Sustainability is Much More Than Just Being Green

Sustainability is Much More Than Just Being Green

Sustainability…that’s a word that’s been thrown around a lot within the past few years and to many it may conjure images of recycling and being a good environmental steward.  However, sustainability is more than just that environmental “stuff,” it’s actually much broader and you can count a lot of different practices towards it.

Sustainability can be defined as what your company is doing to contribute to society in terms of social responsibility, economic growth, AND environmental protection.  It’s what your company is doing to ensure you are adding value to society by how you manage resources, interact with your community, and work with your employees while staying profitable to sustain jobs for your community.

Large corporations have entire teams dedicated to sustainability strategies.  Medium and small companies are soon going to need to develop sustainability strategies in order to keep up.  Suppliers are already being asked to implement and start showing their own sustainable actions.  It’s not a matter of if sustainability will need to be addressed by your company, it’s when.


Goals of Sustainability

The goal of sustainability is to ensure your company is being a sustainable resource that’s in a way profitable for everyone.  It needs to ensure:

  • Customers will want to buy from you.
  • People will want to work for you.
  • Other businesses will want to do business with you.
  • The community will want to have you there.
  • You’re doing what you need to do to protect natural resources and the environment.
  • You’re finding ways to improve efficiencies and lower risk.


Sustainability Areas

There are a number of areas in your company where you can find and develop sustainable practices.  These include:

  • Community Involvement: How your company is making the community(ies) you’re located in a better place to live.  How do you contribute to improving your community, how do you affect its culture and be a good economic source of jobs?
  • Employment Practices: Being a good place to work by promoting personal and professional development, diversity, empowerment and participation from your employees.

  • Business Relationships: Engaging in fair-trading practices with suppliers, distributors and partners.
  • Morality and Ethics: Setting ethical standards and practices in place for working with all persons who have a stake in the success of your business.
  • Transparency: Timely communications with those affected by your company and being accountable to your internal and external customers.
  • Value of Products and Services: Providing a good quality product and/or service that adds value, while ensuring customer satisfaction.
  • Regulations Compliance: What you are doing to ensure you’re following all local, state, and federal regulations.
  • Resource Management: Managing resources efficiently, conscientiously and effectively.
  • Financial Return: Compensating providers of capital with a competitive return on their investment and protecting your company assets.
  • Protecting the Environment: Promoting restoration of the environment, finding ways to reduce waste, and sustainable development of products, processes, services and other activities.

Every department of your company can get involved to affect the process.  For example, it can start with Procurement finding raw materials with lower environmental impacts and socially-responsible suppliers, to Production devising processes that are more efficient while maintaining environmental and safety standards, to Marketing who can look at how sales and distribution methods can reduce adverse social and economic impacts.


What Can Sustainability Include?

Sustainability efforts can be internal or externally focused.  Some examples of each include:

Internal

  • Energy efficiency
  • Process innovations
  • Research and development
  • Plant certifications such as ISO 14001, 45001 and 9001
  • Process Safety Management
  • Audits for environmental standards and practices
  • Employee programs and benefits
  • Training
  • Assessing impacts of new or expected regulations and auditing areas of potential noncompliance
  • Minimizing liabilities
  • Standardizing systems and measures

External

  • Community involvement and philanthropy
  • Regulations compliance
  • Supplier audits and requirements for work practices
  • Supplier certification requirements
  • Public disclosure of sustainability reporting
  • Including sustainability information in shareholder documents
  • New market opportunities and sustainable or environmentally-affected product advances
  • Waste minimization
  • Social policy statements/guidelines
  • Environmental policies
  • Avoiding creating contamination


Other Applicable ISO Standards

There are ISO standards for other items that would be included in sustainability efforts.

There is an ISO 50001 for Energy Management.  Its focus is on how to improve energy use through the development of an energy management system.  This management system is the same used for ISO 14001 and 9001.

There is also a standard for social responsibility, ISO 26000.  ISO 26000 is a guidance only and cannot be certified like other ISO standards.  This standard helps clarify what social responsibility is and gives best practices relating to social responsibility globally.


Where Do You Start?

Just saying you’re committed to sustainability isn’t going to make it happen.  You need to incorporate it into your company culture.  Very much like any effective safety program, this too needs to start with support from top management and become an expectation that trickles down into each and every part of your company until it becomes a part of your corporate culture.

First, you need to decide how sustainable you want to be and what resources you want to dedicate to it.  Decide which areas you want to tackle.  For it to be successful what you choose to do needs to make financial sense and fit well with your company culture, your products, your location, and/or your customers.

Take a look at what you’re already doing.  What else can be done?  What are the costs and benefits of what you could do?  How can future costs be impacted by improvements you can make today?

Are there companies that you are working for who are requiring (or considering) requiring sustainability efforts?  What are those?  Are certain certifications such as the ISO 14001 environmental management system going to be required?  We are finding that many companies, especially those who work globally, are starting to require suppliers to get ISO certifications like the ISO 14001 because they are a recognized standard for implementing an overall environmental management system. 

ISO certifications have a set framework that looks at internal and external policies, communications and procedures.  Certification also helps demonstrate you are committed to putting standards and procedures in place to comply with regulations.  Once you’ve been through one ISO certification, you’ll find the others are very similar, including the ISO 45001 certification for safety because it uses many of the same methods.

Once you decide what you want to do, how far you want to go, and what your budget is going to be, then you’ll need to get different stakeholders involved.  You can have an outside company help you get organized, or you can develop your own in-house team.  Some companies have created internal committees like they do with safety committees, and some have hired full-time sustainability managers to make sure the effort stays on track.


How Do You Track Success?

Sustainability isn’t like sales or other goals your company is used to tracking, it can be hard to put a metric to it.  Sustainability is often a long-term goal and harder to predict.  It is sometimes harder to implement than other goals because it can be more abstract, but nonetheless important.

Besides typical measures like waste reductions, energy savings, and cost savings, there are other metrics that can be counted towards sustainability.  These could include metrics such as

  • Recycling savings;
  • Training expense per employee;
  • Number of sites with environmental or safety certifications;
  • On-time delivery;
  • Number of jobs posted and filled internally;
  • EHS capital expenditures;
  • Number of customer complaints;
  • Positive reviews;
  • Purchases from minority businesses; and,
  • Number of workers participating in industry or community organizations.


In Conclusion

We at iSi are already hearing that some of our major clients are looking to requiring their suppliers to have sustainability programs in place.  We have also had to start developing specific programs related to social issues, not just compliance issues any more.

It looks like sustainability is here to stay and will only continue to grow as an expectation.  iSi has a number of services in place to help you with your sustainability efforts and we are here to help in any way we can.


Learn more about the sustainability services iSi can help you with here
.

iSi's Sustainability Services

iSi can help you get several internal and external sustainability tasks accomplished, including all of the ISO standards listed and more.  Check out where we may be able to help you by visiting our Sustainability page.

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iSi Finds Success With Virtual EHS and ISO Compliance Audits

iSi Finds Success With Virtual EHS and ISO Compliance Audits

The COVID-19 pandemic really threw a curveball at all businesses, forcing them to think differently about how to provide services and products to their customers.  Although the pandemic has been a major disruption, something good has come out of it for iSi.  We’ve been forced to think outside of the box to develop alternatives to business as usual.  In some cases it’s made us more efficient and has worked out nicely for our clients too.   One such success story at iSi has been virtual audits.

Traditional Audit Tactics Out the Window

Business disruptions unfortunately don’t disrupt environmental, health and safety (EHS) compliance obligations.  Businesses still need to ensure they’re complying with EPA and OSHA regulations correctly, and for those companies who are requirements to achieve ISO Certification, those requirements still go forth.

iSi conducts several different types of audits, from records reviews, to facility walkthroughs, to a combination of the two, to ISO standards-based audits.  Traditional EHS and ISO audits often have involved travel to facilities to spend one or more days onsite.  With COVID, travel to and from different locations has been reduced, discouraged, and even forbidden in certain locations without quarantine.  Many of our client sites have been closed to outside visitors either completely, front doors are locked, and in some instances entry has been limited to a contractor approval process.  Interviewees are working on limited schedules, or working from home, making traditional methods that much more difficult.

Records Reviews

With travel affected, we needed to find an alternative to being onsite.  Records reviews were the first and best items in our process to start with virtually.  Clients can scan and upload records for reviews.  Over the past year, iSi has implemented a new Enterprise Resource Planning (ERP) System, allowing us to improve multiple processes throughout the company including project management, document storage, web conferencing, online training, digital file transfer, electronic billing, and more, and so we’re set up to do a lot of different things electronically.  iSi and its clients can upload and review documents back and forth electronically with a lot of ease.

Walkthroughs and Interviews

Although walkthroughs are a very valuable piece to our audits, we find that we can use alternatives here too.  iSi has HD smart glasses so that our client can literally be our eyes onsite. The glasses have camera, video, and communications capabilities so that the client can record a walkthrough through the glasses and still communicate back and forth with our auditor remotely.  Even better, they are safety rated so that they can be used as safety glasses in industrial facilities.  In lieu of the glasses, clients can also record videos of certain areas of their facilities, conduct live streaming videos, or take photos for our auditors to inspect.

The pandemic has forced us all to get more familiar with video conferencing software.  Interviews and discussions can be done remotely through video conferencing.  This has allowed us to still get to know our clients and has given us the chance to discuss important topics or answer questions, just as if we were sitting there side by side.

We’ve also been able to give clients guidance on how to use certain pieces of equipment by giving visual demonstrations on camera and providing step-by-step instructions.

ISO Audits

Virtual audits have been most seamless for our ISO projects.  For example, iSi recently conducted a third-party ISO internal audit for a worldwide aircraft components manufacturer to identify existing EHS Management System conformance to the ISO 14001:2015 and ISO 45001:2018 standards.

iSi reviewed the corporate EHS management system and the corporate office’s EHS management system. These systems were compared against the ISO standard, legal/regulatory standards, internal policies and procedures, and customer needs.

The audit was completed virtually through Microsoft® Teams, a communication and collaboration platform. Employee interviews were done through video meetings, and documents were reviewed through screen sharing and e-mail.  Management interviews were conducted virtually and over the phone with the corporate CEO, Investor Relations, and Senior Leadership such as the Executive Vice President and Human Resources, as well as various environmental and safety committees.

All the while, iSi’s auditor remained at our headquarters in Wichita, Kansas while conducting the audit at the client’s facility in Connecticut.

Following the audit, a report of findings and deficiencies was prepared and these reports were all delivered electronically.

iSi was able to conduct a very comprehensive ISO audit for this client, covering topics such as

  • External and Internal Issues
  • EHS Policies, Procedures, Objectives Compliance Obligations
  • Current Processes
  • Leadership Commitment, Culture and Management Roles
  • Employee Participation and Worker Needs
  • Available Resources
  • Internal and External Communication Systems and Evaluation Processes
  • Continual Improvement Efforts
  • Organizational Roles and Responsibilities
  • Reporting
  • Conformance to Regulatory and ISO Standards
  • and More

The Future of Virtual Audits

Although we don’t think we’ll be doing virtual audits exclusively from now on, we do see the benefits of this new alternative.  It’s allowed us to become more organized and more in tune with the electronic resources we have at our disposal.  It’s also saved our auditors a ton of time in not having to travel far distances, instead reinvesting that time into the project itself.  This, in turn, also have been a cost savings and a time savings for our clients too.

In our business, there’s nothing like the interpersonal relationships that are built between our teams and our clients throughout a project.  However, virtual audits has still allowed us to develop these and haven’t gotten in the way as much as one may think they would.

The efficiencies learned and gained are bound to help future projects going forward.  Perhaps these experiences have shown us there will be less need in the future to be onsite for those visual audits or walkthroughs, while the other parts of the audit will be done remotely, saving time and efforts for both parties.

Time will tell what the future of audits will look like, but at iSi we are happy that we have found something positive to take away from this crazy time.

Visit Our Audits Page!

Learn more about our audits and what we can provide!

Contact Us for Your Next Audit!

Our audit team can help your company too – either in-person or virtually!  Where does your compliance stand?  Let’s get the conversation started!

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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What is a Phase I Environmental Site Assessment?

What is a Phase I Environmental Site Assessment?

If your company plans to purchase, manage, lease, or sell a piece of commercial property, the phrase “Phase I Environmental Site Assessment” is bound to come up, and if it doesn’t, it should, because it’s key to limiting your risk with the transaction.

What’s a Phase I ESA?

Phase I Environmental Site Assessments (Phase I ESAs) are studies that research the current and historical uses of a property. The intent of the study is to assess current or historical property uses impacting the property that could pose a threat to the environment and/or human health.  This research will help give insight if there’s a potential that you’ll be responsible for environmental issues found onsite.

Who Needs to Conduct a Phase I ESA?

  • Property Owners
  • Property Sellers
  • Banks/Lenders
  • Property Buyers

What Federal Regulations Impact a Phase I ESA?

EPA’s CERCLA (Comprehensive Environmental Response, Compensation and Liability Act), aka Superfund, gives the federal government the ability to respond to releases, or threated releases of hazardous substances.  It also gives them the ability to pursue polluters (responsible parties) or potential polluters (potentially responsible parties) for the cleanup of contaminated sites.  As a property buyer or seller, it’s up to you to do some due diligence and make an “all appropriate inquiry” into the environmental conditions of the site.

