination to areas outside the regulated area. These two items were cited together since they were part of the same portion of the standard, and the original fine was at a Serious level for $8,192.

The third item was a citation for finding hexavalent chromium in the break area.  There are no set limits on the amount of hexavalent chromium that can be found on surfaces.  Wipe samples indicated levels of 0.05 µg/m3, a very low level detected.  However, it was still enough to be detected and the company was fined for a Serious violation at $5,461.

The total fine was $13,653, which is OSHA’s minimum fine amount for any Serious violation.  With many violations, the company was given a chance to reduce the fine through an Expedited Informal Settlement Agreement, still leaving a violation of over $8,000.

So what are the hexavalent chromium standard’s rules for General Industry and Construction?

The Rules – General Industry
29 CFR 1910.1026

The permissible exposure limit (PEL) for hexavalent chromium is 5 micrograms per cubic meter (5 µg/m3) in an 8-hour time weighted average (TWA). There is also an Action Level that triggers parts of the standard that begins at 2.5 µg/m3.

Make an Exposure Determination

Companies are required to make an Initial Exposure Determination by conducting employee exposure sampling to determine your exposures, including enough breathing zone samples to characterize a full shift, do representative sampling for each shift the exposure can occur using the employee with the greatest potential exposure, or use other air monitoring, historical data and performance-oriented sampling.  If the results are at or above the Action Level, periodic monitoring is required every 6 months, and if they’re above the PEL, monitoring is required quarterly. Notify your employees within 15 business days of the results of monitoring, and if you’re above the PEL, you need to include what corrective action is being taken.

You’re not allowed to rotate employees’ job assignments in order to not meet the PEL requirements.

Establish Regulated Areas

Formally establish the area where employee exposures can be expected above the PEL and then clearly demarcate and label that area from the rest of the workplace to alert employees of its boundaries.  Limit access to this area to only authorized personnel. Regulated Areas can not be used for eating, drinking or smoking nor can any of these items be taken into a Regulated Area such as a pack of gum or cigarettes in an employee’s pocket.

Engineering Controls and PPE

Your first responsibility is to use engineering controls where possible, and if not feasible, reduce the levels as low as you can and then use personal protective equipment (PPE), such as respirators.  The aircraft industry is required to use engineering/work practice controls to reduce exposures to at least 25 µg/m3.  If employees are not exposed for more than 30 days/year, then this requirement does not apply.

Protective Clothing and Equipment (PPE)

Contaminated PPE and other waste and debris must be removed at the end of the shift or completion of tasks and placed into sealed, impermeable bags or containers.  No PPE leaves the workplace and can be laundered as long as those who are laundering are alerted to the harmful effects of hexavalent chromium, that it cannot become airborne and requires minimal skin and eye contact.  Remove contaminated PPE from the change rooms and ensure these bags and containers are properly labeled per Hazard Communication requirements.  PPE cannot be shaken or blown down to remove the dust.

Also, for EPA purposes, all waste material needs to have a waste determination and any debris or waste may be considered hazardous due to the chromium levels.  Make sure you have a determination for these materials.

Hygiene Areas

Provide changing rooms with separate storage for contaminated clothes and equipment and the employees’ street clothes.  Provide washing facilities, with employees washing prior to eating, drinking, smoking, chewing tobacco/gum, applying makeup or using the restroom.  Employees are not to do these activities within the marked off regulated area.  Any eating or drinking areas need to be as free of hexavalent chromium as practicable, and employees are not to wear contaminated clothing/equipment in those areas.

Housekeeping

All surfaces need to be as free as possible of hexavalent chromium.  Clean using wet methods or HEPA vacuums first, and only use dry shoveling/brushing/sweeping where the HEPA vacuum wasn’t effective.  No compressed air can be used to blow the dust.

Initial and Annual Medical Surveillance

Employees who exceed the Action Level must be provided, at no cost to the employee, initial and annual medical surveillance for those with the following situations:

  • Greater than 30 days of exposure (within 30 days for initial, then annually)
  • Exposure in an emergency (within 30 days)
  • Those exhibiting symptoms of exposure (within 30 days)
  • Those terminated (if exposed within past 6 months)

Hazard Communication (Hazcom) and Training Requirements

Include hexavalent chromium in your Hazcom program, including container labeling, SDSs, and training.  Training for hexavalent chromium needs to include all of the requirements of the standard as well as provisions for medical surveillance.

