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

Questions?

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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.

Questions?

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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!

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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!

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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!

Questions?

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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!

Questions?

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

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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.

###

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.

Email  |  LinkedIn

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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.

Email  |  LinkedIn

EPA Issues Air Permitting Updates for New Sources, PSD and Title V Air Permits

EPA Issues Air Permitting Updates for New Sources, PSD and Title V Air Permits

​EPA has issued air permitting updates in order to help companies save time and reduce paperwork and compliance burdens.

Air Permitting Update:  Definition of Adjacent Areas

As we first reported here last fall, EPA was considering changing the interpretation of the word “adjacent” for its EPA Title V air permit and New Source Review (NSR) air permits for new construction or modifications.  That interpretation change is now final.

In the regulations, the word adjacent comes into play when determining if a facility qualifies for permits.  When determining sources, a building, structure, facility or installation must be under the control of the same person, belong in the same industrial grouping, and located on one or more contiguous or adjacent properties.  When it came to “adjacent”, EPA had been also considering “functional interrelatedness,” that is, grouping together facilities with similar functions, even if they were miles apart.

According to the new rule, for all industries other than oil and natural gas production and processing, adjacent is physical proximity only.  EPA makes additional comments on the word “contiguous” as well, noting the difference between adjacent and contiguous.  Operations do not have to be contiguous to be adjacent.  That is, operations that do not share a common boundary or border, not physically touching each other will be adjacent if the operations are nearby.  If there is proximity (neighboring or side-by-side operations where the “common sense notion of a plant” can be deduced) that will be considered adjacent.  Railways, pipelines and other conveyances will not determine adjacency.

Please note that states with their own air permitting programs aren’t required to follow the new interpretation, so be aware of the regulations in your own state.

More information about EPA’s change can be found here.

Air Permitting Update:  Revised Exclusions for Ambient Air

EPA has broadened the exclusions industrial facilities can take from the ambient air regulations.

The Clean Air Act sets standards that affect ambient air quality, that is, that portion of the atmosphere, external to buildings, to which the general public has access.  In the air permitting process, companies are required to make air quality analyses of how their operations, (or changes to operations) will affect the ambient air quality.  Within that requirement, there’s been an exclusion for areas that the public didn’t have access to.  That is, you didn’t have to count the effects to the air quality of the areas of your facility that the public didn’t have access to as long as your company owned or controlled that area.

Until now, fences and other physical barriers have been the determining factor on public access.

In the updated regulations, EPA is allowing for other types of measures to which deter public access.  Some examples could include:

  • Signage
  • Security Patrols
  • Remote Surveillance Cameras
  • Drones
  • Natural Barriers Such as Cliffs or Rugged Terrain (case-by-case basis)

Your company will still need to have the legal authority to prevent the public from going onto that property.  Please note that in this case as well, states with their own air permitting programs aren’t required to follow the new interpretation, so be aware of the regulations in your own state.

For more information, check out the EPA’s guidance page here.

How Does This Apply to Your Facility?

Need help determining where you stand on air compliance? Let iSi’s environmental team help you with your site-specific obligations.

iSi can help you with air permits & determinations – Contact us today!

What OSHA Says About Using Online Safety Training Courses

What OSHA Says About Using Online Safety Training Courses

OSHA's opinion on online safety training

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News to your inbox! We cover OSHA, EPA and DOT regulations news & best practices each week.  Subscribe to our blog today!

OK, OK, before anyone has a chance to say “of course you’re going to write THIS article,” we want to make it clear that although iSi may be known for the face-to-face classes we hold at our offices and onsite at client facilities, we DO write and produce online and computer-based training modules.  Thus, we are in favor of training in all forms, including online.  Online and computer-based classes can be a great tool for your training program, especially in places where there is high turnover, multiple shifts, or high numbers of employees at the facility.

Now…on to the article.

Recently, an OSHA interpretation letter was published that asked the question:

Are online training programs acceptable for compliance with OSHA’s worker training requirements?

OSHA’s Opinion of Online Safety Training

The response from OSHA said that although online safety training can be a valuable part of your training program, you cannot use it by itself to meet OSHA requirements unless it contains hands-on interactive elements.   OSHA says that training requires a mastery of the material that would include safe uses of tools and equipment.  The students must be able to interact with the proper equipment and tools.  This benefits not only the new student, but is a good refresher for those who are more skilled and also allows a qualified instructor to make sure the student has mastered the skill.

The interpretation letter references a previous letter published in 1994 that mentions HAZWOPER (Hazardous Waste Operations and Emergency Response) as an example.  In HAZWOPER, hands-on use of personal protective equipment is very important.  Training should include how to don and doff the PPE and include a way to ensure the student is comfortable doing so and is doing it correctly.  The information also needs to be able to somewhat be tailored to the student’s situation.  OSHA adds that this hands-on training needs to be conducted in a non-hazardous location as well.

This would also be the case for any powered industrial vehicle training.  In each of those courses, there is a classroom portion about the hazards that could be done online.  However, specific hands-on training with the actual equipment, whether that be a forklift, a scissor lift, a tug that pulls an airplane, etc., needs to be conducted in a hands-on fashion with the student operating the equipment and an instructor evaluating his/her performance and providing guidance.

Ability to Ask Questions

Another requirement to be meet OSHA standards is the student must be able to ask questions of an instructor.  Some of the topics may be unfamiliar, and OSHA values the student’s ability to ask questions and receive them in a timely manner.  They say that not having this interaction impedes the student’s ability to comprehend the material and retain it.

OSHA suggests that to take care of this requirement, a way to ask questions should be built into the program.  They mention a hotline number could be used, but you may also be able to use email or chat. 

Regardless of what you use, the contact needs to go directly to a qualified trainer and the responses need to come back in a timely fashion.

Where to Find These Interpretations

To review these OSHA interpretation letters regarding online safety training, read the one from 2019 here, and the one from 1994 here

Are you using online safety training for your company and now need to rethink how you’re administering it based on OSHA’s guidance?  Let iSi help you!  Contact us today for guidance, hands-on assistance, or customized online training modules that can be imported into your company’s learning management system.

Do you need assistance in administering your safety training programs?  Let us help – contact us today!

OSHA’s New Weighted System for Inspection Priorities

OSHA’s New Weighted System for Inspection Priorities

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OSHA’s fiscal year has started and with the new year comes a new system for weighting their priorities for inspections. This OSHA inspection weighting system is aimed to help them track inspection activity and give regional administrators a guide for prioritizing resources.

Inspection weighting has been around since 2015. Prior to that, OSHA would use numbers of inspections completed to count activity. This led to some inspectors loading up on shorter inspections in order to gain quantity while not giving as much credit to those who were doing the long, complex inspections. So, in 2015, a weighting system based on time of completion was developed. However, OSHA found that this was not as ideal as needed either.