When you make that all appropriate inquiry, there are certain defenses allowed to protect yourself from CERCLA liability.

The Bona Fide Prospective Purchaser Defense allows a purchaser to first evaluate the property’s environmental conditions and assess potential liability for any contamination, then purchase the property with knowledge of hazardous substance contamination without incurring liability as an owner or operator.

The Innocent Landowner Defense is allowed if a purchaser “did not know and had no reason to know” that contamination existed on the property at the time the purchaser acquired the property, if a government entity acquires a property by escheat, involuntary acquisition, or eminent domain, or if a person acquired the facility by inheritance or bequest.

For the Contiguous Property Owner Defense, the property must be contiguous to a property that is or may be contaminated by hazardous substances from other property that is not owned by that person.

Another defense, the Brownfield Defense, can be used when a property is already assumed to have contamination, and it becomes a part of EPA’s Brownfields Program for economic redevelopment.

What’s Included in a Phase I ESA?

All appropriate inquiries must be conducted by an environmental professional and they include:

Site Visit

The professional will conduct a reconnaissance of the site to determine if there is a likely presence of hazardous substances or petroleum products, and if there is an indication a release or threatened release could have occurred.  The property’s exterior and interior structures are observed at this time.

Historical Research

Research of property records back to the property’s first development, or 1940, whichever is earlier is conducted.  This research includes inspecting historical aerial photographs, topographical maps, Sanborn Fire Insurance maps, street/city directory searches, building permits, planning records, title searches, and government records review.

Geology and Hydrogeology Studies – The environmental professional will look:

  • Soil types to determine the composition, texture, hydrologic group, and its drainage class.
  • Physical setting/topography of the property.
  • Groundwater depth and flow direction studies identify hydrologically upgradient source areas and risk of vapor intrusion and vapor encroachment.

Vapor intrusion occurs when volatile chemicals migrate from contamination in the soil or groundwater up into a building’s interior space. Vapor intrusion can be caused by contamination on-site or off-site from a property. A contamination plume can originate from an off-site source and migrate onto the property and underneath buildings. Vapor encroachment is a broader concern when compared to vapor instruction. Vapor encroachment is focused on the potential for vapors to exist within a building.

Interviews and Other Documents

The environmental professional will interview tenants, the current owner(s), and previous tenants/owners, and state and local regulators.  Any additional provided documentation such as previous Phase I ESAs, spill reports, state or local contamination reports, etc. will be reviewed.

Other Reviews

While an environmental professional is already conducting this research, the entity requesting a Phase I ESA may also want them to look at other sources for potential environmental issues.  The following items can also be included in a Phase I ESA, but are not a part of the EPA CERCLA regulation for sources of liability.

  • Asbestos-Containing Building Materials
  • Biological Agents
  • Cultural and Historic Resources
  • Ecological Resources
  • Health and Safety Issues
  • Indoor Air Quality (unrelated to vapor intrusion)
  • Industrial Hygiene
  • Lead-Based Paint
  • Lead in Drinking Water
  • Mold
  • Radon
  • EPA/OSHA/DOT Hazardous Materials Regulatory Compliance Items
  • Wetlands

Limitations of a Phase I ESA

Phase I ESAs are valid for 180 days.  Between 180 days and a year, the interviews, title search, government records research and visual inspection will need to be updated.  Any Phase I ESA over one year old is consider invalid and outdated and will need to be redone.

Phase I ESAs can reveal the likelihood of existing and/or past evidence of contamination, but they

  • Cannot prove that hazards are present;
  • Cannot ensure hazards or pollutants will not be discovered at a later date; and,
  • Cannot ensure landowners can avoid all responsibility.

Phase II Environmental Assessments (Phase II ESAs) involve further environmental sampling, including sampling of soil, water, groundwater and/or soil vapor to help better determine if contaminants are present.  If a recognized environmental condition is found from the Phase I ESA study, a recommendation for Phase II ESAs will often be suggested.

If you have questions about Phase I ESAs, or would like pricing to conduct one for your next property transaction, please contact us!

Need a Phase I ESA?

We can help you with your next Phase I or Phase II ESA!  Contact us today to get the conversation started.

Sarah Winfrey
Sarah Winfrey

Contributing:

Bria Weast

Environmental and Safety Consulting Manager

A member of our Consulting Services division, Bria works with client facilities for annual environmental reporting and day-to-day environmental compliance assistance.  She also manages iSi project managers.  Bria has conducted well over 100 Phase I environmental site assessments for iSi and is one of the trainers for our Hazardous Waste Management class.

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2020 ERG – Emergency Response Guidebook Updates

2020 ERG – Emergency Response Guidebook Updates

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The new 2020 version of the Emergency Response Guidebook (ERG) is finally out, and hard copies are now available.  The ERG is published every 4 years.

What is the ERG?

The ERG contains emergency response information and is a handbook used by emergency and hazardous materials incident responders, truck drivers, railroad personnel, pipeline personnel, pilots, police and firefighters.  It is written and updated by four separate international agencies:

  • U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Transport Canada’s Canadian Transportation Emergency Centre (CANUTEC)
  • Argentina’s Chemistry Information Center for Emergencies (CIQUIME)
  • Mexico’s Secretariat of Communications and Transport

iSi uses the ERG in our HAZWOPER training as well as our DOT Hazardous Materials Transportation, Hazardous Waste Management and RCRA Refresher classes.  This is because handling emergency spills are a component of all of these classes.

Updates

The four agencies have been working on this latest version since 2017.  In 2018, all of the agencies solicited input from their public through calls for comment, listening sessions, online surveys, and articles.  From these solicitations, 100 comments were gleaned to be considered for incorporation and DOT held a public meeting as well.  Since then, sub-groups worked on the updates.

Here is a list of the planned changes and items that were up for review within each section of the book. The agencies will:

White Pages [General Information, Instructions, Recommendations, Guidance]

      • Review content for use of plain language;
      • Improved quality of illustrations in charts for railcar and road trailer identification;
      • Add new lithium battery markings;
      • New terms in the glossary section;
      • Add a decontamination section; and,
      • Add basic information about heat induced tears (HIT).

Orange Pages [Response Guides]

      • Comprehensively review of all materials and their assignments in the orange pages by FEMA/NFA, with certain items up for review in 2020 while others will be reviewed before the 2024 version;
      • Distances in the Public Safety section are now in the Evacuation Section;
      • Created a new “How to Use the Orange Guide Pages” section;
      • Guide 121 Gases – inert was merged with Guide 120 Gases – inert (including refrigerated liquids);
      • Added CAUTION sentences for specific materials;
      • Clarify sentences;
      • Address inhalation concerns for petroleum crude oil (UN1267) in Guide 128; and,
      • Reevaluate radioactive materials guides with radiological/nuclear regulatory agencies.

Yellow/Blue Pages [Materials in ID/Name of Material Order]

      • Add or remove UN numbers to align with United Nations Model regulations and North American regulations;
      • Remove UN numbers for chemical warfare agents;
      • Reevaluated guide assignments for some materials; and,
      • Review polymerization hazards for certain materials.

Green Pages [Isolation and Protective Action Distances]

      • Add distances for new Poison Inhalation Hazard/Toxic Inhalation Hazard materials added by regulations;
      • Revise Table 2 introduction;
      • Add container capacities to Table 3;
      • Make a new border to differentiate between Tables 1, 2 and 3; and,
      • Argonne National Laboratory will update the Chemical Accident Statistical Risk Assessment Model (CASRAM) with outcomes from field and lab experiments.

Where Can the Current ERG Be Found?

A free PDF version of the current Emergency Response Guidebook is available online on the PHMSA website. There’s also a mobile app for the guide available for both Android and iPhone devices.    If you’d like to purchase a hard copy for your use, check out the iSi online store.

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EPA Reinforces State’s Authority Over Oklahoma Environmental Compliance

EPA Reinforces State’s Authority Over Oklahoma Environmental Compliance

A recent U.S. Supreme Court case regarding legal jurisdiction and Native American tribal lands has extended itself to environmental regulations compliance authority in the state of Oklahoma.

Native Lands Still Native

It all started when Patrick Murphy, a descendent of Native Americans, committed murder in 2015 within the Muscosgee reservation territory.  He argued to the courts that the Oklahoma Enabling Act of 1906 never disestablished the territories of the Five Civilized Tribes.   Because of this, he should have been prosecuted by federal courts and not the state of Oklahoma courts.  That is, the state courts should have no jurisdiction over Native Americans on federal reservations.  The 10th Circuit Court agreed with Murphy and it was ultimately appealed to the Supreme Court.  In 2020, the Supreme Court agreed that the territories had not been disestablished, giving more power to the tribes.

The territories involved in this case make up the eastern half and some of southern Oklahoma, including Tulsa.  The ruling means the state of Oklahoma would have no criminal jurisdiction over Native Americans within the reservations.  Federal regulations still need to be enforced within these lands and major crimes like murder would be charged federally, but the tribes could prosecute all other Native American crimes in their own courts.

The court ruling led to a lot of concern not only about the ramifications to major crimes committed in these territories, but the legal impact to environmental regulations, taxation and other regulations on reservation lands.

Oklahoma Petitions EPA

Seeing the potential for a wide variety of environmental rules being affected, the potential for inconsistent standards and efforts, and the overall impact to Oklahoma businesses, the Governor of Oklahoma wrote a request letter to EPA in July 2020.  In the letter, he asked that the state be authorized to continue to regulate environmental compliance throughout this territory.  The state agencies currently involved in overseeing environmental regulations are the Oklahoma Department of Environmental Quality, the Oklahoma Department of Agriculture, Food and Forestry, the Oklahoma Water Resources Board and the Oklahoma Corporation Commission.

On October 1, 2020, EPA approved this request and gave the state authority to continue its efforts in overseeing any of the programs it currently oversees in those areas.  EPA will continue to oversee the state of Oklahoma’s programs as it does in many states.

Tribal Reaction

The tribes are not happy with this decision.  Cherokee Nation Principal Chief Chuck Hoskin, Jr. said “[The governor’s decision] ignores the longstanding relationships between state agencies and the Cherokee Nation. All Oklahomans benefit when the tribes and state work together in the spirit of mutual respect and this knee-jerk reaction to curtail tribal jurisdiction is not productive.” [Taken from The Oklahoman, Oct. 6]

It’s unlikely this is the last we’ll hear of this issue.  The tribes may have a course of action to take EPA to court for not fully consulting with them prior to the decision per EPA’s Policy on Consultation or Coordination with Indian Tribes, or with the government-to-government consultation with affected tribes requirement per Executive Order 13175.

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What You Can Learn from Starbucks’ EPCRA Violations

What You Can Learn from Starbucks’ EPCRA Violations

In the EPA news releases recently there was a story about how EPA had settled fines with Starbucks for EPCRA 312 violations.  EPCRA violations??

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. For reporting, EPCRA has the Tier I, the Tier II , and the Toxic Release Inventory aka Form R.   Tier II can be found in Section 312 of EPCRA, and that’s the one that Starbucks violated.

Starbucks’s Violations

EPA found 2 Starbucks stores had not filed EPCRA Tier II forms when they should have for the years 2017 and 2018.  The stores were storing hazardous chemicals, including sulfuric acid.

The Starbucks case shows that even companies who you don’t typically associate hazardous chemicals with can still be required to report.  There are 800,000 chemicals on the list of hazardous chemicals and extremely hazardous substances that could apply, so many different types of companies can be affected.

Starbucks negotiated a reduced fine of $100,000, so the error of not knowing can also be very costly.

Does EPCRA 312 Apply to Your Facility?

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

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

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

Information to Collect

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

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

Reporting

Each state varies on how the information is reported and then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1, but now is a good time to determine if this applies to you and to develop a system to track quantities so that you’ll know what your final numbers will be at the end of the year.

EPCRA 311, 312 & 313 – Which One Applies to You?

We can help you figure this out.  Contact us today to get the conversation started.

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Annual Supplier Chemical Notification: Does This Affect Your Company?

Annual Supplier Chemical Notification: Does This Affect Your Company?

Recently EPA sent email reminder notices to companies who submitted 2018 and 2019 Toxic Release Inventories under EPCRA Section 313.  These reminders were about the regulation’s annual supplier chemical notification requirements for those companies who process or manufacture chemicals or chemical mixtures.

This annual notifications rule can be found at 40 CFR § 372.45.

Who Does This Affect?

  1. SIC codes 20-39 (or NAICS codes corresponding to those SIC categories), and…
  2. You manufacture (including import) or process a toxic chemical on the EPCRA Section 313 list, then…
  3. You sell/distribute that chemical under a trade name, or sell/distribute a mixture containing one or more of these chemicals.

Suppliers who are not required to complete a Toxic Release Inventory can still qualify for this rule.  They would still need to notify if they meet those 3 criteria.

The Notification

An annual notification must be sent with the first shipment of the chemical sent within the calendar year.  The notice needs to include the following information:

  • A statement that the mixture or trade name product includes a toxic chemical listed pursuant to EPCRA section 313 or 40 CFR Part 372;
  • The name and, if applicable, associated CAS registry number of each listed chemical, and;
  • The percentage by weight of each listed chemical in the mixture or trade name product.