Recordkeeping

You must keep records of your air monitoring data (who – names and job positions, when, where, method used, results, PPE used, other data used) as well as medical surveillance records and training records.

Most Hexavalent Chromium Exposures – General Industry

Electroplating – Hard chrome plating, decorative chrome plating, anodized chrome plating when placing and removing products into and from the bath, rinsing with water, and replenishing bath with chromate solution or powder.

Welding – Welding stainless steel, welding in confined spaces on stainless and carbon steel, indoor welding without engineering controls. Exposures come from welding fumes generated from the base metal and applied coatings, electrode coatings, high-chromium nickel alloy electrodes and chromium-containing filler metals.

Painting – Spray painting, abrasive blasting for the removal of chrome containing paint/primer, sanding or grinding on chrome-covered materials. Hexavalent chromium found in paint include strontium chromate and zinc chromate, and even the blasting grit will contain paint waste-containing chrome.

Foundries, Steel Mills, Molten Metal Operations — Furnace and crane operations, molten metal pouring and transfer, tapping, surface conditioning, hot rolling, torch cutting and gouging, and welding.

The Rules – Construction
29 CFR 1926.1126

The hexavalent chromium rules for the construction industry are pretty much the same as those in general industry, with the following exceptions:

  • Employee notices of monitoring must be provided to employees within 5 days rather than 15
  • The sections on Regulated Areas and Housekeeping are not included in the construction standard.

Most Hexavalent Chromium Exposures – Construction

Painting and Surface Operations – Removal of chromate-containing paint and primer for surface preparation of existing steel (bridges, water towers, and industrial buildings), abrasive blasting and equipment maintenance for site cleanup following abrasive blasting.

Welding and Thermal Cutting – Welding stainless steel and welding in confined spaces or indoor conditions, for both stainless steel and carbon (mild) steel (industrial piping and vessels; architectural facades; constructional structures; boilers; indoor architecture; petrochemical structures; shipbuilding; and turbine blades.), brazing, thermal cutting and boilermaker work.

Concrete Operations – Certain mixes, such as Portland Cement, are know to contain hexavalent chromium and operations such as mixing, pouring or cutting dry cement may release the chromium to the air and become a breathing hazard.

What does your hexavalent chromium area look like?  Are you following the regulation requirements and monitoring your employees?  iSi works with many companies who are required to comply with this standard, so we’re well versed in how to help.  Contact us today!

Program Assistance

Need help determining where you stand with hexavalent chromium compliance?  Need sampling or an audit to see what you’re missing?  We can help!

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iSi Environmental – Hazardous Waste Disposal

iSi Environmental – Hazardous Waste Disposal

Jul 1, 2022

Hazardous waste management is essential for your operations. Our responsive hazardous waste management services provide safe, compliant, and sustainable solutions for the collection, disposal, treatment, recycling, and transportation of hazardous waste materials. With three decades of experience in the industry and a national network of facilities and transportation infrastructure, our team is equipped to meet all your hazardous waste management needs.

Choose iSi Environmental for Hassle-Free Hazardous Waste Disposal!

You and your company want to be environmentally responsible, but you struggle to find reliable companies for your hazardous waste disposal. With global supply chain and transportation disruptions, all businesses are looking for responsive and reliable services, at a fair price. Today, more than ever, getting a competitive price from a waste disposal company requires sacrificing predictable transportation. It doesn’t have to be this way, and, frankly, your facility management expects more from their waste disposal company. Businesses cannot afford to have containers sitting on the loading dock, disrupting production, and causing service delays to your end customers.

iSi Environmental is a leading provider of hazardous waste industry services. Our team has over three decades of experience working with facility hazardous waste, and we are committed to providing safe, compliant, and sustainable solutions for your needs. Whether you need to dispose of electronic waste or industrial products, we have the hazardous waste experts and resources to help you achieve your goals. With our professional services, you can rest assured that your hazardous waste transportation will be handled in a responsible and compliant manner. Contact us today to learn more about our services and how we can help you!