The new system factors in agency priorities, inspection impact, and the most hazardous workplaces and operations. Each category of inspection is assigned a numerical value. The most time intensive, complex and high priority inspections gain the most points.

The following is the new points system, from highest value inspection to least value inspection. The points are listed in terms of Enforcement Units, or EUs.

1. Group A: High-Priority, Time-Intense, Complex Cases [7 EUs]

  • Criminal Cases
  • Significant Cases

2. Group B: High-Priority Hazards, More Complex Than Average [5 EUs]

  • Fatalities and Catastrophes
  • Chemical Plant National Emphasis Program Inspections
  • Process Safety Management Inspections

3. Group C: Focus Four Emphasis Program [3 EUs]

  • Caught-In Hazards (trenching, equipment operations, oil & gas)
  • Electrical Hazards (overhead power lines, electrical wiring methods)
  • Fall Hazards (scaffolds, elevated walking and working surfaces)
  • Struck-By Hazards (highway work zones, material handling, landscaping)

4. Group D: Programmed and National Emphasis Program Inspections [2 EUs]

  • Amputation Hazards
  • Combustible Dust
  • Ergonomics
  • Federal Agency Inspections
  • Heat Hazards
  • Non-PEL Overexposures
  • Workplace Violence
  • Permit Required Confined Space Hazards
  • Personal Occupational Exposure Sampling
  • Site-Specific Targeting

5. Other Regional/Local Emphasis Programs Not Already Covered (2-3 EUs)

6. Group E: All Other Inspections Not Listed (1 EU)

Phone/fax/email investigations (e.g., complaints) and rapid response investigations earn “activity points.” Each one of these earn 1 activity unit for every 9 completed, so the equivalent of 1/9 EU. Additional enforcement support activities such as responses to Freedom of Information Act requests, electronic correspondence responses, state plan monitoring and interventions have not gotten units assigned yet.

OSHA has weighted their compliance assistance activities as well.  This is the hierarchy from most important to least: 1. Voluntary Protection Program (VPP) evaluations, 2. OSHA Strategic Partnerships activities, 3. OSHA Alliances activities, and 4. Compliance Assistance activities such as making presentations and staffing informational booths.

Please note, that OSHA can and will still add on any program area to an inspection if they are already at your facility for another issue.

How would your facility do if it was inspected by OSHA tomorrow? Let iSi help you find out! We can conduct safety audits and mock/test run inspections and then help you prioritize the list starting with your most critical. Contact us for a price quote!

Where does your facility stand on OSHA compliance? Schedule iSi for a mock OSHA inspection, audit or walkthrough!

Shelbye Smith Receives Promotion

Shelbye Smith Receives Promotion

Shelbye Smith with iSi Environmental

Shelbye Smith, SPHR

iSi is pleased to announce the promotion of Shelbye Smith, SPHR to the Chief Culture and Talent Officer at iSi.  Shelbye has been with iSi for 16 years, where she primarily has served as both the Human Resources Manager and Risk Manager.

“This promotion is a recognition of Shelbye’s tremendous talents and our desire to have a talented Human Resource voice at the highest level of leadership”, said iSi CEO, Gary Mason. “Our business creates many challenges for HR professionals.  At iSi, we have a full range of both highly trained EHS professionals and entry-level laborers. As a result, our HR professionals must create a recruiting and retention process that addresses all of these needs but also allows for an entrepreneurial approach to our business. Shelbye has done exactly that. Her balance of technical knowledge and understanding of the business has provided a tremendous advantage to our organization”.

“iSi is very fortunate to have someone of Shelbye’s caliber and experience to be a leader within our organization. Shelbye was State Director of the Society of Human Resource Managers (SHRM) from 2017 through 2018 and is also a Trombold Award winner. We look forward to her leadership moving forward”, said Karma Mason, iSi COO.

Shelbye grew up in Wichita, Kansas and graduated from Friends University with a B.S. in Psychology and Spanish, and completed a Masters in Industrial/Organizational Psychology from Emporia State University. Shelbye is married to Ben Smith and they have two sons: Trevor and Connor.  Shelbye’s favorite pastime is watching Trevor and Connor play baseball.

OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

Respiratory Protection Assistance

iSi conducts both quantitative and qualitative fit-testing and can help you determine what your facility’s needs are for respiratory protection.  Contact us today!

OSHA has added two new fit testing protocols for quantitative respirator fit-testing.  The two new protocols are actually modifications of the current ambient aerosol CNC protocols for full-facepiece, half-mask elastomeric, and filtering facepiece respirators.  These modifications cut in half the number of steps required, also making them faster to conduct.

There are two types of manufacturers of quantitative fit-testing machines which are most popular, the Portacount by TSI and a controlled negative pressure (CNP) machine by Occupational Health Dynamics, or OHD.   The changes in the protocols affect TSI’s PortaCount-type machines.

 Quantitative Fit Testing vs. Qualitative Fit Testing

Qualitative fit-testing uses items such as saccharine or irritant smoke to determine protection.  It relies on the person being tested’s ability to sense odor or irritants.  Qualitative fit testing is only for half-face and N95 filtering facepiece respirators that have an APF of 10.

Quantitative respirator fit-testing uses a machine to measure pressure loss inside the mask or to count quantities of particles to calculate a fit factor. 

Quantitative testing is considered more accurate than qualitative fit-testing.  Quantitative fit-testing must be conducted for respirators requiring an Assigned Protection Factor (APF) over 10.  Full-face tight fitting respirators have an APF of 50 and thus need to be quantitatively fit-tested.

The New Protocols

OSHA based their new protocols on the results of three different studies.  After consideration and comment, 4 of the 8 exercises were removed or changed. 

These include the grimace exercise, normal breathing, and deep breathing.  The grimace exercise was often found to shift the fit of the mask while the breathing exercises were considered exercises that rarely affected fit factor.  For full facepiece and half-mask respirators, talking was eliminated in favor of jogging-in-place, a new exercise.   

Additional changes were made to the number of sets and the duration.   OSHA anticipates 5 minutes can be shaved from each fit-test with the new protocols.

PortaCount Upgrades Needed

If you have PortaCount Models 8030, 8038, 8040 or 8048, you will need a software upgrade that you can download from the TSI website.  You can also have the update uploaded when you send in your machine for its annual service.  PortaCount Model 8020 or 8028 users will only be able to use the original 8-step protocols.   If you have a machine manufactured by another company which uses the same protocols, you will need to check with your manufacturer if the machine you’re using requires an update.

Link to the New Protocols

For more information about the specific protocols, visit the revised Appendix A of the standard.

iSi can help you determine your facility’s respirator needs then provide the personnel to help accomplish tasks — Contact us today!