The chemical notification can be a letter, a label or a written notice within the shipping papers.  It may accompany and be attached to the product’s SDS, but an SDS alone will not suffice if the SDS is missing the required notification information.  If your SDS has the required information on it, that can be used for the first shipment.  Then in subsequent years, a letter referencing the previous year’s SDS would suffice as long as the customer still has the most current version of your SDS.  If an SDS is not required for your chemical, you can send the notification on a separate written notice.

If you have any changes or updates to the information for the notice, you need to send out a revised notice within 30 days of that change.  If find that you had errors in your notice, you’ll need to send a revised notice listing the shipment dates that the new correct data would cover.

Exclusions

There are a few exclusions to this rule, including:

  • Not falling within those specific SIC/NAICS codes.
  • The chemical is a result of a chemical reaction from two or more chemicals mixed. You do not have to notify in this case because it would not be considered a mixture anymore.
  • If the chemical is prepared for consumer use, you don’t have to notify. However, if you prepare a version for consumer use in one type of packaging, but provide an industrial version in a different quantity or packaging, then you would have to notify.
  • The quantity of the toxic chemical is below the de minimis level (1% or 0.1% for OSHA carcinogens).
  • It’s a waste.

If your company does not fall within the SIC/NAICS codes or you just repackage the chemicals (not manufacture them), and you receive notifications from your suppliers, you should forward on those chemical notifications with the EPCRA Section 313 chemicals you send to users who would be covered under these codes.

Recordkeeping

You’re required to keep the following records for 3 years:

  • Notifications sent to recipients;
  • All supporting materials used to develop the notice;
  • If you are claiming a trade secret, a record of why it’s considered a secret and why the generic name you can use in your notification is appropriate; and,
  • If the concentration is a trade secret, record explanations of why it’s a secret and the basis for the upper bound concentration limit you’re allowed to use is appropriate.

More Information

More information can be found in the rule and in EPA’s Frequently Asked Questions about this rule.

Need Help?

If you need help determining how this new rule will affect you, or help with any environmental compliance issue, contact us today!

Questions?

Does this apply to your company?  Do you have questions?  Contact us!

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It’s “Basic” Environmental and Safety Training with iSi’s EHS Bootcamp Virtual Seminar

It’s “Basic” Environmental and Safety Training with iSi’s EHS Bootcamp Virtual Seminar

EHS bootcamp

More About EHS Bootcamp

Visit our EHS Bootcamp website to learn more about the agenda and to register!

Starting out, every day as an EHS professional felt overwhelming.  I started at this company doing one thing, but I inherited EHS duties somewhere along the way.  I didn’t have any formal training and I was wearing so many hats that I didn’t have a lot of time to search out training opportunities anyway.  Over the years I was able to sift through the complex language of the regs, enough to identify what we needed to do to stay compliant.  However, I always wished there was a course available to help weave through the madness. 

— Many EHS Professionals We Meet

Does this sound familiar?  We have worked with hundreds of EHS (environmental, health and safety) professionals over the years, and this is a story we hear all of the time.  Very few people go to college to become an EHS professional, but somehow they end up being one.  Safety regulations have a lot of standards to wade through and sometimes they tell you what you are required to do, or what they think you should do.  Environmental regulations can be a whole other animal, with lots of arms and legs and elbows and teeth.  In many cases available training is either pinpointed on a specific topic or is very generalized.  

That’s why iSi has developed our EHS Bootcamp.

What’s an EHS Bootcamp?

Our bootcamps deliver overview and compliance information about specific regulatory topic areas in 45 min-1 hour increments.  Within these sessions we explain what the reg is about, why it’s important, what the documentation requirements are and any other items you need to know about it.

We feel our EHS Bootcamps will be good for those who are new to the industry, those who have been in it a while and need a refresher, and those who deal with EHS regulations only on a limited basis.  

September 24 EHS Bootcamp

Our first ever EHS Bootcamp will be online on September 24.  We will have 2 tracks…an environmental track and a safety track with new topics every hour.    You can choose the sessions you want to attend as they happen.  So if you take care of both environmental and safety duties, you can choose from a mix of both sessions. 

As an introduction, we’re offering this event for of only $100 per ticket!  So if you have a conference that you were going to attend this fall that has been cancelled, think about attending this one!

Site-Specific EHS Bootcamps

We have many more presentations built and envision providing custom bootcamps to be held for individual companies. If this is something you’d like to see at your company, email us for more information.

We hope that our EHS Bootcamp will help you hone your professional skills and point out compliance issues you weren’t aware of.

Agenda

Check out the agenda below for our September 24 event!

EHS BOOTCAMP AGENDA — SEPTEMBER 24, 2020

All times listed in Central Time

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9:00am – 10:00am

Environmental Track: Hazardous Waste

Safety Track: Regulatory Inspection Process

}

10:00am – 11:00am

Environmental Track: Clean Air Act/Air Permitting

Safety Track: Chemical Inventory for Hazcom

}

11:00am – Noon

Environmental Track: Stormwater

Safety Track: Injury Reporting and Worker’s Compensation

}

Noon - 1:00 pm

General Session
ISO Certification: More About ISO 14001 and the New ISO 45001

}

1:00pm – 2:00pm

Environmental Track: Spills: SPCC and Contingency Plans

Safety Track: PSM and RMP

}

2:00pm – 3:00pm

Environmental Track: Wastewater

Safety Track: Electrical Safety

}

3:00pm – 4:00pm

Environmental Track: EPCRA and Emergency Planning

Safety Track: Developing an Industrial Hygiene Plan

}

4:00pm – 5:00pm

Environmental Track: DHS Chemicals of Interest

Safety Track: OSHA Emergency Action Plans

Marc
Marc

Contributing:

Marc Mason

Strategic Channel Manager

Marc is the leader of our sales and marketing team, and as a member of iSi’s family ownership group, he has been around iSi pretty much all of his life.  Besides business development efforts, Marc works with iSi’s departments and our clients to help find and implement new technologies for better efficiencies and client benefit.

Email  |  LinkedIn

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Workplace Safety Technology: T-Mobile for Business Adds 4G LTE HardHat and Contactless Temperature Device

Workplace Safety Technology: T-Mobile for Business Adds 4G LTE HardHat and Contactless Temperature Device

EHS Technology Solutions

iSi can help you find safety and environmental technology solutions to make your job easier.  Contact us today! 

T-Mobile for Business has added two new workplace safety technology products geared to make workplaces safer.  Each one also has features to help provide solutions related to recent concerns with workplace health.  The first product is a “smart” hard hat by Guardhat.  The other is a contactless temperature device for people entering crowded or confined spaces.  Both devices will take advantage of T-Mobile’s 4G LTE connectivity.

Guardhat

Guardhat utilizes sensors that let you know where the worker is at all times and what conditions they are working in order to analyze that data.  It also allows for audio and video communications so that you can see what they see and communicate back and forth with a central control center.

Some of the features include:

  • Location: Geofencing sensors track where Guardhat wearers are at, at all times.  Persons at a central control center can see where they are on a map.  Wearers can be alerted when they’re getting too close to hazards such as moving equipment, lockout/tagout areas, working areas like trenches or equipment drop zones and other dangers.   Sensors can be placed on all types of equipment and other assets so it can be tracked as well.
  • Communications: Guardhat wearers can communicate with the control center through voice and video capabilities.
  • Environment Monitoring: The hat will sense gases, noise, temperature and pressure issues and sound an alert until the worker gets to a safe location.   Persons at the control center will be able to use the camera on the hat and the locating sensors to help guide the worker to safety, if needed.
  • Physical Monitoring: The hat monitors vital stats and if it senses something is medically wrong with a worker wearing one, it will send an alert to other Guardhat users in the area and then will contact emergency medical services.
  • Fall Detection: The hat will sense when a worker has fallen and will alert other wearers in the area as well as emergency services.
  • Social Distancing: Location sensors can also be setup to ensure workers are working 6 feet from each other for social distancing purposes.

Guardhat is good for workers in areas with a number of hazards around them as well as workers who work alone in isolated areas.

PIMMAP Contactless Temperature Solution

The PIMMAP Contactless Temperature Solution is an 8-inch HD tablet that is an infrared camera and contactless temperature sensor.   It can be mounted to stands, kiosks or stations in places like schools, offices, arenas, factories, stores, hospitals, etc.

A person will stand in front of the device and it will use its infrared camera and facial recognition features to take temperatures at accuracy readings +/- 0.36 degrees F.   Facial recognition technology will also scan for signs of fatigue, watery eyes, and other flu-like symptoms.

Readings can be taken from 3-5 feet from the device and can scan 40 persons per minute.  An alert will come up on the screen if the temperature is too high.

The data for the device can be transferred to cloud servers and they can send push notifications.  They can also be worked on and troubleshot remotely.  If there’s no internet access where the device is located, it has its own 4G LTE router.

To learn more about these workplace safety technology devices, check out T-Mobile’s news release about them here.

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

Tami has been with iSi for over 24 years.  During this time, she has enjoyed helping promote regulations compliance awareness and education through her involvement with iSi Training and through leadership roles with industry conferences and professional organizations.

Email  |  LinkedIn

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Update:  2020 Final Rule Adds to and Clarifies OSHA Beryllium Standard

Update: 2020 Final Rule Adds to and Clarifies OSHA Beryllium Standard

Need Help?

iSi can do the sampling, write your plan, and help with any other part of this new requirement!

OSHA’s beryllium exposure standard for general industry, construction and maritime has been in place since May 2018, with various enforcement dates for different requirements.  Included below are the major highlights of the standard as well as 2020 Final Rule updates due to become effective on September 14, 2020.

There are a number of requirements for companies with potential beryllium exposures. Do these apply to your company?

What is Beryllium?

Beryllium is a lightweight but strong metal used in aerospace, telecommunications, information technology, defense, medical, and nuclear industries. It can be found in various items such as brake systems, missile parts, guidance systems, welding, alloys in dental crowns and bridges, laser devices, heat shields, computer parts, x-rays, golf clubs, bicycles and more. Exposure to beryllium comes through inhalation and through contact.

What’s Required in OSHA’s Beryllium Exposure Standard?

Exposure Assessments and Limits

If your workers are expected to be exposed to beryllium, you must conduct an exposure assessment using performance or scheduled monitoring methods. There are standards for exposures:

  • Permissible exposure limit (PEL) to 0.2 micrograms per cubic meter, averaged over 8 hours;
  • A short-term exposure limit (STEL) of 2.0 micrograms per cubic meter over a 15 minute sampling period; and,
  • An action level of 0.1 micrograms per cubic meter, calculated as an 8-hour time weighted average.

NEW (2020)   The definitions of a confirmed positive case (including a clarification of time requirements for abnormal or borderline test results) have been updated.  

Written Exposure Control Plan

If workers will be exposed to beryllium, companies must prepare a written exposure control plan. It doesn’t matter if you’re over the above limits – if you have the potential exposure, you need a written plan. The plan must include a list of operations and job titles affected, procedures for minimizing cross contamination and keeping surfaces clean, required engineering controls/practices to be used, respiratory protection methods, required personal protective equipment (PPE), and procedures for handling contaminated PPE, clothing and respirators. The plan must be reviewed annually, updated as required, and available for employee review.

PPE

Companies must provide respiratory protection where exposure cannot be controlled and personal protective equipment separate from street clothing must be provided to limit skin contact.   For protective clothing, change rooms and showers are to be provided and used. These rooms and showers must be in place by March 11, 2019.  There are specific rules for PPE

NEW (2020)   OSHA did not intend for beryllium-related PPE to be worn in areas outside of beryllium work areas.  Thus, it’s important for employers to determine what their beryllium work areas are, that is, where is there a potential for dermal contact and airborne impact and then act accordingly with PPE.  Employees who could reasonably be expected to have airborne exposure to and/or skin contact with soluble beryllium, beryllium solutions, or visible beryllium dust, fumes, or mists in concentrations of 0.1 percent by weight or more would be the ones affected.  OSHA also didn’t intend for PPE to be changed out after each individual work task and didn’t intended that residue be completely eliminated before entering eating and drinking areas, it needs to be “as free as practicable.”  They’ve made some word changes to clarify this.

Beryllium Work Areas

Engineering and work practice controls such as ventilation changes or enclosure must be developed to prevent excessive beryllium from becoming airborne. Engineering controls are due by March 10, 2020. In the meantime, beryllium work areas must be marked and have limited access. In construction, a competent person must be designated to mark these areas.

NEW (2020)   Some minor changes have been made in the Housekeeping section for disposal, recycling and reuse.  The rule’s requirements for disposal, recycling, and reuse do not apply to intra-plant transfers; more detail has been given as to what constitutes an appropriate enclosure; materials bound for disposal can be cleaned; and some minor wording changes have been made to this section and other sections to make them easier to understand. 

Medical Monitoring

Companies with beryllium exposures must offer medical exams to affected workers. If a worker has a beryllium-related disease, companies must offer additional workplace accommodations for the worker to protect themself from additional exposure.