The iSi Environmental Advantage:

– Trusted leader in hazardous waste services with over 30 years of experience

– Offers many benefits, including peace of mind knowing that your waste disposal will be managed responsibly and in compliance with all regulatory requirements

– Team of hazardous waste experts committed to finding safe, compliant, and sustainable options for the widest range of waste streams

– Nationwide network of facilities and transportation infrastructure

– Flexibility to meet all your hazardous and non hazardous waste disposal needs

– Focus on process safety, compliance, and sustainability

– Extensive experience and expertise in hazardous waste management services

– Dedicated to helping our customers achieve their hazardous waste disposal goals

– Commitment to excellence ensures that all our services meet the highest standards

– Effective and reliable hazardous waste removal solutions that are safe, compliant, and sustainable.

What is hazardous waste and why do I need to manage it?

Hazardous waste is any waste that poses a potential threat to human health or nature. It can be any type of waste, from industrial and commercial waste to household products. Managing hazardous waste presents unique challenges and is essential for protecting people and our earth from the potential hazards posed by these materials.

What are the different types of hazardous waste?

There are many different types of hazardous waste, including industrial waste, medical waste, electronic waste, universal waste products, radioactive waste, waste sludge, non hazardous waste, and household hazardous waste. Each type of waste has its own unique set of hazards that need to be managed appropriately.

How can I safely dispose of my hazardous waste?

Disposing of hazardous waste can be difficult and confusing. There are many different methods for disposing of hazardous waste, and each disposal method has its own set of risks and benefits. Hazardous waste disposal can be accomplished through a variety of methods, including treatment, landfills, recycling, and incineration. The best removal option for hazardous waste will depend on the type of waste and the specific regulations in your area. Working with professional hazardous waste disposal services can help ensure the removal of waste is handled safely and legally.

What are the benefits of using a professional hazardous waste management service?

Professional hazardous waste disposal services offer a number of benefits, including expert knowledge and guidance, cost-effective solutions, reliable transportation and storage options, and compliance with all local regulations. Whether you need removal of liquid or solid hazardous waste, non hazardous waste, or household products, working with a reputable hazardous waste experts can help ensure that your waste is handled safely and responsibly.

The Hazards of Hazardous Waste

Hazardous wastes pose many risks to human health and the planet, including contamination of soil and water, damage to ecosystems, and exposure to toxic chemicals that can cause serious health problems. Disposing of hazardous waste safely is essential for protecting people and the environment from these hazards.

Why You Can’t Afford to Ignore Hazardous Waste Management

Hazardous waste administration is a critical part of any business or organization, yet many people choose to ignore this important issue. Whether you are dealing with industrial waste, non hazardous waste, or household products, failing to manage your waste disposal responsibly can lead to serious consequences, including hefty fines, damage to your reputation, and even jail time. Ignoring hazardous waste is simply not an option if you want to protect your business or organization.

How iSi Environmental Can Help You with Your Hazardous Waste Disposal Needs

iSi Environmental is a leading provider of hazardous waste disposal services. We offer a wide range of management solutions for the collection, transportation, and disposal of hazardous waste materials. With more than three decades of experience in the industry, our team is equipped to handle any hazardous waste disposal challenge. iSi’s hazardous waste disposal experts can create a safe, cost-effective, and legal treatment approach for the disposal of your hazardous materials and byproducts regardless on their size or content. We offer responsive customer service, competitive pricing, and a commitment to compliance with all local, state, and federal regulatory guidelines. Contact us today to learn more about our hazardous waste disposal services process and how we can help you keep your organization safe and compliant. Responsive and attentive service is only one call away.

Disposal Services:

  • Radioactive Waste
  • Industrial Waste
  • Lab Packs
  • Sludge
  • Chemical Waste
  • Medical Waste
  • Toxic Waste
  • Paint Waste
  • Non Hazardous Waste Disposal
  • Hazardous Waste Removal
  • Containers and Supplies
  • Facility Management

Disposal Facility Options:

  • Recycling
  • Landfill
  • Underground Storage
  • Incineration
  • Fuel Blending Facilities

 

Questions to ask your hazardous waste disposal companies:

 

Will the onboarding and implementation process be time consuming?

iSi Environmental’s waste disposal services offers a seamless onboarding experience. Responsive client service has allowed our firm to experience continuous growth over the last three decades.

Do your disposal facilities handle radioactive waste?

With a wide variety of disposal solutions, iSi will work to find appropriate disposal options for your radioactive waste.