SPCC Plans:  What Are They and Does Your Company Need One?

SPCC Plans: What Are They and Does Your Company Need One?

Need an SPCC Plan?

iSi can help you determine if this applies to your company, and then we can help you write the plan.  Contact us today! 

If your company uses or stores large quantities of oil, you may be subject to EPA’s Spill Prevention, Control and Countermeasures, or SPCC regulation and be required to have a plan to prevent discharges of that oil into navigable waters.

Who Needs to Comply with SPCC?

SPCC regulations cover all types of oils, including petroleum, fuel oil, sludge, vegetable oils, mineral oils and synthetic oils.  If your facility has the capacity aboveground of 1,320 gallons or more or underground capacity of 42,000 gallons or more, you quality for this regulation. 

To count capacity, add together everything that can store 55 gallons or more of petroleum.  This includes drums, totes, tanks, or any other storage vessel.  Also included in the total is the capacity from equipment such as hydraulic systems, lubricating systems, gear boxes, coolant systems, heat transfer and transformers, circuit breakers and electrical switches. 

Therefore, all types of industries are included within this regulation, including, but not limited to:

  • Industrial and Commercial Facilities Using or Storing Oil
  • Oil Exploration and Production
  • Refining and Storage
  • Airports
  • Marinas
  • Power Transmission, Generation and Distribution
  • Construction
  • Waste Treatment

What’s the Purpose of SPCC?

SPCC planning is the practices, procedures, structures, and equipment used at the facility to prevent spills from reaching and contaminating navigable waters.  Most facilities will discharge to navigable waters because this often includes ditches, storm sewers, and other drainage systems that can lead to streams, creeks and other bodies of water.

SPCC planning includes three basic functions:

1)  Practices devoted to the prevention of spills,
2)  Planning for containments should a spill occur, and
3)  Removal, cleanup, and disposal of spilled materials. 

These basic functions are incorporated into the SPCC Plan.

What’s Included in an SPCC Plan?

A SPCC Plan has several required elements, including:

  • Petroleum-related chemical quantities and locations;
  • Release prevention structures;
  • Release prevention procedures;
  • Procedures in place to respond to a spill, should it occur;
  • Equipment used to prevent or respond to a spill;
  • Key personnel;
  • Training programs;
  • Spill history; and,
  • Certification.

In most cases, the certification of the SPCC Plan needs to be completed by a professional engineer. 

Compliance Deadlines

If you make changes to your facility, such as adding containers, secondary containment structures, or installation of piping, you must update your SPCC Plan within six months of the change. 

Per requirements, review your SPCC Plan every 5 years and make changes accordingly.

Where Do You Send the SPCC Plan?

Unless you’re asked for it, your plan stays onsite and is not required to be submitted to EPA or your state office.  Some states do have SPCC requirements in addition to the EPA requirements.  EPA says that if the facility the SPCC Plan covers is staffed at least 4 hours per day, the Plan needs to be maintained there.  If the facility is not staffed 4 hours per day, then it can be maintained at the nearest field office.

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Do you need an SPCC Plan?  If you have one, when was the last time it was reviewed?  iSi has worked with hundreds of plans and we’d like to help.  Contact us today!

Does this apply to your facility?  Do you need help writing or updating your SPCC Plan? — Contact us today!

Citation Case Study: Fluorescent Lamps Hazardous Waste Violation

Citation Case Study: Fluorescent Lamps Hazardous Waste Violation

Haz Waste Audits

iSi conducts audits and inspections to find potential environmental violations, including hazardous waste.  Let us give you that second set of eyes to make sure your company is on track.

The following is an example of a fluorescent lamp hazardous waste citation given to a manufacturing facility by a state’s environmental regulatory agency.  The company appealed to the state’s Office of Administrative Hearings.  Although this particular citation was from a state regulatory agency, the citation referenced a federal hazardous waste regulation and thus this issue may be cited in any location.

Can this scenario be found at your facility?

Scenario:

A company was found with one spent 8’ fluorescent lamp on a shelf. 

The Citation:

40 CFR 273.13(d)(1), 273.14(e), and 273.15(c)

The company was cited with hazardous waste violations for

1)  Failure to containerize lamp;
2)  Failure to label lamp as Universal Waste; and,
3)  Failure to mark lamp with accumulation start date

The company tried to prove that the lamps used are non-hazardous (do not contain mercury above the TCLP limit) and were purchased from Lowe’s by providing receipts.  However, receipts found were from 4’ lamps and not 8’ lamps.

The company also stated that a marked container was indeed present for lamps (and the state environmental agency acknowledged a container marked “Universal Waste – Lamps” was present in their notes from the inspection).  The company argued that therefore, they should not be cited for the container violations of failure to label and failure to date, only the failure to containerize.

The Ruling in Appeal:

It was found that while the fluorescent lamp was ultimately placed in the container as required, that it did not detract from the fact that, upon inspection, the spent lamp had not been placed in a container. Moreover, since the lamp was not in a labeled container, the regulation requires that the lamp itself be labeled. If the lamp was not in that container then it must be labeled, according to the regulation.

Likewise, the fluorescent lamp needed to be dated to indicate when it became waste.  While the there was a labeled and dated container in the facility, the lamp in question was not in that container.  Because the lamp was not in the container maintained by the facility, the company was in technical violation of all three regulations.

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Are you maintaining your fluorescent lamps properly?  What about the other wastes at your facility?  iSi can help you determine what you’re currently doing correctly and which areas need changes.  Let us come take a look at your facility today!

How does your hazardous waste program look?  Let our experts do a walkthrough to see what could be potential violations!

Phase I ESAs: Reveal the Hidden Truths Behind Your Next Property Acquisition

Phase I ESAs: Reveal the Hidden Truths Behind Your Next Property Acquisition

Phase I ESAs

iSi conducts Phase I ESAs, as well as Phase II ESAs which include sampling of water, groundwater, soil and more.  Add us to your list of potential vendors for your next property transaction!

Imagine this scene:  your company just purchased a prime piece of property and has proceeded to establish your business on that land.  Your company uses few chemicals and those you do use are carefully managed.  Ten years later, chemicals commonly used to degrease parts appear in private wells in the area.  Upon investigation, it’s found that 30 years ago, a previous owner of the land operated a printing plant on the site.  This company used hundreds of gallons of the same chemical to clean their presses and they disposed of the remaining chemical on the ground.  The groundwater is now contaminated.  You didn’t put it there, but you own the land. And the printing company is out of business.

Who’s going to clean all of the wells?  According to the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), or Superfund, your company, as the landowner, can be held responsible for the cleanup.  EPA will either order your company and other potentially responsible parties on the chain of ownership to clean the site or they will clean it themselves and sue you for reimbursement.  What defense does your company have?