NEW (2020)   OSHA has made clarifications regarding the specific timing on when employers are to have employees who may have been exposed to beryllium in an emergency get medical exams taken, depending on when their last exam was or if they’ve ever had one.  In another update, because exams at Chronic Beryllium Disease (CBD) Diagnostic Centers may take more than 30 days, OSHA has allowed for the initial consultations to be done within 30 days (including virtual/phone consultations) and then full evaluations within a reasonable time.  The employer must also be sure the employee is offered any tests deemed sufficient by the examining physician at the CBD testing center, and if not offered there, they should be allowed to be performed at a separate location mutually agreed upon by employer and employee. 

Worker Training 

Affected workers must be trained in the hazards of beryllium. This must be done separately from Hazard Communication training and be specific to beryllium.

NEW (2020)  Just as PPE pertains to those in beryllium areas, so does training.  Those are employees working in beryllium work areas and any other employees who may not be working directly with a beryllium-generating process, but who may reasonably be expected to have airborne exposure to and/or skin contact in concentrations of 0.1 percent by weight or more.

Recordkeeping 

NEW (2020)   In recordkeeping requirements throughout the standard, all references to collecting social security numbers have been removed.

Other 2020 Changes

  • Dermal and Airborne Contact, but Not Everybody:  Just like PPE and training have been clarified it’s only for those working in or could be reasonably affected by beryllium, medical monitoring, wash facilities and change rooms are also subject just to those persons who could be exposed.  References to dermal contact have been updated to also encompass airborne contact, but this change also helps narrow the requirements so that they don’t have to be in place for everyone in the facility.
  • Check out the complete 2020 final rule revisions and explanations in the Federal Register HERE.

Does This Apply to You?  We Can Help You Find Out

Are your workers exposed to beryllium? What are your exposures, which work areas of your company are affected, and do you have the necessary protections in place?   Let iSi conduct your monitoring to check. We can also help you with plans, PPE recommendations and training. 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.

Email  |  LinkedIn

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Industrial Hygiene in Construction: Focus Four Health Hazards

Industrial Hygiene in Construction: Focus Four Health Hazards

Recently the American Industrial Hygiene Association (AIHA) published results of its study of construction occupations and workers across 32 states regarding construction worker health.

For several years, there has been an OSHA Focus Four emphasis on physical safety (Falls, Electrocutions, Struck-By and Caught-In-Between).  However, at construction worksites, the focus on industrial hygiene in construction and worker health has consistently lagged behind. Besides Focus Four and equipment and tool safety, companies focus on zero injuries.  Health hazard exposures are just as common and can be harder to see because some may not arise until they become chronic.

As a result, AIHA has published a guidance document on a new Focus Four for Construction HEALTH Hazards including:

  1. Manual Material Handling
  2. Noise
  3. Air Contaminants
  4. High Temperatures


Manual Material Handling

Manual material handling is strenuous work that can cause overexertion. Repeated work day after day, vibration from tools and equipment or awkward positioning can cause musculoskeletal disorders (MSDs) such as back strains and sprains; arm and hand injuries; elbow and shoulder issues; and knee disorders. There are not many medical remedies for MSDs other than pain killers which can lead to opioid addictions.  Disabilities and early retirement can also arise.  MSDs are not cheap from a worker’s compensation perspective, taking 50% of all worker’s comp costs in construction.

AIHA says reducing these hazards will not only lower your costs, but help you retain your most experienced workers, help attract new employees, keep employees productive as they age and increase roles for women in the trades.


Noise

Exposures to noise can create either temporary or permanent hearing loss and other problems like tinnitus (ringing in the ears), sleep disturbance, impairment of balance, hypertension and cardiovascular disease. AIHA says a rule of thumb to use is that if you need to raise your voice to talk with someone an arm’s length away, the noise level will be over your 85 decibel limit. There are also many apps for your phone that can give an approximate noise level reading. Just remember these are not calibrated and can be off by several decibels. Those exposures at 85 decibels will cause damage over time, but construction tools and activities at 130-140 decibels will cause instant damage.

AIHA says hearing loss is the most common workplace illness in the U.S., and there is no cure for hearing loss or tinnitus.

Make sure you know what your noise exposures measurements are , know how to properly select and use hearing protection, communicate noise hazards, conduct hearing tests annually, train employees and include information about noise off the job. Better yet, find ways wherever possible to reduce noise exposures.


Air Contaminants

Air contaminants can include dusts, metal fumes, gases, vapors, solvents, and exhaust.    Odors are not always present, and those who “get used to the smell” may not know their overexposures to it.  For some contaminants, the fact that you can smell them means you’re already overexposed.

Contaminants can be inhaled or absorbed. Inhalation causes damage to the nose, throat and lungs causing damage and potential for asthma, breathing difficulties, lung scarring, COPD and lung cancer.  Absorption can cause blood, nervous system and organ damage.

This is another health hazard that may not be seen right away, but can arise later in an employee’s life, affecting quality of life.

This hazard can be reduced by pre-planning, determining:

  • Hazards of material to be used – what does the SDS say?
  • Amount used?
  • Duration used?
  • How will it be dispersed?
  • Confinement/enclosures used?
  • Controls used?
  • Ventilation and exhaust planned?
  • What PPE is needed?
  • Are respirators needed and do you have a proper respiratory protection program in place?
  • What are the occupational exposure limits allowed?

AIHA cautions that just because a task will be done for a short amount of time doesn’t lessen the hazard.


High Temperatures

Construction workers are susceptible to heat exposures due to the nature and location of their work.  Often things like PPE will add to the potential for problems.

Heat exposures play with the body’s ability to think clearly and act normally, so the worker may not speak up. That’s why it’s important for all workers, supervisors and foremen to be aware of the signs and symptoms of heat-related illnesses.

Proper training and planning ahead will help prevent major issues.  Make sure you look at things like:

  • Heat index
  • Experience and acclimation of worker (new or temp workers?)
  • How much work will be in direct sun?
  • Confined spaces
  • Additional heat sources (radiant heat/welding)
  • Physical workload
  • PPE to be used
  • Insulation and heat shields
  • Ventilation
  • Work schedules
  • Hydration, shade and break areas


In Closing

Although this article focuses on the construction worker, there is a lot that general industry workplaces can learn from this information too.

For more information about the Focus Four Health Hazards, check out the AIHA guidance document.

iSi’s team of industrial hygienists can help you with these issues and take care of the workplace and employee sampling that’s needed in several of these hazards.  Contact us today with your questions or to get a price quote.

Worker & Area Sampling

Let iSi’s industrial hygiene team help you determine what your workplace exposures are. Contact us today!

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

Tami has been with iSi for over 24 years.  During this time, she has enjoyed helping promote regulations compliance awareness and education through her involvement with iSi Training and through leadership roles with industry conferences and professional organizations.

Email  |  LinkedIn

Questions?

Does this apply to your company?  Do you have questions?  Contact us!

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Safety News Briefs: OSHA 300 Public, Tyvek Shortages, New Respirator Posters

Safety News Briefs: OSHA 300 Public, Tyvek Shortages, New Respirator Posters

Here are a few recent headlines from the world of safety:

Federal Judge Rules OSHA 300 Info is Not Confidential

A federal judge in the U.S. District Court for Northern California has ruled that OSHA injury and illness log information is not confidential.  The ruling comes as a part of a lawsuit where news organization the Center for Investigative Reporting made a Freedom of Information Act (FOIA) request to OSHA for records and OSHA denied the claim under FOIA exemptions for “law enforcement” and “trade secrets”.

The judge ruled that because employers are required to post this information annually and keep it on file for up to 5 years so that current and former employees can review them, these employees can freely share this information.  Thus, it’s readily observable and can be made public anyway.

The Center for Investigative Reporting was pleased with the ruling, saying that it would help keep the “dangerous” employers accountable and encourage them to improve safety while giving workers a better understanding of the risks involved in the job.

MSA Warns of Shortage of White Tychem, Tyvek 

Personal protective equipment company MSA Safety has issued a notice regarding a shortage of the white DuPont Tychem hoods used for powered air purifying respirators.  DuPont notified MSA that there would be shortages of white Tyvek, including Tychem, materials until early 2021.

MSA will be substituting white hoods with yellow Tychem hoods.  They say that the yellow Tychem is just as protective as the white.  However, some companies have policies requiring the white, and those policies may need to be altered for a while until the supply is restored.

Respirator Posters Available in 16 Languages

OSHA’s poster “Seven Steps to Correctly Wear a Respirator at Work” has now been published in 16 different languages.  These include English, Spanish, Arabic, Brazilian Portuguese, Chinese (Simplified and Traditional), French Creole, Hmong, Korean, Kunama, Polish, Russian, Somali, Tagalog, Thai and Vietnamese.

As many manufacturing safety managers know, most OSHA documents and posters are not printed in this many varieties, so this is a great time to get these for your workplace.  Find all of these for download at https://www.osha.gov/news/newsreleases/national/06152020-0.

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Questions?

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DOT Hazardous Materials Registrations Due July 1

DOT Hazardous Materials Registrations Due July 1

If your company ships or transports hazardous materials, including hazardous waste, you are required to register for a U.S. Department of Transportation (DOT) number. These registrations are due for renewal annually and the payments are due before July 1.

DOT registration fees are based on the nature and size of your company. You will need to know the primary NAICS Code for your company first. There are two tiers of company sizes: “small” and “large” based on number of employees and revenues. Small company fees are $250/year and large company fees are $2,575/year.

You can register by mail or online at https://www.phmsa.dot.gov/registration/online-registration.  Your company cannot transport hazardous materials until registered. If your company has failed to register for any previous years, you will need to register for any missed years and pay for those as well.

DOT has the option for your company to register for up to three years at a time.

If you are transporting hazardous materials, certificates of registration are required to be kept in your vehicle at all times. These will be required during roadside inspections. Failure to have one in the vehicle, or failure to have an updated certificate, could result in a fine of up to $37,500 per day.

In addition, copies of the certificates of registration are to be kept for three years at your place of business and must be available for inspection.

Fees that are collected from DOT registrations are used to pay for grants and state and Indian tribe programs related to hazardous materials emergency response planning and training.

If you need assistance in determining the DOT registration process applies to your company, or need help in completing the paperwork for this requirement, please contact us. Also, if your company is shipping or transporting certain types of hazardous materials or large bulk quantities (6,614 lbs. of solids or 792 gallons of liquid), you are required to have DOT Security Plans in place. iSi can help determine if this additional requirement applies to you, and help you prepare these plans as well. Please contact us for more information.

Need Help?

Need an extra hand to get this done?  What about required DOT training?

iSi can help you with DOT hazmat transportation compliance. Contact us today!

iSi Summer Safety Toolbox: Staying Hydrated

iSi Summer Safety Toolbox: Staying Hydrated

hydration safety toolbox

Dehydration can be a common cause of heat illness. Maintaining hydration is important, even if you don’t feel thirsty. Drinking water or electrolyte drinks are highly preferred to sugary and heavily caffeinated drinks. OSHA recommends drinking small amounts of cool water often before getting thirsty; 4 cups every hour during heat index values between 103°F – 115°F. Another recommendation is not to exceed 12 quarts of water per day.

An important reminder is that every person and situation is different. Some people require more water than others. These intake amounts depend on several things including the type of work being done, how much you’re sweating, and your personal risk factors. Don’t chug a large amount of water in the morning and call it good for the day; the important thing is maintaining hydration. You don’t flood your vegetable garden once at the beginning of the month and neglect it the rest of the month. If you do, you probably don’t have much of a harvest. Drinking throughout the day helps to better regulate core temperature and reduces strain on your cardiovascular system, keeping consistent body temperature.

It’s the supervisor’s duty to have a plan in place during days of extreme heat. If possible, rescheduling a job to a cooler day or even a cooler part of the day could make a difference. Getting a job done on time is important, as is maintaining client satisfaction. However, no part of a job is worth risking the health and safety of your team and clients should understand that.

It’s every person’s duty to watch out for themselves and their teammates. Providing cold water for your team is beneficial during hot days, as is having a first aid kit. If you have a first aid kit, kudos! If you don’t have a first aid kit, now is the time to get one. A few beneficial items to add to your first aid kit would be cold packs, cooling towels, electrolyte/salt tablets, or electrolyte powder drink mix. There are also specific first aid kits that can be purchased that include heat-stress care items.

Some symptoms of dehydration include:

  • Extreme thirst
  • Less frequent urination or dark colored urine
    Decreased sweating
  • Muscle cramps
  • Nausea, dizziness or confusion
  • Fatigue

If you’re a supervisor who would like some ideas on a heat safety plan or have questions on where to find quality first aid kits, contact us!

drew lyon
drew lyon

Contributing:

Drew Lyon

Project Manager | Meteorologist

Drew Lyon’s experience and training encompasses environmental reporting, day-to-day EHS compliance assistance at manufacturing facilities, wastewater compliance, hazardous waste management, environmental field sampling and safety. She is also a meteorologist, providing weather-related guidance to clients and our team.

Email  |  LinkedIn

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How UV Lighting Can be Used as a Disinfectant for Your Facility

How UV Lighting Can be Used as a Disinfectant for Your Facility

UV Light for Your HVAC

iSi can now provide disinfecting UV lighting for your HVAC system. UV light installations kill protein encased viruses, bacteria and mold.

UV lighting can be used as another tool in your safety and environmental arsenal to make your workplace safer and healthier.  But how does it work?

What is UVGI?