Do you offer on-site logistics management services?

Our Facility Support Services can help you to streamline facility operations and allow your team to better focus on supplying products to the end customers. With experience in transportation, logistics, warehousing, and onsite waste and recycling activities, we have unique experience to benefit your operations.

Do you offer a wide array of disposal facilities and treatment technologies for my waste? (landfill, incineration, recycling, or reuse facility disposal options)

We offer a wide range of disposal facilities and treatment options, including landfill, incineration, recycling, or reuse facility disposal options.

Are you familiar with my industry specific, local, state, and federal regulations?

iSi has performed waste consulting in 30+ states across the United States. Having worked in production facilities prior to consulting, our staff has wide ranging industry knowledge. As a backup, we use a software that highlights industry specific regulatory requirements by state and municipality.

Can you provide examples of similar disposal projects?

On request, we can provide examples of similar disposal or recycling projects.

What types of containers can you provide to us?

We offer a wide variety of containers, including drums, totes, bags, and boxes. We also have a wide range of capacities available, from small to large. Please feel free to contact us at 888-264-7050 and we would be more than happy to help you select the right container for your needs.

Can you provide a origin/destination workflow for my paint waste, toxic waste, sludge, chemical waste, or medical waste?

Yes, we can provide an origin/destination workflow for your paint waste, toxic waste, sludge, chemical waste, or medical waste. Please feel free to contact us at 888-264-7050 and we can discuss your specific workflow needs.

Do you offer hazardous waste removal or remediation services?

Outside of disposal services, we have a separate division within iSi that can assist with the removal of hazardous waste and perform remediation service at your facility

How quickly can you deliver lab packs to my facility?

Depending on facility location, iSi can usually deliver lab packs as soon as 24 hours. Please feel free to contact us and we would be more than happy to confirm availability and delivery time for your specific needs.

Do you offer containment materials and PPE for purchase?

Our convenient software platform provides all the containment materials and PPE a facility could need. We participate in a consortium of buyers that allows our clients to receive a competitive price on all available items.

Would you be able to share business references from companies similar to mine?

We would be happy to share business references from companies similar to yours. Reach out to us at 888-264-7050 and we will provide you with any information you need.

Do you offer bulk on-site liquid storage containers?

Yes, we offer a variety of bulk on-site liquid storage containers. Our service partners carry a variety of container types and sizes. We would be happy to discuss options with you.

Can you assist in a zero waste to landfill program?

iSi is available to assist your management team in pursuit of sustainability and your ‘zero waste to landfill’ strategy. Our years of experience inside industrial settings can aide in the removal of defaulting to landfill for your hazardous waste disposal needs and shift the focus to recycling and reuse.

Where can I dispose of paint in Wichita KS?

Chemical waste is not acceptable. Instead bring it to the local household waste disposal facility, located at 801 Stillwell, Wichita, KS 67213. The cost is zero.

Are there Kansas hazardous waste disposal options?

Services are available statewide and across the region. Specific cities served in this region include:

  • Wichita, Kansas
  • El Dorado, Kansas
  • Kansas City Metro Area
  • Omaha, Nebraska
  • Oklahoma City, Oklahoma
  • Tulsa, Oklahoma

What is considered hazmat waste?

Hazardous waste are materials that may be harmful to human health and environmental conditions. Hazardous waste can be solid, liquid. They are a collection of discarded materials, such as cleaning fluids or chemicals, as well as byproducts from manufacturing processes.

What is a Subtitle C landfill?

Subtitle C landfills include Hazardous Waste Landfills. These are specialty sites that accepts hazardous waste for disposal. This waste disposal system has no use as a waste dump.

How do I dispose of old CNC coolant?

If a fluid waste is not considered nonhazardous, the material may be disposed at the treatment plant or if the sewer is allowed into the water supply, discharged into the municipal sewer system for non hazardous waste disposal.

How do you get rid of chemical waste?

Chemical waste is regulated under the Resources Conservation and Recovery Act of the United States (RCRA). The materials are not acceptable for disposal at sewage treatment stations or in the normal garbage collection. Almost all chemical waste is disposed of as EHS hazardous waste.

How do companies get rid of chemicals?

Since industrial biproducts may cause harm to humans and the planet, environmental protection agencies are imposing restrictions on industrial chemicals. The most common disposal procedures are burning waste incinerated land or infiltration of underground water.