What is a Phase I Environmental Site Assessment?

Because current owners can be held liable for environmental damage on their land, even when they didn’t cause it, lenders and insurance providers will usually protect their assets by requiring an environmental inspection of the property prior to its purchase.  Commonly called a Phase I Environmental Site Assessment (ESA), this inspection provides the “due diligence” necessary to assess the environmental conditions of the property with reasonable confidence.

Innocent Landowner Defense

Superfund only recognizes three defenses to a landowner’s liability in such a case: an act of God, an act of war, and the “innocent landowner” defense.  An innocent landowner is one who used “due diligence” to determine if there was a potential for contamination on the site before buying it, and the Phase I will meet this requirement. 

However, for a Phase I to have any meaning in establishing an innocent landowner defense, it must be produced following guidelines established by the American Society of Testing Materials (ASTM).  The guidelines are voluntary, but they are a consensus among lenders of what research is necessary to provide a satisfactory evaluation of a property’s environmental condition.

What’s Included in a Phase I ESA?

  • History of Site Usage: A title search, interviews of past owners and neighbors, map analysis, historical document analysis should be conducted.
  • Review of Public Records: A search of federal, state and local information to identify nearby regulated facilities that could impact the property (e.g., underground storage tanks, hazardous materials generation amounts) should be evaluated.
  • Site Reconnaissance of Property and Adjacent Properties: A walkthrough site inspection should be completed to identify recognized environmental hazards such as disposal sites, leaks, storage tanks, water or gas wells, and sumps or the obvious presence of asbestos, lead, or transformers that contain PCBs.  In addition to the physical inspection, the topography, geology, and hydrology of the site and surrounding region should be researched and evaluated to determine the potential for a neighbor’s contamination to migrate to the property.

What Kind of Transactions Require a Phase I ESA?

There are a number of instances where a Phase I ESA can be very beneficial:

  • Purchasing Property:  A Phase I can alert the buyer to possible contamination before the purchase of property.  It can also serve as documentation of the condition of the property at time of purchase.
  • Leasing Property (As the Tenant):  A Phase I can serve as documentation of the environmental condition of the property before the lease begins and after lease termination.  Without the assessment, the tenant may be held liable for contamination caused by past or future tenants.
  • Leasing Property (As the Landlord):  A Phase I should be conducted before and after a tenant occupies the property. Prior to leasing, the Phase I can serve as a baseline of the condition of the property, and after the tenant leaves, the Phase I can properly document and address any environmental issues left by the tenant.
  • Disposal of Property:  A Phase I can serve as a baseline of the condition of the property at time of disposal.  This will help protect the disposer from future liability.
  • Other Transactions:  Use Phase I ESAs for land swaps, right-of-way purchases, easements and special use permits (i.e., public recreation, grazing, mining, etc.)

Are you planning a real estate transaction in the next few months?  Let iSi conduct your Phase I ESA for you, or provide one of our other real estate or new facility services.  Contact us today!

Selling or purchasing property?  Let iSi conduct the Phase I ESA — Contact us today!

Robot Safety: NIOSH Develops Program to Study Robot-Related Injuries

Robot Safety: NIOSH Develops Program to Study Robot-Related Injuries

Robot Safety Evaluations

iSi has provided safety assistance to companies utilizing laser guided vehicles.  Let us help you with hazard evaluations, training and related issues.

With the increased use in robotic technology, NIOSH has been looking into the safety impact of working alongside these machines.  While robots can help reduce workplace injuries by replacing workers in some types of hazardous work conditions, the use of robots may create their own set of hazards.

The National Institute for Occupational Safety and Health (NIOSH) has a Center for Occupational Robotics Research, and more specifically, a special program called the Fatality Assessment and Control Evaluation (FACE) Program.  Through the FACE program, NIOSH is conducting robot safety surveillance, targeted investigations, and prevention activities.  The program is conducting in-depth investigations of robot-related deaths. The FACE program is currently operated in 7 states through local state health or labor agencies. 

Recently the Washington State FACE Program issued recommendations for safety actions for two separate types of robots: laser guided vehicles and remote controlled demolition machines.

 Laser Guided Vehicles

In one case, NIOSH investigated a death at a water bottling company where a worker was crushed.  At the facility, each vehicle had safety sensors to detect objects or workers in the vehicle’s path.  An alarm would sound when an obstruction was present, and the vehicles would stop moving until the obstruction was removed. 

The worker heard an alarm sound on one of the vehicles indicating sensors detected an object in its path.  He attempted to remove a piece of plastic that likely tore off a pallet.  Before removing the plastic and reaching under the forks, the worker had not cut the power to the machine.  He also had not heeded label warnings to stay clear of the forks.  Investigators believe that when he removed the plastic obstruction, he was positioned outside the path of the sensor.  The vehicle resumed operation, the forks came down, and the worker was crushed. 

FACE recommends the following safety practices to prevent injury from laser guided vehicles:

  • Incorporate manufacturer safety requirements into written company safety procedures for automated guided industrial vehicles;
  • Train workers about the specific hazards and safety requirements associated with automated guided industrial vehicles; and,
  • Emphasize workers are expected to follow required safety procedures every time, and ensure compliance through periodic refresher training and spot checks.

Demolition Robots

FACE investigated two cases where workers were severely injured by demolition robots.  In the first case, a worker was using a machine that had a wire connected to a remote control the worker wore on his waist. When the worker attempted to move the machine’s power cable, he bumped the remote control against the machine, pinning him between the machine and the wall. 

In another case, a worker broke his foot when operating a machine to chip concrete.  He was in a tight spot between an excavation wall and the machine.  When he tried to apply more force on the machine to chip the concrete, the machine shifted and the outrigger came down on his foot.

As a result, FACE has developed recommendations for demolition robot safety:

  • Prepare a job hazard analysis with operators for each new job to identify and control hazards. Use the manufacturer’s safety instructions to establish the risk zone for the specific machine, attachment, and task;
  • Always stay outside the risk zone when the machine is in operation, and do not enter until the machine is put into emergency stop mode or de-energized;
  • Consider using a proximity warning system, such as those based on radio frequency identification (RFID), to maintain a safe worker-to-machine distance;
  • Train operators to manage power cables and to continually monitor the process for hazards and redefine the risk zone;
  • Ensure operators always read and follow manufacturer’s provided safety instructions; and,
  • Consider using a spotter to assist the operator.

NIOSH is Looking for Case Studies

NIOSH’s Center for Occupational Robotics Research, and its FACE programs are looking for other instances where robotics technology has contributed to injuries.  Through their research, they hope to develop additional safety programs and guidance to help companies keep workers safe.  If you know of a related incident, NIOSH would like to hear from you for an anonymous investigation.  You can find more about them at https://www.cdc.gov/niosh/topics/robotics/aboutthecenter.html.