Ultraviolet Germicidal Irradiation, or UVGI, is a technology that goes back to the 1930’s with studies showing that ultraviolet light has the ability to kill or inactivate airborne microorganisms. These studies showed that an optimal wavelength of 265 nanometers (nm) was able to provide the largest reduction in airborne microorganisms. This was found to be very close to the wavelength produced by low-pressure mercury vapor lamps (254 nm).

Ultraviolet light can be broken down into 4 different bands:

  • UV-V: 10-200 nm
  • UV-C: 200-280 nm
  • UV-B: 280-315 nm
  • UV-A: 315-400 nm

The sun emits the full spectrum of ultraviolet light but only UV-A & UV-B make it to the surface.  The others are filtered out by the Earth’s atmosphere.  The UV-C band is the most effective at attacking the harmful microorganisms, so it needs to be generated artificially.

UV light spectrum

How does UVGI work?

UV-C wavelengths are readily absorbed by the DNA and RNA of microorganisms such as germs and mold.  When absorbed, UV damages their DNA or RNA structure, preventing the microorganism from replicating. The magnitude of their reduction is affected by their resistance to UVGI, the quantity of UV energy delivered, and the type specific microorganism being irradiated.

UV light

Wall-mounted UV light system.

Disinfecting light is delivered in two common methods. The first is by placing light units, either with or without fans, near the top of a room close to the air vents in order to clean the air as it circulates the room.

The second method is to place the unit directly into the heating and air conditioning (HVAC) system. This second method places the light in a location where the room occupants are not directly exposed to the light, and if placed correctly, can have an added advantage of cleaning the HVAC coils and drip pan to improve the efficiency of the HVAC system.

iSi light frame

UV light for HVAC system.

The design and placement of these different systems are governed by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) which has published many documents on the subject.

UV Safety Considerations

UV-C band light is a safer band than the UV-A and UV-B that we deal with in nature. We have always been taught to apply sunscreen and wear sunglasses to protect ourselves from the burns we receive when outside. Due to the shorter wavelengths UV-C will only penetrate the outer skin layers and along the surface of the eye. It will not give you the severe sun burn the longer wavelengths will. It will cause a reddening and slight irritation of the skin and an painful itching sensation that will last a few days in the eye so slight protection is required if you are directly exposed to the light from these units.

UV Lighting for Your HVAC Units

iSi is now providing the second method UV germicidal lighting, the one for your HVAC system.  Our units are customized to your specific HVAC system and area to be disinfected.  Learn more about this service and get a quote here.

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.

Email 

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COVID-19: A Potential OSHA Recordable Illness

COVID-19: A Potential OSHA Recordable Illness

UPDATED 5/22/20

Recently published guidance from OSHA clarifies that workplace-contracted COVID-19 can be a recordable illness.  That is, a recordable if it was contracted as a result of work duties.

Illnesses such as the flu and colds have always been, and continue to be, exempt from recordable illnesses recordkeeping.  However, COVID-19 is NOT exempt from being a recordable, even though it contains some of the same symptoms as the flu and cold.

When COVID is Recordable

Use the following guidelines when determining if a case of COVID 19 is a recordable illness:

  • Is confirmed as a coronavirus illness,
  • Falls under one or more of the typical recording criteria such as medical treatment beyond first aid, hospitalization, or days away from work, and
  • Is work related as defined by 29 CFR 1904.5.

Determining if it’s work related will take some investigation on your part as there’s a possibility that exposures can occur outside of work as well. OSHA expects employers to make reasonable efforts, based on the evidence available to make that determination.  A best practice is to ensure you have documentation of your investigation, including all the steps you took to come to your findings, and what led you to choose why to count or not count that illness.

Like with other recording requirements, companies with 10 or fewer do not need to make a recording unless it is work related and results in a hospitalization, amputation, loss of an eye or a fatality.

Have a Plan

Some workplaces and worker tasks are considered to have a higher risk for employee exposure.  Most workplaces will have a low exposure risk.  Those in healthcare, death care, airline, border protection, solid waste management and wastewater treatment are considered to be in the high risk category.  Workers who are required to work within 6 feet of each other would fall in the medium risk exposure level because the virus is spread through person-to-person droplet contact within that 6-foot range.

As a result, OSHA says it is important for workplaces to take measures to prevent the spread of COVID-19 and have a plan for dealing with it.  OSHA’s guidance specifically says there is currently no standard that covers COVID-19, but it would fall under the General Duty Clause that requires employers to provide workers with “…a place of employment which is free from recognized hazards that are causing or likely to cause death or serious physical harm.”  They also mention the PPE standards (1910 Subpart I) which covers usage of gloves, eye protection, face protection and respirators and the Bloodborne Pathogens standard (29 CFR 1910.1030) which covers exposures to body fluids and blood.

Respirator Usage

Depending on work tasks and potential exposures, workers may need to wear masks, goggles, face shields, and/or respirators.  In the guidance document, OSHA says that workers, including those who work within 6 feet of patients known to be, or suspected of being, infected and those performing aerosol-generating procedures, need to use filtering facepiece or better respirators.  Remember that if your workers are wearing respirators, you must have a comprehensive respiratory protection program that has its own complete set of requirements.  You can find the respirator standards at 1910.134.

Hierarchy of Controls

OSHA’s guide contains ideas for identifying and isolating sick people, where appropriate.   OSHA also draws on the Hierarchy of Controls, just as it does for all other safety concerns.  For example:

Engineering Controls

  • High-efficiency air filters
  • Increased ventilation rates
  • Negative pressure ventilation in areas where aerosols are generated

Administrative Controls

  • Encouraging sick workers to stay home
  • Virtual or teleconferenced meetings rather than face-to-face
  • Alternating days or extra shifts to reduce the number of employees in the building, increasing work distances
  • Discontinuing non-essential travel
  • Emergency communication plans
  • Worker training

Safe Work Practices

  • Promote personal hygiene with tissues, no-touch trash cans, hand soap, alcohol rubs and wipes, disinfectants and disposable towels
  • Required regular hand washing or alcohol hand rubs, especially after removing PPE
  • Post handwashing signs in restrooms

PPE

  • Select based on hazard to the worker
  • Ensure proper fit and refit
  • Consistent and proper wear
  • Regular inspections
  • Regular cleaning, maintenance and repair
  • Proper storage and disposal

OSHA says PPE recommendations are likely to change depending on location, current PPE effectiveness and the nature of the job, so check in with OSHA and the CDC website for updates on recommended PPE.

Resource Links

OSHA has a dedicated webpage covering COVID-19 and they have published a guidance document in conjunction with the Department of Health and Human Services.  Both of these address measures on how to protect workplaces and workers at low, medium and high exposure risks and those who work in the specifically targeted high risk industries above.  Below are links to resources for COVID-19 planning and information:

OSHA and DHHS Guidance on Preparing Workplaces for COVID-19

OSHA COVID-19 Website

CDC COVID-19 Website

EPA’s List of Registered Antimicrobial Products for Use Against Novel Coronavirus SARS-CoV-2, the Cause of COVID-19

Need Help? Have Questions?

Do you need help pulling together a plan?  Do you have all the other pieces in place?  Let us help!

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COVID Complaints: Will You Be Inspected by OSHA?

COVID Complaints: Will You Be Inspected by OSHA?

​Updated 5/22/2020

With tensions somewhat high about the COVID-19 pandemic, OSHA has experienced quite an increase in the number of whistleblower complaints from workers. As a result, OSHA has published some enforcement guidance to their inspectors on how to handle these complaints.

Employee Complaints

OSHA complaints over the past few months have centered mostly on two issues. One, a lack of PPE such as respirators, gloves, gowns, etc. The other is on the lack of training a company may have given their employees on the standards and COVID in the workplace.

OSHA Puts Employers in One of 3 Risk Groups

High Risk

These are medical-related facilities with a high risk of coming into contact with the virus. These could include hospitals, emergency rooms, medical centers, nursing homes, postmortem facilities, or labs.

Medium Risk

These facilities have high contact with the general public or are densely staffed so that it would be difficult to maintain a 6 ft. distance. Facilities with contact with international travelers would also fall into this group. Some examples would be airports, high retail, schools, and any other business tightly crowded.

Low Risk

These facilities have little contact with the general public and don’t provide a lot of frequent close contact where it’s not a problem to maintain a 6 ft. distance.

Inspections 

Originally, only the High Risk category of facilities were planned for inspection unless something drastic happened in one of the other facilities, such as a COVID-related fatality. This is because the resources of OSHA are limited and there was a concern by OSHA to keep inspectors safe and healthy themselves.

However, there was backlash to this policy from union and industry groups, prompting OSHA to modify it to add the possibility of conducting inspections at other facilities.  Starting May 26, 2020, inspections will be determined based on the following:

  • In geographic areas experiencing sustained elevated community transmission or a resurgence in community transmission priority will be given to high risk facilities mentioned above.  Priority will also be given to workplaces with high numbers of complaints or known COVID-19 cases.
    • Where resources are not available, OSHA will initiate the inspection remotely with the understanding that an inspection will be conducted onsite when the resource becomes available.
    • OSHA will develop a program to conduct monitoring inspections from a random sampling of fatality or imminent danger cases where inspections were not conducted because of low resources.
    • Use non-formal/fax/rapid response investigation in industries where doing so can address the relevant hazard(s).
  • In geographic areas where community spread of COVID-19 has significantly decreased:
    • Fatalities and imminent danger exposures related to COVID-19 cases will be prioritized.
    • OSHA will use non-formal/fax or rapid response investigations (send a letter) when possible to ensure effective use of resources, especially in medium and low risk facilities.  However, it’s up to the Area Director’s discretion to conduct an onsite inspection in these cases.

What to Expect in an Investigation Letter

OSHA will inform you of the complaint that has been made, and it will be your company’s responsibility to:

  • Investigate the complaint
  • Determine results and respond by a certain date

  • Provide backup documentation of your investigation

  • Provide corrective actions taken or to be taken

  • Provide backup documentation of corrective action

  • Post the letter

  • Sign a certificate that you posted the letter

If you do not respond to the letter, then you may get inspected. The employee who made the complaint, requesting OSHA do an inspection will receive a copy of OSHA’s letter to you and will be advised of your response.

For more details, check out the inspector enforcement memorandum on OSHA’s website.

Return to Work

Check out our new Return to Work resource page for related articles and services!  

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Return to Work Building Issues: Stagnant Water

Return to Work Building Issues: Stagnant Water

Legionnaires, Heavy Metals Among the Hazards That Could Affect Your Building’s Water System Safety

As we all prepare to return to work, we may find additional hazards lurking in our buildings if they have been closed up or have had limited occupancy due to stay at home orders. Building water systems that have been sitting stagnant can have depleted disinfectant levels. This leads to increased bacteria and biofilm levels inside the system. It can also show increased levels of corrosion products such as iron, lead and copper depending on what your pipes are made from.

Water System Safety:  Environmental and Safety Hazards of Stagnant Water

As water sits unused in pipes, the disinfectant normally found in water (typically chlorine, but check with your water service to see what they are using) depletes to a point where a biofilm forms inside the pipe. This biofilm then grows and when the system is turned on water droplets can become airborne and inhaled causing many illnesses that can affect the lungs such as Legionnaires’ disease. Water that has sat in pipes also increases the amount of corrosion products from the piping itself and can lead to increased levels of metals in the water, depending on what your plumbing is made from. These increased levels can be ingested from various sources within a company such as drinking fountains, ice machines, plumbed coffee systems, water softeners, improperly maintained water heaters, on demand water heaters and dishwashers.

Water System Safety:  Have a Plan to Deal With the Stagnant Water dirty water in faucet

Before buildings are reopened, a plan should be established to flush out the contaminates in your building’s entire water system. This flush should go all the way back to the main line from the municipality. You may need the assistance of a plumber or water engineer to properly determine the size and length of the pipes so the proper volume of the water system can be calculated.

Once known, the volume will then determine the length of time the system will need to flow. In some cases, this could require over an hour of water flow. Be sure to pay special attention to any dead spaces in both the hot and cold-water systems. Remember, this water can be contaminated with bacteria that may cause respiratory issues and the hot water may be hot enough to cause burns so be sure to include proper safety equipment in the plan if doing large scale flushing.

Water System Safety:  Clearance Testing

Once the system has been flushed, testing can be done on the water to determine if it meets the standards established by the Environmental Protection Agency (EPA) for Primary Drinking Water. Those standards can be found at https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations. If you are interested in the USEPA’s Lead and Copper Rule a Quick Reference Guide can be found at https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt.

If you need assistance in determining the safety of your buildings water system, please contact iSi.

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.

Email  |  LinkedIn

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Bleach Safety

Bleach Safety

With the spread of COVID-19, businesses and households are looking for ways to clean and sanitize surfaces, and bleach is one of those cleaners that experts have deemed acceptable.  Before you begin, please review these bleach safety tips to ensure you and your workers are protected:​

Uses for Bleach

Bleach can disinfect which means it is effective at killing most bacteria, fungus and viruses but the surface needs to be clean of dirt and grime beforehand. If needed clean the surface with soap and water before disinfecting.

Cleaning refers to the removal of dirt and impurities, including germs, from surfaces. Cleaning alone does not kill germs. But by removing the germs, it decreases their number and therefore any risk of spreading infection.