How do you get rid of a biohazard?

All biohazard liquids are preferably autoclavable before disposal.

How do companies get rid of toxic waste?

The Environmental Protection Agency has restricted the disposal of industrial chemicals. Incineration is a common treatment process and land and underground injection holes are also available to remove waste.

What certifications do your drivers have?

Our drivers are certified in hazmat transportation. Please feel free to contact us at 888-264-7050 and we would be more than happy to help you with your specific needs.

Need Assistance?

Let iSi’s EHS team help you improve your company’s hazardous waste compliance.  How can we help?  Contact us!

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Trailer Safety

Trailer Safety

Jun 7, 2022

Trailers are often used in the workplace — by operations personnel down to even the sales department who may move their exhibits from show to show.  The construction industry uses a lot of trailers to move equipment. 

With the summer season, our employees may be using trailers to haul boats, ATVs, campers, or extra large smoker grills.  U-Hauls can be rented by anyone for moving from house to house or to move a kid to or from college, to haul cars or other items.

Here are some trailer safety tips to help avoid a potential accident:

  • Choose the right tow vehicle and trailer for the load. Review the tow capacity and ensure it’s capable of handling the weight of the trailer and what you’re going to be towing on it.  Exceeding the capacity can severely affect handling, braking and damage your vehicle’s suspension. Check the hitch for the maximum trailer and maximum tongue weights it can safely support.
  • If you’re going to be carrying additional loads or passengers in the vehicle, check the gross vehicle weight rating issued for your vehicle and make sure the load will not exceed that rating, nor that the combination of the trailer and vehicle weights will be exceeded.
  • Make sure you have the proper hitch ball for the trailer. Incorrectly sized hitch balls are the #1 cause of trailer accidents.
  • When hauling loads, 60% of the load on the trailer should be placed on the front half of the trailer, with a tongue weight of 10-15% of the total weight that’s loaded on the trailer. Ensure weight is evenly distributed on the left and right sides of the trailer.
  • Straps are critical — broken or cheap straps can fail fast. Use ratchet straps for anything heavier than an average person and use more than one strap in case one comes loose.  The working load of the strap should be more than the weight of what you’re hauling.  For vehicles, strap vehicles at four points of the trailer corners.
  • Check your tires on both the vehicle and the trailer. Underinflation can cause rolling resistance and forces the engine to work harder and consume (now more expensive) fuel.
  • One of the most common trailer issues is lights — make sure your lights work before you leave, make sure the load doesn’t obscure them and take spare bulbs and fuses with you.
  • Check your brakes and make sure the breakaway cable is properly attached to your tow vehicle. In the event the trailer somehow disconnects from the hitch, the cable will trigger the trailer brakes.
  • Always cross safety chains so that they form a cradle for the tongue to fall down onto.
  • Adjust your mirrors so that you can have a clear view of the entire trailer, to the end.
  • Carry spare parts such as at least one trailer spare tire as well as extra wheel bearings and hubs.
  • When unhooking the trailer from the tow vehicle, use wheel chocks in front of and behind the trailer’s tires to ensure it doesn’t roll away.
  • Towing can stress your engine, so make sure your vehicle has all of its fluids to prevent overheating. Make sure your vehicle has proper levels of coolant, oil and transmission fluid.
  • Be patient when passing and take extra care when changing lanes.
  • Don’t speed and know the speed limits of the trailer and of your state/local area. Some areas have specific speeds for trailers.
  • Stop gradually when possible and allow for plenty of stopping distance between you and the vehicle in front of you. It takes longer to stop when pulling a load. Scan the road ahead to anticipate potential problems.
  • Watch out for trailer sway. High winds, large trucks, downhill grades and high speeds can lead to your trailer swaying.  If you’re not careful, it can swing like a pendulum.  Consider using a hitch stabilizer or a sway control unit to help alleviate this issue.
  • Don’t drive in if there’s no way out. It’s easy to get blocked in, so make sure there’s plenty of space to make a complete turnaround.

Besides our weekly EHS blog articles, every other week we email out a general safety topic sheet that you can share with your teams.  Want to be added to the list?  Sign up here.

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What is OSHA’s National Emphasis Program on Heat Hazards?

What is OSHA’s National Emphasis Program on Heat Hazards?