We have worked with companies that use laser guided vehicles and other technology.  Let us assist you too — Contact us today!

Citation Case Study:  Paint Drippings on the Ground a Hazardous Waste Violation

Citation Case Study: Paint Drippings on the Ground a Hazardous Waste Violation

Haz Waste Audits

iSi conducts audits and inspections to find potential environmental violations, including hazardous waste.  Let us give you that second set of eyes to make sure your company is on track.

The following is an example of a hazardous waste citation given to a manufacturing facility by a state’s environmental regulatory agency.  The company appealed to the state’s Office of Administrative Hearings.  Although this particular citation was from a state regulatory agency, the citation referenced a federal hazardous waste regulation and thus this issue may be cited in any location.

Can this scenario be found at your facility?

Scenario:

A company had paint drips on the ground outside by their dumpster.  The paint drips had accumulated over time since the company had been in the same location for over 10 years.

The Citation:

40 CFR 265.31

The company was cited for violation of hazardous waste rules for “Failure to prevent the possibility of fires, explosions or sudden releases of hazardous waste.” 

The company tried to prove the paint drips came from exempt containers that were RCRA empty at the time of disposal into the dumpster, and the paint drips had accumulated over time.

The Ruling in Appeal:

In this appeals process, a judge reviewed the work of the state inspector and heard testimony by the cited company. 

The first consideration was whether all wastes were removed from the can that could be removed, as required by regulation in order for the remaining contents to be exempt. KDHE and the Administrative Judge found that if the contents were able to drip from the cans upon transport to the dumpster, and in the quantity dripped, not all of the wastes were removed from the paint cans that could have been removed. As a handler of hazardous wastes, the company had a responsibility to take precautions to ensure that hazardous materials were not subject to a release “to air, soil, or surface water which could threaten human health or the environment.”  

The judge noted that spills were understandable; however, the failure to clean up the spills and mitigate the release is crucial. 

With the premise that the hazardous waste contents of the paint cans were no longer exempt once they exited the paint can(s), the question is then whether the spills identified during the inspection violated 40 CFR 265.31.  The regulation states: “Facilities must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.”  The judge found that the company did not minimize the possibility of a fire or release of hazardous waste, and took the least restrictive means’ of handling a hazardous waste, resulting in spills.

Possible Solution:

During the hearing a question was posed to the inspector as to what could have been done to prevent the spills. The inspector mentioned the possibility of using better bags for disposal or even double bagging the paint containers, and landfills are constructed to avoid release of hazardous wastes into the environment.

The company was told it must take precautions to mitigate release, at the very least until the waste reaches the landfill and the citation was upheld.

How does your hazardous waste program look?  Let our experts do a walkthrough to see what could be potential violations!

The 3 Most Important Elements of a Good Safety Program

The 3 Most Important Elements of a Good Safety Program

OSHA’s Safe + Sound Week this week gives us a chance to take a look at company safety programs, what makes them successful and what elements need to be a part of them. OSHA identifies the following three main elements of an effective safety and health program.

Management Leadership

Successful programs all begin with management commitment. Management commitment is often the strong foundation to the program, and without it, all other efforts don’t have nearly the same chance for success. Management commitment shows workers that safety is an important part of the business’s success. In turn, it shows workers that efforts workers make will be valued in the long run.

There are a number of ways management can show their commitment besides financial and resource support. They can factor safety into plans and decisions of the company from construction/renovations to process changes to company policies. Management can also establish rewards and recognition programs for safety participation and achievements as well as making safety a daily part of conversations. At every company event or meeting, a moment can be made available for safety. Safety goals, expectations, achievements, and even the incidents and near misses need to be highlighted through company communication channels.

Worker Participation

Workers are the ones who are exposed to safety issues on a daily basis. They have the knowledge of the hazards they encounter on the job. Safety programs which involve worker ideas and contributions and then follow through on those assist in giving employees ownership and investment into the safety effort. Genuine worker participation efforts need to ensure workers feel comfortable about speaking up when issues are found or injuries happen.

You can encourage worker participation through involving them in program design elements, job hazard analyses, site inspections and incident investigations. Programs which allow workers to assess the safety of themselves and those around them are helpful, as are tools for reporting near misses and incidences of good safety practices.

At iSi we have required Peer to Peer evaluations where workers evaluate safe/unsafe actions of their co-workers. Those who are being evaluated are kept anonymous so there’s no fear of someone “getting in trouble” for not following a safety protocol. We’ve found that the ones who are doing the evaluation tend to get more out of it than the person being evaluated because the act of finding and assessing safety brings more attention to determining what’s the correct safety behavior. The discussions between workers during the evaluations are some of the most valuable for alerting to a potential hazard, enforcing good behavior, and opening up a dialogue for finding ways to make daily work safer.

Finding and Fixing Hazards

When both management and workers are participating, good momentum comes when issues are fixed and resolved. OSHA says that most fixes are reactive, that is, they’re a result of something happening whether it be a response to an incident or a new regulation coming out. However, a strong safety program finds issues and resolves them before they become an issue. The workplace is ever changing, so safety issues may arise where you least expect. Considering safety implications in any workplace change is important.

Take a look into your incidents and determine what is the root cause of those? Are you continually having the same issues in your near misses? What are the injuries in your OSHA 300 logs? Is there a correlation? If there are similarities, then you have a place to start. Involve workers and solicit their ideas in how to make those operations safer. Is there a way to do things differently with minimal efforts and investments? Use the hierarchy of controls when determining solutions. Is there a way to remove the hazard completely? Are the controls you currently have in place working or do they need to have some reevaluation?

So How Do You Get It All Accomplished?

A good safety program like this doesn’t happen overnight and it will take the participation of everyone in your company to make it happen. There are a lot of pieces that will need to be accomplished. Consider using iSi as a resource for getting some of these pieces completed. We have assisted hundreds of companies with their safety programs and have been involved in strengthening safety cultures and putting program elements in place. Not only can iSi be an extra set of hands, but sometimes in developing programs, an experienced third-party to lend ideas or even serve as a mediator can be helpful.

For example, iSi can assist with:

  • Safety Committee and Safety Culture Development
  • Site Audits and Inspections to Help You Gain a Baseline Checklist to Start From
  • Occupational Exposure Monitoring to Get an Idea on Where You Stand
  • Written Safety Program Development Through SafetyPlans.com
  • Job Hazard Analyses
  • Emergency Action Plans
  • Employee Perception Surveys
  • Worker Training

Need Help?

Need an extra hand to get this done? How about policies/programs developed or training conducted?

iSi can be an extra hand to help you accomplish your safety program goals.  Contact us today!