Disinfecting works by using chemicals to kill germs on surfaces. This process does not necessarily clean dirty surfaces or remove germs. But killing germs remaining on a surface after cleaning further reduces any risk of spreading infection.

The Centers for Disease Control & Prevention (CDC) recommends the following concentrations for disinfection of hard surfaces:

  • 5 tablespoons (1/3rd cup) bleach per gallon of water
  • 4 teaspoons bleach per quart of water

Remember to always add bleach to water and not water to bleach.

Personal Protective Equipment 

Bleach is a corrosive, meaning it will burn skin, so it needs to be kept off skin and out of eyes. So always wear the following when mixing and using bleach.

  • Nitrile gloves
  • Safety glasses or chemical goggles
  • Long sleeves
  • Pants
  • Covered shoes

Always wash your hands with soap and water after working with any chemical but especially before eating, drinking or smoking.

First Aid

  • Eyes: Hold the eye open and rinse slowly and gently with water for 15 to 20 minutes, or for the time the manufacturer recommends. Remove contact lenses, if present, and continue rinsing the eye. Call a poison control center, emergency services, or a doctor.
  • Skin: Remove the contaminated clothing. Rinse the skin immediately with plenty of water for 15 to 20 minutes, or for the time the manufacturer recommends.
  • Inhaled/breathed in: Move the person to fresh air. If breathing is affected, call a poison control center, emergency services, or doctor.
  • Swallowed: Call a poison control center, emergency services, or doctor. Do not try to get the person to vomit unless told to do so specifically by a medical professional. Do not give anything by mouth to an unconscious person.

When providing first aid or when helping another person, be careful not to come into contact with the bleach yourself. Use protective clothing when necessary.

Hazards of Mixing Bleach

Don’t mix bleach with ammonia, acids, or other cleaners. Mixing bleach with common cleaning products can cause serious injuries. Be sure to always read the product label before using a cleaning product.

iSi works with companies to help them with safety and industrial hygiene issues.  Contact us if you have questions about industrial cleaning issues, using bleach or any other industrial disinfectant.

dont combine these bleach products

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.

Email  |  LinkedIn

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12 Tasks for Safety Managers Working From Home

12 Tasks for Safety Managers Working From Home

Many in the U.S. are under stay at home orders, encouraged to work from home where possible. Although many manufacturing facilities are considered essential and still open, safety managers and their support staff do not always need to be onsite. With your routine disrupted, this may actually be a great time to accomplish safety projects that your normally crazy busy days do not allow you to do. Here are 12 ideas for tasks that safety managers working from home can do themselves, or can assign to their safety team members to keeping teams busy and productive during this time:

1. Develop Your Pandemic Plan

What better time than now to develop a plan for dealing with a pandemic? What actions did your company take? What has worked and what didn’t?  As a contractor, a number of clients have asked to see our plan.  What will you do about your own vendors and contractors next time? What about visitors? Read our article on pandemic preparedness plans to get some ideas on how to get started.

2. Review/Develop Cleaning Procedures

The events of the past month have shown a spotlight on the way we handle the spread of germs from person to person.  What are your procedures for cleaning and disinfecting respirators? What about your other personal protective equipment? What are the proper protocols? How often should they be cleaned? What cleaning products are EPA-approved and most effective on the PPEs’ materials?

3. Review Your Emergency Plans

We are entering wild weather months of spring and summer. How would your company deal with the effects of tornadoes, floods, wildfires, hurricanes, hail storms, high wind events, heat waves, etc.? What are your business continuity plans if one of these events would occur at your facility? How would you be affected? Electricity powers the lights, your computers, and your machines. What would you do about electrical service interruptions? Did you know that there are EPA regulations for emergency power generators? What other regulations would come into play?

4. Review Your Written Safety Programs

Written safety programs need to be reviewed on a regular basis, and some of them actually have OSHA rules about how often they are to be reviewed. Take a look at all of your plans. What do they commit you to doing, and is your company doing what it says you are supposed to be doing? Who else in your company is affected by these programs and needs to review and be aware of what they require? Remember that if it’s in writing that your company will do it, you will be held to that in a regulatory inspection. Are your programs compliant with OSHA standards?

Are you missing a plan? Visit SafetyPlans.com to purchase one you can edit and expand upon.

5. Take Advantage of Web Conferencing for Safety Training

Many companies have been using web conferencing software to hold online meetings or to just check in with each other. Take this time to get some of your general safety training out of the way. You could do weekly toolbox meetings or even longer sessions. Just make sure that you document what was held, on what date, who was the trainer, and who attended. You could even take a screenshot of the online attendees list, or a screenshot of the webcams of the persons in attendance to add to your documentation.   iSi can help you facilitate/setup this training, request more info here.

6. Spruce Up Your Training Materials

Speaking of training, now’s a good time to look at the training materials you’re using and consider giving it a refresh. Is the training still current and within the regs? Are the people in your videos dressed like characters from the 80s? At the very least, does your Powerpoint need a new look and some new pictures?

7. Write your RFPs

What services and products will you be needing for the rest of the year? Does your procurement/purchasing department require you to help them develop solicitations? Now would be a great time to knock out scope of work development, writing descriptions of what you’re going to need and developing the criteria for what information you want to see back from your vendors’ responses. Instead of waiting later when the RFP will go out, do this part now because you know you’re likely to be swamped later and won’t have the time to put much thought into it.

8. Get Quotes for Services and Products

If you already know the products and services you’re going to need, even if it’s later in the year, go ahead and approach your vendors now. It’s likely they’re working from home too, and with business slowing for everyone, now is a good time for them to work on pricing and proposals. With the uncertainty in the business climate, you may even get better pricing if you ask for it now than you would later when business will be catching up. Make sure you let them know what time frame you’re going to need it, and then ask vendors if they’ll hold that pricing until then. Get a quote from iSi.

9. Develop a Presentation for a Local Organization or Conference

Local safety organizations, safety conferences and civic groups are ALWAYS looking for speakers and presentations. The most popular highlight real-world safety management ideas, tell stories on how you have solved a problem that other EHS managers likely have faced, or just share how handle a particular part of compliance. For civic groups, use your knowledge of general safety principles and find a topic that may apply to all types of businesses and business owners. Speaking to a group or professional event is also a great way to get publicity for your company and yourself as a professional in the community.

Read our article The Importance of EHS Organizations and Conferences to Your EHS Compliance.

10. Research Products and Services That Will Make You More Efficient

Once everyone is back to work, it’s likely your budget will be strained, labor may be stretched, and you’ll have to do more in order to catch up. Now is a good time to find products or services that will help make you more efficient and save money in the long run. Try out new software, get samples of products, and find resources that can give you assistance to help you make up for gaps in staffing. Now is the time to round up the tools for your toolbox that you may need to use later.

11. Permit Reviews

If you have them stored electronically, take a look at completed lockout/tagout and confined space entry permits. Were the requirements of the permits fully executed and documented

12. Clean Up Your Email

How many times have you gotten the notice that your email boxes are full and it has been at the worst time you could’ve gotten that message? Go through your inbox and delete what you do not need anymore and read what you may have missed. Don’t forget to go through your sent items too. If you find you are not making much headway in creating space, sort your messages by size. This will allow you to uncover those emails with the 50 MB attachments that you don’t need anymore.

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Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

Tami has been with iSi for over 24 years.  During this time, she has enjoyed helping promote regulations compliance awareness and education through her involvement with iSi Training and through leadership roles with industry conferences and professional organizations.

Email  |  LinkedIn

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Creating a Pandemic Preparedness Plan for ISNetworld or for ANY Company

Creating a Pandemic Preparedness Plan for ISNetworld or for ANY Company

If you are a contractor to large refineries and manufacturers like we are, you are likely a member of one or more safety oversight companies like ISNetworld. Recently clients have been asking contractors to upload a Pandemic Preparedness Plan for ISNetworld, in response to the COVID-19 outbreak. Other non-ISNetworld clients may have also been doing the same, or you as a safety professional may have been thinking about what your company should develop. Using ISNetworld’s program questionnaire can help any company determine what should be included in a plan and give a place to start.

The following are the topics covered by the questionnaire for the current Pandemic Preparedness Plan for ISNetworld. Even if ISNetworld doesn’t apply to you, this may give you some ideas for best practices:

1.  Assignment of Ownership

Who is going to be in charge of carrying out the plan? Who is on that team and how is it decided?

2.  Hand Washing Facilities, Cleansers and Other Hygiene Items

What hand washing facilities will be available to your employees? What other sanitizing products will be available (i.e., hand sanitizers, disposable towels, etc.). In this section you could also cover personal protective materials to be provided as well.

3.  Periodic Training

Periodic training should be conducted regarding illness prevention and spread of disease. It should also communicate your policies regarding illness. At what frequency will they be conducted, and who will do (or be responsible for) that training.

4.  Work From Home Policy

What is your company policy regarding working from home, or staying at home when an employee is ill or taking care of an ill family member.

5.  Continuance of Operations

What is your company’s strategy for continuing operations if a large percentage of your staff becomes ill? What’s your plan for maintaining operations during quarantine or stay at home orders?

6.  Immunizations

Does your company encourage employees to get proper immunizations? 

7.  Communications

How are employee and internal communications conducted? 

8.  Gatherings

Does your company limit large or crowded gatherings during outbreaks or increased disease levels? What does that look like?

9.  Cleaning

What is your strategy for cleaning workplace surfaces and equipment?  

10.  Reviews and Testing

How will this plan be tested? How often will it be reviewed? Who is responsible for doing so?

11.  Lessons Learned

What is your process for implementing lessons learned? How will that be done, and who will do it?

Writing the Plan

Hopefully this gives you a start on creating your own Pandemic Plan. If you do not have the time nor the labor right now to do this, let us help! We have written these Pandemic Preparedness Plans for ISNetworld compliance and for our own company.  Contact us today for pricing!

Save Time With Our Template!

If you need help getting started, we have a template plan for you to purchase for $100.  Click below to buy and download this Microsoft Word document now.

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EPA Enforcement During COVID-19 Disruption: What Do You Need to Do?

EPA Enforcement During COVID-19 Disruption: What Do You Need to Do?

UPDATE:  EPA has announced they will be ending these policies on August 31, 2020.

The COVID-19 outbreak is affecting businesses — from creating labor challenges to shutting them down altogether. As a result, you may not be able to meet your EPA or state environmental obligations. During this time, what is EPA doing about enforcement?

EPA has issued a guidance document on how it will conduct enforcement for noncompliance. Basically, the overall message is to communicate, document-document-document and do your best to make a good faith effort to comply.

EPA is leaving discretion to the states on how they want to handle noncompliance. So although in this article we are going to cover what EPA says (and what iSi’s experience has been with state agencies lately) ALWAYS double check with your state or your permitting agency because what they say will be the overall direction you will need to follow. Better yet, keeping in contact with your permitting agency and alerting them of potential noncompliance is likely the best policy because if their policies differ, they will be able to tell you so. Always document your conversations or communications for your files.

Overall EPA Guidance

EPA wants your company to make every effort to comply, but if you cannot,

  • Act responsibly until you can;
  • Identify the nature of what your noncompliance will be, on what dates, and the reasons why COVID-19 was the cause;
  • Document the steps you are going to take to become compliant,
  • Work to become compliant ASAP; and,
  • Document all actions and reasons and keep those in your files.

EPA understands that staffing may be limited and resources like contractors and laboratories may affect your compliance status. So until further notice from EPA, they will not be penalizing the following actions if they agree with you that COVID-19 was the legitimate cause of your noncompliance:

  • Monitoring
  • Sampling
  • Lab Analysis
  • Integrity Testing
  • Reporting
  • Certification
  • Training

Although training is on that list, EPA says they expect you to maintain your training certifications as there are a number of online alternatives available. An example where they would excuse noncompliance is if you needed to make a choice between having certified and qualified operators running your operations vs. sending them to training. They would prefer you to keep operations running if that was the only choice you had.

Resume bi-annual and annual reporting as soon as possible and submit late reports as soon as possible. If your report requires a handwritten signature, it can be digitally signed. If you miss a sampling or monitoring episode, you will not need to make it up later if it is typically conducted in intervals of 3 months or less.

Hazardous Waste

If possible, continue to conduct your weekly inspections. If you have containers onsite that will exceed the number of days you can store them, such as a 90-day storage limit, continue to properly store and label them until you can get them removed. EPA will not consider you a TSDF (treatment, storage and disposal facility) if you go past the date. If you are a Small Quantity Generator or a Very Small Quantity Generator, you will retain your generator status if you go past the date.

Ensure you document everything and put it in your records.

Air Emissions

Get very familiar with your permits and what they say about notifications during shutdowns. In some permits, there may be a reference to emergency episode plans that typically address equipment failures, but see if they say anything about temporary shutdowns. Some permits may also mention that temporary shutdowns may cause less emissions during shutdown, then exceedances when the equipment is refired. You may have to give a notification in both instances.

If you cannot find anything, double check with your permitting agency and then document any phone calls or emails. Self-reporting shows good faith efforts on your part.

Wastewater

Every permit may be different, so check what yours says about shutdowns. Many permits will mention that you must notify if there will be a “significant change,” and a shutdown would be a significant change. You will likely need to continue doing weekly inspections and sampling. For shutdowns over extended periods, when you return to service, you may need to do weekly sampling for a set term to prove you’re in compliance.