Jun 2, 2022

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Heat plays a large part in how we plan our day. We often put off work that creates heat or highly strenuous tasks to a time when the weather is more conducive to our needs. However, that cannot always be done. Sometimes a task must be done on a rigid schedule or is of an emergency nature so that work cannot be put off to a later, cooler, time of day. To that end, OSHA has developed a National Emphasis Program (NEP) to give some guidance to companies on how to work in the heat and keep employees safe.


What is OSHA’s NEP on Heat Hazards?

OSHA will conduct programmed (pre-planned) inspections in targeted high-risk industries on any day that the National Weather Service has announced a heat warning or advisory for the local area.

The NEP went effective on April 8, 2022 and will remain in effect for 3 years unless canceled or extended by a superseding directive.

The NEP establishes heat priority days when the heat index is expected to be 80 degrees Fahrenheit or higher. During these days OSHA will:

  • Initiate compliance assistance in the list of targeted high-risk industries; and,
  • Inspect any alleged heat-related fatality/catastrophe, complaint or referral regardless of whether the worksite is within the list of targeted high-risk industries.


What are the Targeted High-Risk Industries?

OSHA’s NEP on heat hazards targets over 70 high-risk industries based on:

  • Bureau of Labor Statistics (BLS) on incidence rates of heat-related illnesses
  • Elevated numbers of fatalities or hospitalizations reported to OSHA
  • Highest number of heat-related General Duty Clause violations over the last 5 years

These include but are not limited to:

General Industries That are Likely to Have Heat-Related Hazards:

NAICS Code        NAICS Industry Sector Title

1121                      Cattle Ranching and Farming
1151                      Support Activities for Crop Production
2131                      Support Activities for Mining
3118                      Bakeries and Tortilla Manufacturing
3211                      Sawmills and Wood Preservation
3241                      Petroleum and Coal Products Manufacturing
3251                      Basic Chemical Manufacturing
3272                      Glass and Glass Product Manufacturing
3311                      Iron and Steel Mills and Ferroalloy Manufacturing
3314                      Nonferrous Metal (except Aluminum) Production and Processing
3315                      Foundries
3323                      Architectural and Structural Metals Manufacturing
3329                      Other Fabricated Metal Product Manufacturing
3361                      Motor Vehicle Manufacturing
3362                      Motor Vehicle Body and Trailer Manufacturing
3363                      Motor Vehicle Parts Manufacturing
3364                      Aerospace Product and Parts Manufacturing
3365                      Railroad Rolling Stock Manufacturing
3366                      Ship and Boat Building
3369                      Other Transportation Equipment Manufacturing
3371                      Household and Institutional Furniture and Kitchen Cabinet Manufacturing
4239                      Miscellaneous Durable Goods Merchant Wholesalers
4241                      Paper and Paper Product Merchant Wholesalers
4242                      Drugs and Druggists’ Sundries Merchant Wholesalers
4243                      Apparel, Piece Goods, and Notions Merchant Wholesalers
4244                      Grocery and Related Product Merchant Wholesalers
4245                      Farm Product Raw Material Merchant Wholesalers
4246                      Chemical and Allied Products Merchant Wholesalers
4247                      Petroleum and Petroleum Products Merchant Wholesalers
4248                      Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers
4249                      Miscellaneous Nondurable Goods Merchant Wholesalers
4413                      Automotive Parts, Accessories, and Tire Stores
4442                      Lawn and Garden Equipment and Supplies Stores
4881                      Support Activities for Air Transportation
4882                      Support Activities for Rail Transportation
4883                      Support Activities for Water Transportation
4884                      Support Activities for Road Transportation
4889                      Other Support Activities for Transportation
4921                      Couriers and Express Delivery Services
4922                      Local Messengers and Local Delivery
4931                      Warehousing and Storage
5311                      Lessors of Real Estate
5617                      Services to Buildings and Dwellings (includes landscaping services, tree removal and tree trimming services)
5621                      Waste Collection
5622                      Waste Treatment and Disposal
5629                      Remediation and Other Waste Management Services
6231                      Nursing Care Facilities (Skilled Nursing Facilities)
7211                      Traveler Accommodation
8111                      Automotive Repair and Maintenance
8113                      Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance
8114                      Personal and Household Goods Repair and Maintenance