Self-Retracting Lifelines Under Recall

Self-Retracting Lifelines Under Recall

Fall Equipment Inspections

iSi conducts required routine fall protection equipment inspections for our clients companies.  Let us give you that 3rd party eye, and get this task off your to-do list.

If your company uses DBI-SALA self-retracting lifelines, you may be subject to a recall.  3M has issued a stop use recall on the DBI-SALA Twin-Leg Nano-Lok edge and the Twin-Leg Nano-Lok Wrap self-retracting lifelines.  If you have any of these, stop using them immediately and take them out of service.  All models manufactured since 2013 are affected.

Although no injuries have occurred yet, 3M has found that the energy absorbers may not properly deploy, which could result in serious injury or death.

What are Self-Retracting Lifelines?

Self-retracting lifelines are part of a fall protection system. They are placed above a worker’s head and work much like seat belts do.  They pull out and retract, but when tugged or a force is applied, an internal mechanism acts as a brake to shorten the distance of a fall.  Both of the affected DBI-SALA models are used to connect two self-retracting lifelines under the D-ring of a fall protection harness.  The edge model anchors at foot level and the Wrap Back wraps around the anchor. 

I’m Affected by the Recall – Now What?

If you have one of these models, you can either return it to 3M to be fixed, repaired, or replaced at 3M’s expense.  If 3M has not been able to determine a fix or a certified solution for your particular model, you may choose to send it back for a $200 refund. Once repair solutions are determined, and model SKU numbers have been certified, the cash option will not be available.  As of August 8, 2019, 3M has only found a fix for the edge model, not the Wrap-Back. 

For the edge model, 3M announced a fix had been certified to ANSI standard Z359.14 about 2 weeks after the recall notice.  Once the unit has been repaired, it will have a green checkmark on the front label.  This fix will only be available in regions that recognize the ANSI standard as a regulatory certification.  If you are located in an area where additional certifications are required for fall protection devices, 3M will be working to receive those certifications.

3M specifies that until it can fix your Nano-Lok edge models, none of its other twin-leg self-retracting lifelines are approved for use over sharp edges or abrasive edges.  That was the key feature of the edge model.

Get the Recall Notice

To learn more about this recall and to see if your model numbers are affected, check out the recall website at https://www.nanolokedgerecall.com/.

Required Fall Equipment Inspections

When was the last time you had your fall protection devices inspected?  Did you know iSi conducts the required routine fall equipment inspections for a number of our clients?  Let us give you a different pair of eyes in inspection, and help you check this requirement off your to-do list!  Contact us today!

When was the last time you inspected your fall protection equipment?  Let us do that for you — Contact us today!

EPA’s National Compliance Initiatives Show Enforcement Priorities

EPA’s National Compliance Initiatives Show Enforcement Priorities

Does This Apply To You?

We can help determine which of these apply to your facility, and help you make sure you’re on the right track if you’re inspected.

Just like OSHA has national emphasis programs for areas they want to target in their enforcement, EPA has its own national emphasis targets.  Called the National Compliance Initiatives (NCI), EPA has listed 7 priority areas to target for enforcement for Fiscal Years 2020-2023. 

So what’s on the EPA NCI Target List?

Air – Reducing Air Emissions at Hazardous Waste LQGs and TSDFs

EPA has found that facilities that generate a greater amount of hazardous waste have air emissions issues.  Their focus will be on air emissions at Large Quantity Generators (LQGs) and Treatment, Storage and Disposal Facilities (TSDFs).  This emphasis item was in the agency’s last list of NCIs, and inspectors have found there is still significant noncompliance at these facilities.  EPA wants improved compliance in controlling organic air emissions from certain management activities.  They will especially be looking at the following areas in which they are continuously finding problems:

  • Leaking or open pressure relief valves;
  • Tank closure devices;
  • Monitoring; and,
  • Recordkeeping.

Water – Reducing NPDES Permits Noncompliance

EPA will be looking at your facility’s NPDES (National Pollutant Discharge Elimination System) permits to see if you’re in compliance.  NPDES permits are for water discharges, whether they be wastewater, stormwater or otherwise.  In 2018, 11,000 permits had violations totaling 4 billion pounds of pollutants above permitted limits, and EPA wants to crack down on that.  Out of 40,000 facilities with NPDES permits, EPA estimates 29% are in significant noncompliance.  EPA’s goal is to cut that in half by fall 2022.  EPA specifically mentions failure to submit required reports and significant exceedances of limits as two of the most violated areas.

Air – Reducing Excess Emissions of HAPs and VOCs from Stationary Sources

EPA wants a focus on reducing emissions of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs).   They will be focusing on sources of VOCs that may have substantial impact on an area’s attainment or non-attainment of National Ambient Air Quality Standards.  EPA will also be focusing on areas with a greater concentration of HAP sources.  EPA has listed over 180 chemicals that are HAPs, including mercury, asbestos, toluene, cadmium, chromium, benzene, perchloroethylene, and lead.

Hazardous Chemicals – Reducing Risks of Accidental Releases at Industrial and Chemical Facilities

This was on EPA’s list last time, and is continuing.   This NCI not only applies to facilities subject to Risk Management Program requirements (for accidental chemical releases at facilities that store certain chemicals above a certain threshold).   EPA cites a General Duty Clause in their Clean Air Act to cover all facilities with regulated substances and extremely hazardous substances, regardless of quantity.  They’ll be using that General Duty Clause (Clean Air Act Section 112(r)) which requires companies:

  • Identify hazards that may result from accidental releases by using appropriate hazard assessment techniques;
  • Design and maintain a safe facility;
  • Take steps to prevent releases; and,
  • Minimize the consequences of the accidental releases that occur.

It will be important that your facility not only has conducted the proper hazard assessments and has plans and controls in place, but has documentation that has occurred.  This exercise and documentation will help you with both EPA and OSHA compliance.

Air – Stopping Aftermarket Defeat Devices for Engines

This is a new item on EPA’s list.  They will be looking to stop the manufacture, sale and installation of defeat devices on engines.  Often called tuners, these devices bypass the engines’ emissions control systems in order to improve engine performance or fuel efficiency.  The systems modify the exhaust system or electronic chips within the vehicle.   EPA has been levying fines on car manufacturers for a number of years in this area.  One of the most famous cases is the recent Volkswagen emissions scandal where vehicles were rigged to recognize regulatory emissions testing, but operated differently in real world driving conditions.  Now EPA is going after the aftermarket manufacturers and have already started.  However, the emphasis isn’t just limited to vehicles on the road, it’s for any engine, including non-road vehicles and engines.