When any part that is covered by your permit is removed from service, you’ll need to notify the permit authority to ensure the water and the environment is protected.

Stormwater 

Stormwater regulations vary from state to state and in some areas, city to city. Most will have quarterly inspections and rain event sampling. Continue to do that whenever possible. If you cannot, contact your local stormwater authority and/or document the reasons why this cannot be accomplished.

Spill Prevention, Control and Countermesure (SPCC)

Most SPCC plans require monthly inspections. Continue to do these, and if for some reason you cannot, document the reasons why.

Public Water Supply

For those who operate public water supplies, it needs to be run business as usual. EPA has specifically called out this operation as critical to public safety and health. If you are having staffing or laboratory issues, you need to work with your state to get these issues solved.

Accidental Releases

If you have an accidental release or an equipment failure that causes an exceedance which can affect the environment, this needs to be handled business as usual as well. You need to stop the release, mitigate the affects of it as quickly as possible, and still make all the necessary notifications.

Questions?

If you have questions about what you need to do, or need us to help while your own staffs are short, please contact us!

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Electronic EHS Training: Maintain Certifications, Complete Requirements Now

Electronic EHS Training: Maintain Certifications, Complete Requirements Now

With stay-at-home orders mandated in many states, counties and cities across the U.S. due to the COVID-19 breakout, business operations have been dramatically affected – including environmental, health and safety training (EHS training).  Unless otherwise noted by regulatory agencies, compliance requirements are still required to be followed.  To help our clients stay compliant for the duties they’re performing iSi has electronic training options to help you make sure you maintain your certifications. 

With many business operations disrupted, this may actually be a very good time to get your required training taken care of for the year.

Viewing Options — How It Works

iSi can provide electronic EHS training in a number of ways.  One interactive option is our live instructor-led training that’s given through web conferencing.  Our online system allows for students to view slides and the instructor, ask questions both via audio and privately in a questions window, chat with other students in a chat room, respond to polls, download handouts, and take notes within the system that they can have emailed to them.  This provides interactive learning and because it’s live, questions can still be asked of the instructor. 

Need to watch at your convenience? iSi also has the ability to record presentations through the system and provide you a link so that your workers can watch on their own time.  These two options may be the best for training conducted now, but we provide longer term solutions such as slides with voiceover that can be used at your own schedule, produced videos, and even online modules with tests that can be imported into your learning management system.

March and April Scheduled Classes Moved Online

We currently have moved our scheduled March and April DOT and RCRA training classes online in order to help those registered stay certified.  DOT is especially strict about letting workers sign off on hazardous materials shipments past training deadlines, as it’s forbidden.  We have the following classes available for registration:

DOT Refresher:  March 27
DOT (Initial Training):  April 23-24
RCRA Hazardous Waste Management Refresher:  April 17

Our asbestos classes were not able to be moved to online methods due to our licensing requirements with the state of Missouri.  They do not allow electronic training alternatives.

Other Classes Available

iSi can provide a variety of other electronic EHS training classes covering OSHA general safety, EPA compliance, and DOT, IATA and IMDG hazmat shipping.  Contact us today to see how we can help you and maybe take care of some of your EHS training over the next few weeks. 

Complete Your EHS Training Now

Which courses can we prepare for you?  Contact us today!

Questions?

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The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

With all things COVID-19 impacting our businesses, researching immediate actions to understand their impacts is critical. Some companies may feel the pressure and immediate need to “clean” everything. However, it’s important to know which cleaning compounds work in what situations, the impact to the materials they’ll be cleaning, their composition, the application methods required by the label and the potential hazards they may cause those workers applying them and working around them.

Most businesses are considering decontamination strategies where it makes sense. In some cases, this might be at the janitorial level, and in other cases, it might be more of an industrial solution involving the production floor, manufacturing processes and even potential products that need to be disinfected/sanitized.

EPA-Approved Products

Some definitions to understand:

Cleaning is the removal of dirts, soils and impurities from the surface.

Sanitizing is meant to reduce, not kill, the occurrence and growth of bacteria, viruses and fungi (typically reduces bacteria on a surface by 99.9%).

Disinfecting a surface will “kill” the microscopic organisms as claimed on the label of a particular product. … The minimum level of effectiveness in a modern-day disinfectant is 100 percent kill greater-than 6-log reduction of an organism.

Both sanitizers and disinfectants are regulated by EPA. In order to substantiate their claims, testing is required to prove their function, and this would be the EPA certification. There are several pre-defined criteria that pertain to how they perform, at what concentration and conditions, what “bugs” they kill, how fast they work, etc. EPA registrations take time, often years. Companies can subregister under an existing formulation. That means they are using an already certified formula.

How Will What You Are Cleaning Be Affected?

All cleaners do not work with all materials. With the desire to decontaminate everything, one important item to consider is what you are actually “cleaning.” There are numerous products that are EPA-certified, and some will be on the acidic side. Others (most commonly) will be on the alkaline side, and even a few will be neutral. Their contents may include: hydrogen peroxide, quaternary amines, surfactants, acids, bases, etc.

Recently iSi evaluated a solution for disinfecting aluminum surfaces. With softer metals such as aluminum and copper, the possibility of corrosion or discoloration is much higher with certain disinfectants.

Most of your harder metals (steel, stainless, alloys) are unlikely to be affected.

These soft metal materials can be found in food processing plants, automotive, aerospace and other industries. Thus, it is important to know ahead of time what the results of using the cleaner will be.

Also, please make sure you’re applying the disinfectant per the product’s label and directions. Do not vary from those directions.  Variances in application methods from what the label says may alter the effectiveness of the disinfectant, cause damage to materials, and may make you non-compliant with regulatory guidelines.

How Will the Person Doing the Disinfecting Be Affected?

Make sure you know exactly what’s in the cleaners to be used. Most importantly, get their Safety Data Sheets (SDSs) and really read them and analyze them.

  • How will its usage affect the person who will be applying it?
  • What kind of personal protective equipment will be needed?
  • Do you have that personal protective equipment on hand? With national shortages, do you even have a way to get ahold of it?
  • How will it affect the atmosphere and air quality of the areas it will be used in?
  • What does the overall tone of it say about the type of person and qualifications needed to apply it? Is it really something you’d be comfortable having janitorial staff work with, or does it need to be someone with a greater level of hazardous materials training?
  • Do you have the staff on hand (right now) to take care of this?
  • What is your overall risk?

Unfortunately some SDSs can be vague, confusing, and can even contradict themselves. So please be very careful and make sure you have a firm grasp on what you’re dealing with.

We Can Help Take Care of It

iSi has been pulled into some research gathering for current clients, and also has been providing onsite personnel for others. We have people on-staff to help you with researching and figuring out your requirements. We deal with confusing and contradicting SDSs every day and have the proper staff of safety and chemistry personnel on hand to work through them. We also have an entire team of hazardous materials and safety trained and experienced industrial cleaning technicians ready to support you.

Give us a call, email us, or send us a message through social media and we will get back with you to see how we can help.

Need Help?

Do you need help with understanding the ramifications of a disinfectant?  We can help!

Questions?

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iSi Celebrates Career of Founder Karma Mason

iSi Celebrates Career of Founder Karma Mason

photo of iSi's Karma Mason

Karma Mason

On February 20, iSi held an event to salute the career of Karma Mason, iSi’s long time President, COO, and co-owner, who is retiring from full-time duties.

Karma started iSi with her husband Gary Mason, iSi’s CEO, in 1990.  They built iSi from their dining room table to a thriving company of over 150 in 4 office locations.  She started out wanting to be a PE teacher, but was convinced to get a geology degree by her father, who owned an oil and gas company.  She worked with her dad for a number of years and when his business closed during the downturn in the oil industry, she went to work for the research and development department of Vulcan Chemicals (now OxyChem).  Gary also worked at Vulcan Chemicals.  When they decided to start their own business, Gary left Vulcan and Karma stayed on, but working nights and weekends to help keep the business running until she joined full time in 1991.  She worked environmental and geological-related projects for many years.  As iSi continued to grow, she eventually phased into more of the role of Chief Operations Officer.  This highlighted her strengths of managing operations and driving for success.

Early Determination:  3 National Bowling Championships

Recently retired Wichita State University bowling coach Gordon Vadakin provided a narration to highlight Karma’s leadership, passion, and drive to succeed.  As a freshman, Karma and her team had won the first ever National Collegiate Bowling Championship, and it was the first national championship for Wichita State in any sport.  They won the national championship again in her junior year, after taking second in her sophomore year.

photo of Gary Mason and iSi staff and guests

Gary Mason reads a narrative sent by former Wichita State University bowling coach Gordon Vadakin.

Vadakin become the coach in Karma’s senior year. “Believe me when I say this – I let her completely run the women’s team for the year. Hell, if I got in her way, I would have been run over. In fact, in all my years of coaching since then, I’ve never seen anything close to what Karma did for that 1978 team. I have no idea what Karma’s management style is like today, but back then I would describe her as unbelievably driven,” said Vadakin.  Karma’s team won the national championship again her senior year, making her the only person to be on three national championship bowling teams in the 45-year history of collegiate bowling.

“Karma showed me that no mountain is too high, no goal to big, and that dreams become reality when you pour yourself into what you believe in,” said Vadakin.

Local Leadership Highlighted

photo of Gary Plummer and Karma Mason

Wichita Regional Chamber CEO Gary Plummer talks about the impact Karma’s had on the Chamber.

Gary Plummer from the Wichita Regional Chamber of Commerce and Alan Cobb from the Kansas Chamber of Commerce and Industry were in attendance and each spoke glowingly about Karma’s leadership, assistance, education, and guidance she had given both organizations.  Karma is currently on the board of both organizations and has been involved with each for a number of years.

Tracy Streeter, former director of the Kansas Water Office, expressed similar remarks about Karma from her time on the Kansas Water Authority.  She was one of the longest serving women in the board’s history.  Streeter praised Karma’s leadership in putting together the state budget for the group.  When she presented the budget to legislators, she not only knew the budgetary dollars and cents, but she could speak to all of the technical issues involved as well.

Employee Thoughts

Photo of iSi['s Karma Mason in a red hat

Karma goes through her retirement ideas gift and contemplates joining the Red Hat Society.

Several employees remarked about their time with Karma both in serious and lighthearted ways.  As they’ve done with other retiring or leaving managers, long time iSi employees Tammy Gonzales and Tami Hadley prepared a video tribute.  iSi Facility Support Services manager Al Tolbert gave her a U.S. Air Force CMSGT Challenge Coin given only to a few for special achievement and that honor was very special to her as well as a framed photo of her office with “The Birthplace of Leadership” inscribed on it, from iSi’s Dick Genter.

Gary Mason said that Karma had been telling many people she didn’t want a rocking chair as a retirement gift, so he said “…we got her something so she could be more active,” – a walker with a bowling ball tied to it.  She also received a symbolic key to the building (because she’s always welcome), and gifts to help her decide what to do in retirement such as a red hat, silver sneakers, free crochet lessons, and a book about progressive penny slots.  Karma is known for her rock collection, so iSi did give her a serious gift: a heart-shaped geode from Utah.

Future Plans

Although she’s no longer going to be at iSi full-time, Karma will remain a part of the company and will continue to provide geological technical assistance when needed.

If You’d Like to Send a Message to Karma

If you’d like to send well wishes to Karma, email us here or you can send a card or note to her in care of iSi Environmental, 215 S. Laura, Wichita, Kansas 67211.

Watch iSi’s Free Industrial Wastewater Treatment Webinar

Watch iSi’s Free Industrial Wastewater Treatment Webinar

industrial wastewater treatment webinar

Webinar

Watch this free webinar!

iSi currently manages several industrial wastewater treatment plants for manufacturing facilities. In order to best manage these plants, we first needed to learn how they worked in order to develop standard operating procedures and operator training for our own personnel to use.

Ranging in scope from SOP creation, to supervisor operations training, through individual operator’s training, and certification programs, iSi has formalized the knowledge needed to train operators and managers to run effective industrial wastewater treatment systems. Learn more about the process we went through to put these procedures in place and how we can help you do the same for your own facility.

This webinar covers:

  • The Wastewater Process (Using Hexavalent Chromium as an Example)
  • Wastewater Chemistry
  • Disposal
  • Operator Training Content
  • Parameter Table for Checks and Balances

This webinar is free – click here to watch it.

 

​iSi currently manages several industrial wastewater treatment plants for manufacturing facilities. In order to best manage these plants, we first needed to learn how they worked in order to develop standard operating procedures and operator training for our own personnel to use.

Ranging in scope from SOP creation, to supervisor operations training, through individual operator’s training, and certification programs, iSi has formalized the knowledge needed to train operators and managers to run effective industrial wastewater treatment systems. Learn more about the process we went through to put these procedures in place and how we can help you do the same for your own facility.

This webinar covers:

  • The Wastewater Process (Using Hexavalent Chromium as an Example)
  • Wastewater Chemistry
  • Disposal
  • Operator Training Content
  • Parameter Table for Checks and Balances

This webinar is free – click here to watch it.

 

Webinar

Catch our free webinar!