Construction Industries That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

2361                      Residential Building Construction
2362                      Nonresidential Building Construction
2371                      Utility System Construction
2372                      Land Subdivision
2373                      Highway, Street, and Bridge Construction
2379                      Other Heavy and Civil Engineering Construction
2381                      Foundation, Structure, and Building Exterior Contractors
2382                      Building Equipment Contractors
2383                      Building Finishing Contractors
2389                      Other Specialty Trade Contractors

Industries not Included in General Industry or Construction That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

1112                      Vegetable and Melon Farming
1113                      Fruit and Tree Nut Farming
2213                      Water, Sewage and Other Systems (may be State or local jurisdiction)
4411                      Automobile Dealers
4412                      Other Motor Vehicle Dealers
4821                      Rail Transportation (may be Federal jurisdiction)
4885                      Freight Transportation Arrangement
4911                      Postal Service
5611                      Office Administrative Services
5612                      Facilities Support Services
5613                      Employment Services
5614                      Business Support Services
5616                      Investigation and Security Services
5619                      Other Support Services
6117                      Educational Support Services
7225                      Restaurants and Other Eating Places
8112                      Electronic and Precision Equipment Repair and Maintenance
9281                      National Security and International Affairs (includes Customs and Border Patrol, and Transportation Security Administration)


What Will the OSHA Auditors Be Inspecting When They Come to Your Facility?

During heat-related inspections, inspectors will:

  • Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illness(es). 
  • Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations did not occur. This may require the use of a Medical Access Order.
  • Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work.
  • Determine if the employer has a heat illness and injury program addressing heat exposure, considering the following:
    • Is there a written program?
    • How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
    • Was there unlimited cool water that was easily accessible to the employees?
    • Did the employer require additional breaks for hydration?
    • Were there scheduled rest breaks?
    • Was there access to a shaded or cool area?
    • Did the employer provide time for acclimatization of new and returning workers?
    • Was a “buddy” system in place on hot days?
    • Were administrative controls used (earlier start times, and employee/job rotation) to limit heat exposures?
    • Did the employer provide training on heat illness signs, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?
  • Document conditions relevant to heat-related hazards, including:
    • The heat index and additional weather data from that day, e.g., heat alerts from the NWS, data from the OSHA-NIOSH Heat Safety Tool App, saving a screenshot on a mobile phone or tablet. Additional information may be needed for indoor heat investigations.
    • Observe and document current conditions and those at the time the incident occurred (for unprogrammed inspections), including:
      • Observed wind speed
      • Relative humidity
      • Dry bulb temperature at the workplace and in the shaded rest area
      • Wet-bulb globe temperature at the workplace, (ensure the equipment has been properly calibrated prior to use)
      • Cloud cover (no clouds, 25%, 50%, 75%, 100%)
      • The existence of any heat advisories, warning or alerts the previous days
    • Identify activities relevant to heat-related hazards. These can include, but are not limited to:
      • Potential sources of heat-related illnesses (e.g., working in direct sunlight, a hot vehicle, or areas with hot air, near a gas engine, furnace, boiler or steam lines).
      • The use of heavy or bulky clothing or equipment, including personal protective equipment.
      • Estimate workload exertions by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy or very heavy work, considering both average workload and peak workload.
      • Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities.
    • OSHA believes a review of any potential heat-related hazards should be included in any programmed or unprogrammed inspection where radiant heat sources exist in indoor work areas or at outdoor work areas on heat priority days. OSHA advises inspectors to conduct compliance assistance and document it where heat-related hazards do not warrant issuing citations.
    • Inspectors can use the OSHA-NIOSH Heat Safety Tool App as a resource.

How Can You Prevent Heat Illness at Work?

Dangerous heat exposure can occur indoors or outdoors, in any season. Employers can keep workers safe by following these simple safety practices:

  • Follow the 20% Rule — on the 1st day, don’t allow employees to work more than 20% of a shift at full intensity in the heat. Increase their time by no more than 20% a day until they are used to working in the heat.
  • Provide cool drinking water – encourage workers to drink at least one cup every 20 minutes, even if they are not thirsty.
  • Rest breaks — allow workers time to recover from heat in a shady or cool location.
  • Dress for the heat — have workers wear a hat and light-colored, loose fitting, breathable clothing if possible.
  • Watch out for each other — encourage workers to monitor themselves and others for signs of heat illness.
  • Look for any signs of heat illness, including fainting, dizziness, nausea, and muscle spasms, and act quickly — when in doubt, call 911.
  • Offer training on the hazards of heat exposure and how to prevent illness.
  • Develop an Emergency Action Plan on what to do if a worker shows signs of heat-related illness.