Water – Noncompliance with Drinking Water Standards at Community Systems

This is a new NCI area for EPA.  EPA says that out of 50,000 Community Water Systems that serve water to the same people year-round, 40% violated at least one drinking water standard in 2018.  Also at these facilities, 30% had monitoring and reporting violations and 7% had health violations.  EPA’s goal is to reduce this noncompliance by 25% by having EPA’s Office of Water work to increase capacity within the states and tribes to address these violations.

Lead – Child Exposure to Lead

This one is an unofficial NCI emphasis because it will be treated as a directive but not be a part of the official NCI enforcement list as a separate program.  EPA has an overall initiative for lead, and the NCI guidance documents affirm enforcement commitment to participating in that initiative.   Plans for EPA’s overall lead initiative include:

  • Increasing compliance with and awareness of lead-safe renovations with the Renovation, Repair and Painting rule;
  • Developing a mapping tool to identify communities with higher lead exposures;
  • Targeted geographical initiatives; and,
  • Public awareness campaigns on lead issues.

What’s Next:  Regional Plans

Each region is to develop a strategic plan on how they will be accomplishing these EPA NCI goals.  Within these plans the regions are to determine how they’re going to allocate resources to these NCIs and how much investment will be put into each one.  The plans are due August 1.   

These NCIs are the goals for Fiscal Year 2020-2023, thus they will go into effect October 1, 2019.

Does your facility fall under these targets?  We can help you determine that, and get you ready — Contact us today!

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

A new bill introduced in the U.S. House of Representatives would require OSHA to establish heat exposure rules for both indoor and outdoor workplaces.

Called the Asuncion Valdivia Heat Illness and Fatality Prevention Act, it would require OSHA to issue a formal heat protection standard.  The bill was introduced on July 10 by U.S. House Representatives Judy Chu and Raul Grijalva, with 27 co-sponsors.  The Act is named for a farm worker who died from heat exposure.  Chu led the effort to get a similar law passed in the state of California.

The Bill and Standard Requirements

The current bill would require a federal standard as strict as any state law.  As a result, requirements would include:

  • Set exposure limits and limitations on how long workers can be exposed to heat.
  • Written heat-illness prevention programs including:
    • Engineering controls such as local exhaust ventilation, shielding from radiant surfaces, insulation of hot surface, evaporative coolers, fans and mist coolers, updating air conditioning systems, natural ventilation;
    • Administrative controls such as rotating work schedules, scheduling work earlier or later in the day, and work rest schedules;
    • PPE such as water-cooled garments, air cooled garments, reflective clothing, cooling vests; and,
    • Emergency response plans.
  • Workers would have paid breaks in cool spaces and access to water.
  • Employees would be allowed to acclimatize to the heat.
  • Employers would be required to train workers in heat-stress symptoms and responding to them.

If passed, the new OSHA heat standard would need to be in place within 2 years.  If the for some reason the standard wasn’t finalized by then, an interim standard would need to be created for finalization in another 2 years.

How Does OSHA Handle Heat Now?

Currently heat-related injuries and illnesses are cited under the General Duty Clause.  In June, a Georgia company was cited $21,311 for a worker who was hospitalized with heat exhaustion.  In January it cited the U.S. Postal Service $149,664 for a worker who died from a heat-related episode.  Many states and OSHA state-plan states have also developed their own rules.

House Committee Testimony – Let the Debate Begin

The bill has been introduced the House Committee on Education and Labor.  In a hearing of that committee on July 11, in addition to the testimony of Chu and Grijalva, other supporters ranging from an occupational health and safety professor, an organizer with a warehouse advocacy center, an occupational medical doctor, and a representative of the United Farm Workers of America gave testimony in support of the bill.   

However, a labor representative from California Farm Bureau federation, a safety and health representative of Associated General Contractors and other House committee members had some questions about the standard.

Congressman Ben Cline said that while it’s certainly a serious and important issue, he questioned if the bill was taking a one-size fits all solution.  He questioned if it would be overly burdensome to apply a federal standard to all areas of the country when there are different levels of heat and different levels of heat-related illness between states.  Cline said that a one-size fits all approach becomes much more complicated when it’s applied to different industries where the workplace may change from one place to another, such as in truck driving.  He also pointed out that in 2012, OSHA had considered a heat illness standard.  However, the effort was cancelled because OSHA found having one overall standard for this issue had many complications and opportunities for ineffectiveness.

Congressman Bradley Byrne questioned if it was possible to make a federal regulation flexible enough to both be effective and fit different workplaces, workers, and scenarios. He said that anything developed needs to have many stakeholders involved, from OSHA to employers to employees.  If the regulations are too onerous, employees may not want to do what they need to do to comply.  To get everyone involved, it will take time to develop, and the 2-year timeline for a federal regulation is incredibly short compared to the 15 years it took the state of California to bring together stakeholders to develop a similar but state regulation.  Byrne pointed out that OSHA already has a mechanism to enforce heat standards, and also cited the 2012 OSHA decision to cancel heat regulations in favor of enforcement and education. He said he’d like to hear from OSHA as they’re the ones who will be forced to implement such a standard in only 2 years, considering they had tried before and then had decided against it.  Byrne said Congress needs to be very careful when passing laws like this because of the unintended consequences that can come out of it. 

Watch the house committee meeting below:

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iSi can help you with workplace safety issues, programs & training — Contact us today!

OSHA Updates 14 Standards

OSHA Updates 14 Standards

As part of the President’s Executive Order for agencies to improve regulations and conduct regulatory reviews, OSHA has been working on reviewing their standards to remove outdated, duplicate, and inconsistent parts of their standards.  The latest round of reviews and updates, called Standards Improvement Project – Phase IV, will go into effect on July 15, 2019 and it updates 14 different OSHA standards at a projected $6.1 million/year savings. 

Updates range from clarifications and deletions, to updates for current technology, to good news for cats.

Social Security Numbers
29 CFR Parts 1910, 1915, 1926

OSHA is eliminating the requirement to collect worker social security numbers in 19 of its standards.  Any social security numbers already collected on previous forms can remain on those forms, and if employers want to continue to collect numbers, they may do so.

 

Medical Services and First Aid
29 CFR 1926.50

Current standards require posting of physician, hospital and ambulance phone numbers where 911 service is not available.  At the time, 911 was a relatively new concept, but many of today’s 911 services for landlines can pinpoint the caller’s location.  If your area has landline auto-location for 911, you no longer have to post the additional information.

However, the auto-location feature isn’t always available for cell phones in remote locations.  The new rule requires employers, in areas where 911 auto-location for wireless phones is not available, to post the latitude and longitude of the current location in a conspicuous place so that emergency services may locate the worksite.  Employers are also to ensure that the communication system they are relying on to use to report an emergency is working and is effective.  