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Machine Guarding Real Focus of Renewed OSHA Emphasis Program

Machine Guarding Real Focus of Renewed OSHA Emphasis Program

OSHA has updated and renewed its National Emphasis Program on amputations in manufacturing facilities.  With this emphasis, OSHA will be targeting manufacturers and industrial facilities, with a focus on machine guarding and lockout-tagout.

Who’s On the List?

Machine guarding and lockout-tagout are annual residents on OSHA’s top 10 list of violations and cause amputations and injuries each year.  OSHA has had amputations on its national emphasis since before 2015, but they’ve updated it with a new list of potential NAICS codes to target based on data from 2015 to 2018.  OSHA is going to target industries with higher rates of machine guarding and lockout-tagout violations, higher rates of related incidents, higher rates of amputations, those with amputations within the past 5 years, and those with machine-related injuries or fatalities.  They’ve developed a target list of around 130 targeted NAICS codes.

Companies with less than 10 employees will not be on the target list, even if their NAICS code matches.

Please remember that as with all OSHA emphasis programs, if OSHA is onsite for another inspection, they can add this to their scope. 

What Will Be Looked At?

In addition to reviewing 4 years of OSHA logs, they will be inspecting your machinery and equipment, looking for hazard potentials in:

  • Pinch, Nip and Shear Points
  • Cutting Actions
  • Setup and Operation
  • Clearing Jams or Upsets
  • Making Adjustments When Operating
  • Cleaning/Greasing/Oiling
  • Scheduled and Unscheduled Maintenance
  • During the Lockout-Tagout Process

Machine guarding is used to protect both the operator and everyone else who could come in contact with a machine.  Any machine, part, function or process that can cause injury must be safeguarded.

The best way to ensure you are ready for an inspection is to make sure you’re compliant with the following standards.  These will be the ones used by inspectors as they’re the ones that have the greater potential to cause amputations:

1910 Subpart J – General Environmental Controls

1910.147              Control of Hazardous Energy (Lockout-Tagout)

1910 Subpart O – Machine and Machine Guarding

1910.212              General Requirements
1910.213              Woodworking Machinery Requirements
1910.217              Mechanical Power Presses
1910.219              Mechanical Power Transmission

Inspection Start Date

As with all new and revised emphasis programs, there will be a 90-day period where OSHA will provide outreach efforts to alert the industry about the changes before starting targeted inspections.  This puts targeted inspections starting around March 10, 2020.

More Information

For more information, check out the OSHA inspector directive here, which also includes the affected list of NAICS codes.

Need Help?

iSi has conducted a number of machine guarding audits for manufacturers.  Let us provide one for you today!

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EPA’s Navigable Waters Protection Rule Defines Waters of the U.S.

EPA’s Navigable Waters Protection Rule Defines Waters of the U.S.

EPA and the U.S. Army have finalized their definition of the Waters of the United States (WOTUS) through a new final rule called the Navigable Waters Protection Rule.

The definition of WOTUS has been at the point of contention between regulators, industry and environmental groups since the Clean Water Act amendment in 2015.   The definition has been at the heart of a number of legal battles, and an item of regulatory enforcement uncertainty.

“[The Navigable Waters Protection Rule] clearly delineates where federal regulations apply and gives states and local authorities more flexibility to determine how best to manage waters within their borders,” said EPA in a published fact sheet about the new rule.

What is Included?

Once proposed as six categories, the final rule was narrowed to four major categories of waters to be included:

Territorial Seas and Traditional Navigable Waters

Included are bodies of water such as the Atlantic Ocean, Mississippi River, Great Lakes, large rivers and lakes, tidal waters, tidally influenced waterbodies including wetlands, along coastlines — used in interstate or foreign commerce.

Tributaries

These are rivers and streams that flow to traditional navigable waters either directly or through other non-jurisdictional surface waters.  The flow must be perennial (flowing continuously) or intermittent (flowing continuously during certain times of the year), not just when it rains.

These tributaries can connect through structures such as culverts, spillways, and debris piles.  Ditches can be tributaries if they satisfy the perennial or intermittent flow requirements and could be considered an artificial channel used to convey water when they are tributaries or built in adjacent wetlands.

Lakes, Ponds and Impoundments of Jurisdictional Waters

These are included when they are traditional navigable waters like the Great Salt Lake in Utah or where they contribute a perennial or intermittent flow of water.  Lakes and ponds flooded by an included WOTUS in a typical year would be included.

However, lakes, ponds and impoundments must have a surface water connection to a jurisdictional water body.  If they are only flooded by stormwater runoff from fields, or if they lose their water only through evaporation, underground seepage or use, they wouldn’t be included.

Adjacent Wetlands

Wetlands are adjacent and included if they:

  • Physically touch other included WOTUS;
  • Are separated from an included WOTUS by a natural berm, bank or dune;
  • Are flooded by an included WOTUS in a typical year;
  • Are separated from an included WOTUS by an artificial dike, barrier or similar structure that allows direct connection between the wetland and the WOTUS through a culvert, flood gate, pump, or similar; or,
  • Are separated by a road or similar structure where there is an allowance for direct surface connection during a typical year.

What is NOT Included?

The below are not included as long as they do not meet the above definitions, and are upland and in non-jurisdictional areas.

  • Groundwater, including drains in agricultural lands;
  • Ephemeral features: springs, streams, swales, gullies, rills and pools;
  • Stormwater: diffuse stormwater runoff and directional sheet flow over upland as well as stormwater control features excavated or constructed in upland to convey, treat, infiltrate, or store stormwater runoff;
  • Farm and roadside ditches;
  • Prior converted cropland (except in the case where the cropland has been abandoned/not used for agricultural purposes in the previous five years and has reverted to wetlands);
  • Artificially irrigated areas including flooded fields for agricultural purposes;
  • Artificial lakes and ponds including water storage reservoirs and farm irrigation, stock watering and log cleaning ponds;
  • Water-filled depressions incidental to construction or mining and pits for fill, sand, and gravel;
  • Groundwater recharge, water reuse, and wastewater recycling structures (detention, retention and infiltration basins and ponds); and,
  • Waste treatment systems, that is, lagoons, treatment ponds, settling and cooling ponds, and all components designed to convey or retain, concentrate, settle, reduce or remove pollutants either actively or passively from wastewater or stormwater prior to discharge.

Representatives of the agricultural community see this new rule as a win for them as it provides some clarity for their industry and relieves some of the potential impacts the 2015 version would have put on them.  Many of the non-included features are agricultural-based.

What’s a Typical Year?

The phrase “typical year” is used widely throughout the definitions.  In this rule, typical year means the normal periodic range of precipitation and other climactic variables based on data for the past 30 years.  So, some areas which have non-typical flooding or non-typical drought during some calendar years may or may not be included depending on what is “typical.”

What Really Matters:  What Are Your Local Laws?

The Navigable Waters Protection Rule defines the requirements of federal law.  However, some states like California have developed their own regulations and definitions that are stricter and the federal law allows for that.  Be aware of what’s required locally, and that’s the rule you’ll need to follow.  However, having this clearer definition of the federal law may be a help in determining what the differences are locally.

Need Help?

Do your industrial activities affect an included WOTUS?  iSi can assist with determinations, permits, reports, sampling and more!

Questions?

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Potential Employer Requirements in an OSHA Emergency Standard for COVID

Potential Employer Requirements in an OSHA Emergency Standard for COVID

UPDATE: 

President Biden signed an Executive Order on Thursday, Jan. 21, 2021 that requires the following:

  1. Within 2 weeks (by Feb. 4, 2021), OSHA is required to:
    • Issue guidance to employers on workplace safety during the COVID pandemic.
    • OSHA and MSHA are required to determine if an emergency temporary standard is necessary.  If so, it will be due by Mar. 15, 2021.
  2.  OSHA is required to review its enforcement efforts and identify any short-term and long-term changes to be made.
  3.  A National Emphasis Program on COVID-19 in the workplace is required to be developed.
  4.  OSHA is to work with state plan states to make sure they have similar COVID plans in place, and for those who don’t have a state plan, work with state and local officials to make sure they have plans in place to protect public employees.
  5. The Secretaries of Labor, Health and Human Services, Transportation, Energy and Agriculture need to work to identify that workers not covered under OSHA in their respective categories are protected.

What’s an OSHA Emergency Temporary Standard?

Under certain limited conditions, OSHA is authorized to set emergency temporary standards that take effect immediately and are in effect until superseded by a permanent standard. OSHA must determine that workers are in grave danger due to exposure to toxic substances, new hazards, or agents determined to be toxic or physically harmful where an emergency standard is needed to protect them.  OSHA publishes the emergency temporary standard in the Federal Register, where it also serves as a proposed permanent standard. It’s subject to the usual procedure for adopting a permanent standard except that a final ruling should be made within six months. The validity of an emergency temporary standard may be challenged in an appropriate U.S. Court of Appeals.

What May Employers Be Required to Develop in a Federal Standard?

In total, 14 states have adopted comprehensive COVID-19 worker protections through executive order and/or their state OSHA programs. 

Currently, there are 4 states – California, Virginia, Michigan and Oregon – that have issued a state-specific OSHA emergency standards through their state plans.  There are common themes between the policies of these 4 states and they have pulled items from each other.  These items would likely become a part of a federal emergency standard:

Conducting a Workplace Assessment

This would include identifying employee tasks, work environment, presence of the virus, number of employees, facility size, working distances, duration and frequency of exposure, and hazards encountered.

Develop an Exposure Control Plan

This would include designating an on-site COVID coordinator, providing free face coverings and requiring their use, signage, social distancing, barriers, remote working, prohibiting sick employees access to facility, enhanced cleanings for positive cases, employee screenings, and notification of positive cases.

Implement Controls 

This includes maximizing current ventilation systems, installing barriers, partitions, and airborne infection isolation rooms.

Training Employees 

Training would need to be specific to the place of employment.  Included would be reviewing control measures, proper use of PPE, how to report symptoms or positive cases, how to report unsafe working conditions, and an overview of the COVID-19 virus, symptoms, and means of transmission.

Maintain Records of Training, Screenings, and Notifications

This would include employee training, employee and visitor screenings, notifications as required to individuals and Health Departments.

How Often Have Emergency Standards Been Used Before?

OSHA has used emergency temporary standards 9 times.  The last time they were used was in 1983 for asbestos.  OSHA’s first emergency standard was also created for asbestos, and others have been created mostly for chemicals, including 12 different carcinogens, benzene and vinyl chloride.  Most standards have been challenged in court, and although there have been a few that have been vacated, most have remained in place.

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iSi will be monitoring developments with federal OSHA and will update this article, or provide additional information in our blog as information continues to develop regarding this issue.

We're Here to Help If You Need It

Short lead times for OSHA indicate the potential for a short lead time for employers to get program elements in place.  Our team of safety and industrial hygiene professionals are here to help with the things you may not have time to develop.  Let’s get the conversation started!

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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EPA Rule Adds PFAS Chemicals to the TRI Report

EPA Rule Adds PFAS Chemicals to the TRI Report

EPA has added certain per- and polyfluoroalkyl substances (PFAS) to the list of chemicals which need to be tracked annually on your EPA Toxic Release Inventory (TRI) report (below).   This rule is effective 1/1/2020, so you’ll need to start tracking and collecting data on their usage immediately.

PFAS chemicals (aka PFOS and PFOA because these are the most common PFAS chemicals) have been widely used in industrial processes and can be found in many consumer products including firefighting foam, pizza boxes, cookware, paints and polishes, electronics manufacturing, fuel additives and more.

The new rule was signed into law through the National Defense Authorization Act on December 20, 2019.  Reporting threshold is only 100 pounds, far less than typical TRI chemicals.  The de minimis concentration for PFOA is 0.1% and all other chemicals have a de minimis level of 1%.

Because PFAS chemicals come in so many shapes and sizes and in so many industries and consumer products, it’s thought that an alarmingly high percentage of people have been exposed to them.  Contaminated drinking water is the most documented source, but food, house dust, and workplace exposure are among the top as well. In communities with contaminated drinking water, human health effects that have been found include higher cholesterol, increased uric acid, lower birth weight, lower response to vaccines, diabetes, and cancer.

As a result, dealing with PFAS issues has become an EPA focus.  There have already been other efforts by EPA recently to develop methods and guidance for drinking water monitoring and laboratory testing, development of a PFAS Management Plan, conducting toxicity reviews, development of recommendations for addressing groundwater already contaminated with PFAS, and other actions.

If you need assistance with determining if this new requirement affects your facility, we can help.  Contact us today!

PFAS Now on TRI List

Click here to go to EPA’s list of PFAS chemicals that you need to start tracking now for your TRI report.

NAICS Codes Affected

EPA lists the NAICS codes of industries subject to TRI reporting.  Is your company affected?  Click here to go to EPA’s list of NAICS codes.

What is a TRI Report?

TRI, Form R and SARA 313 are all names for the same report.  What is it and does it pertain to you? Click here to find out.

Need Help?

Do you need help sorting out this regulation?  What about TRI reporting?  Contact us for more information or a price quote.

brady gerber
brady gerber

Contributing:

Brady Gerber

Environmental Field Services Supervisor | Project Manager

Brady Gerber has over 13 years’ experience working in environmental site investigation and remediation projects and various environmental compliance regulations pertaining to stormwater, fuel storage, hazardous waste, wastewater discharge, spills, emergency response, and brownfields.

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