Need Help in Getting Your Documentation in Order?

Do you need assistance in developing a formal heat illness and injury program compliant with this initiative? Do you need assistance in determining your potential heat exposures? iSi can help! Contact us today!

 

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

Keith brings over 20 years of industrial hygiene and safety experience to iSi and its clients. An industrial hygienist, Keith jokes that he "sucks air for a living."  He specializes in workplace exposure testing and sampling strategies, safety compliance, ergonomics and training in a variety of topics in both the industrial hygiene and safety field.

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What is EPA’s General Duty Clause? Where is It?

What is EPA’s General Duty Clause? Where is It?

May 26, 2022

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In our blog, we’ve looked at OSHA’s General Duty Clause, including issues that are commonly cited under the General Duty Clause.  Did you know that EPA has a General Duty Clause too?

Who Does It Apply To?

The EPA General Duty Clause can be found in the Clean Air Act, Section 112(r)(1).  It states companies that produce, process, handle or store hazardous substances/chemicals have a primary duty to identify release hazards and prevent chemical accidents.

If your company doesn’t fall under EPA’s Risk Management Plan (RMP) requirements, you will fall under EPA’s General Duty Clause.

General Duty Clause vs. RMP

If you produce, process, handle or store hazardous substances/chemicals, you will need to comply with either the EPA General Duty Clause or RMP, based on your operations.

The requirements for RMP can also be found in this same Clean Air Act Section 112(r) as the General Duty Clause, and it also applies to the same types of facilities who use hazardous chemicals.  However, RMP is focused on one or more of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

RMPs are directly submitted to EPA.  Water treatment plants, agricultural COOPs and chemical manufacturers are typical types of companies who need to comply with RMP.

RMPs must include:

  • Potential effects of a chemical accident
  • Hazard assessments
  • 5-year accident history
  • Evaluation of worst-case scenarios and alternative accident release potentials
  • Prevention programs that include safety precautions, maintenance, monitoring, and employee training measures
  • Emergency response program that lists emergency health care, employee training measures, procedures for informing the public.

 What is Required by EPA’s General Duty Clause?

In an EPA inspection, the inspector can ask your company to produce information to show you are complying with the General Duty Clause.  To be compliant, companies are required to address the following 3 topics, with examples for each.

1.  Identify hazards which could occur if an accidental release happens.

  • Identification of related environmental, health and safety hazards
  • Identification of potential release scenarios through experience/industry research, analysis and logic trees, or “What If” brainstorming
  • Determine the consequences in each scenario

2.  Design and maintain a safe facility. (By putting features such as these in place:)

  • Design safety codes
  • Use of less hazardous chemicals when possible
  • Equipment quality control procedures,
  • Using alternate processes
  • Process siting
  • Using safety technology where possible
  • Standard Operating Procedures
  • Employee training
  • Change management
  • Incident investigation programs
  • Self audits
  • Preventative maintenance programs

3.  Determine potential consequences of accidental releases and minimize them.

  • Development of an Emergency Response Plan that contains, at a minimum: anticipated releases, mitigation, notification process to local responders and local responder involvement
  • Coordination with local emergency response officials including the local emergency planning committee
  • Training for “out of the norm” circumstances
  • Periodic exercises using your plan, training, and equipment practicing response, evacuation, sheltering-in-place, and worker’s ability to perform in the event of an emergency

Inspectors will also be looking into the thoroughness of your process hazard analyses, your evaluations, and the elements you’ve put into place, and whether or not they apply to your current operations.

Which One Applies to Your Facility?

Because the RMP is specific to certain chemicals and thresholds, all companies with the potential for accidental chemical releases may not fall under its requirements.  However, if RMP does not apply to your company, then the EPA General Duty Clause will.  

Which one applies to your facility?  Have you completed all the necessary analyses required? Do you have all the programs, processes and training in place?  If the answer to any of these questions is no, then iSi can help.  Contact us today for more information.

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

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