 

Medical Surveillance Requirements
29 CFR part 1910, subpart Z

Employers will no longer be required to conduct periodic chest x-rays of their employees for lung cancer purposes.  This is a requirement in asbestos, cadmium, coke emissions, inorganic arsenic, and acrylonitrile standards.  Medical data has been found that periodic x-rays don’t make much of a difference in reducing lung cancer.  However, periodic x-rays are still required for asbestosis determinations, and initial baseline x-rays are still required as well.  Digital radiographs will be allowed as well as different sizes of x-ray films.

 

Occupational Hearing Loss
29 CFR 1904.10

The recordkeeping rule now clarifies physicians must use the standards of 29 CFR 1904.05 to make the determination if a hearing loss is work-related.  Previously, employers have been able to not record hearing loss as an injury when a physician determines the loss was NOT work related. However, no guidance was given for physicians in that determination.  A cross-reference from 1904.05 will be added to 1904.10 to help make that determination.  Get more info on iSi’s work area noise surveys & sampling.

 

Cotton Dust
29 CFR 1910.1043

The technology of pulmonary function testing has come a long way since 1978. OSHA will be updating the pulmonary function testing guidelines.  More info on iSi’s worker sampling protocol development.

 

Lifelines
29 CFR 1926.104

OSHA is changing the minimum breaking strength of lifelines from 5,400 lbs. to 5,000 lbs. to align with the most recent ANSI/ASSE standards.

 

Process Safety Management (PSM)
29 CFR 1926.64

Rather than having a separate PSM standard for construction, this standard will now reference the general industry standard 1910.119.

 

Coke Oven Emissions
29 CFR 1926.1129

OSHA has determined coke oven emissions does pertain to construction work, and will be deleting the standard.  Any construction worker exposures to coke oven emissions will fall under the General Duty Clause.

 

Signs, Signals and Barriers
29 CFR 1926, Subpart G

Employers will now be required to comply with the 2009 version of the Manual on Uniform Traffic Control Devices to better align with DOT’s requirements.  OSHA feels the newest version adds better safety controls. These included high visibility safety apparel, stop/slow signage (not just hand signals), the use of automated flagger assistance devices, and crashworthy temporary traffic barriers and lane channelization. Confusing language will be removed from the traffic signs section, and the barricades and definitions sections will be deleted because they’re duplicates.

 

Materials Handling and Storage
29 CFR 1926.250

Currently, posting of maximum safe load limits of floors in storage areas is required.  However, in residential buildings, heavy materials are not placed in areas above floor or slab on grade.  Thus, this requirement no longer applies to construction of “single-family residential structures and wood-framed multi-family residential structures.”  iSi’s safety assistance services

 

Underground Construction
29 CFR 1926.800

Mobile diesel-powered equipment used in “other than gassy operations” must now meet the most current MSHA requirements of 30 CFR Part 7, Subpart E.

 

Occupational Health and Environmental Controls, Gases, Vapors, Fumes, Dusts and Mists
29 CFR 1926.55

“Threshold limit values” will change to “permissible exposure limits” and references to ACGIH standards will be removed.  OSHA is also cleaning up phrases such as “shall be avoided”, deleting the terms “inhalation, ingestion, skin absorption, or contact”, will change Appendix A to Tables 1 and 2, and will correct inconsistent and errant table headings, footnotes, cross references and asterisks.  iSi’s workplace sampling program development services

 

Shipyards
29 CFR 1915.80

Feral cats will no longer be considered vermin and thus, no longer a health and safety hazard.

 

Rollover Protective Structures, Overhead Protection
29 CFR 1926, Subpart W

OSHA is removing test procedures and performance requirements and replacing them with the current standards of ISO 3471: 2008.  They will also be making some other technical error revisions.

 

 For more details about each change, read the Federal Register notice here.

iSi can help you determine which of these safety and industrial hygiene issues will affect you — Contact us today!

EPA’s “Once In, Always In” May Be Officially on the Way Out

EPA’s “Once In, Always In” May Be Officially on the Way Out

EPA has proposed a rule that would officially eliminate the air regulations rule of “Once In, Always In” for major source hazardous air pollutant (HAP) emissions.  As a result, EPA is estimating reduced regulatory burden for thousands of locations, and thousands of others could now have a better incentive to reduce air emissions.

Background: Air Emissions Regs

Locations that emit one or more of the 187 named hazardous air pollutants above a certain threshold are classified as a “major source.”  As a result, they become subject to a number of additional regulatory obligations.  They are required to follow certain rules established by their related Maximum Achievable Control Technology (MACT) rules and are required to complete annual Title V Air Emissions permitting. 

If locations have HAP air emissions below the stated threshold, they are classified as “area sources.”  The regulatory requirements at this level are much less burdensome.

What’s Once In, Always In?

EPA’s Once In, Always In policy stated that once a location reaches that major source classification, they were always going to be a major source, not matter what – even if the company took steps to reduce emissions below that threshold.  It was developed in 1995 as a guidance memo and originally intended to only be in place until the agency could propose amendments, but it stayed in permanently. 

As part of the 2017 Executive Order for agencies to review and reduce regulations, EPA looked at Once In, Always In.  They determined the Clean Air Act really did not specify or support time limits.  As a result, EPA issued its own interpretation memo saying there was no basis for major sources to have that classification permanently.  These sources should have the ability to reclassify as area sources if they implemented the controls and reductions necessary to become area sources.

This new proposed rule is the formal step to make this interpretation final.

The Benefits

This rule will benefit companies that have already implemented technologies to control HAP emissions, and companies whose processes or operations have changed to the degree that they no longer emit or have the capabilities to emit HAPs above the thresholds. 

EPA estimates that out of 7,920 major sources, approximately half will now be eligible to reclassify as an area source.  Besides the lessened compliance burden, EPA estimates costs savings of $168.9 million in the first year, and $163-$183 million each year after.

Those companies who are still major sources will also now have a concrete incentive to make changes to operations that would further reduce HAP emissions.

Public Comment

Find out more information about this rule here.  EPA is also soliciting public comment at regulations.gov.  They want to hear about all aspects of their proposal including their interpretation of Once In, Always In, requirements for establishing effective HAP limits, allowing limits issued by states/local/tribal agencies as effective as long as they are legally and practically enforceable, and ideas for safeguards to ensure emissions are not increased.

Which Source Are You?

Is your site a major source or an area source? Can you reclassify?  Let us help!

iSi can help you with air emissions determinations & compliance — Contact us today!

What are Lab Packs and How Could Your Facility Use Them?

What are Lab Packs and How Could Your Facility Use Them?

Casey Moore, iSi Environmental

About the Author: iSi’s Casey Moore has more than 25 years of experience in the hazardous waste industry including working for hazardous waste carriers and operating hazardous waste facilities in California and Arizona.

I’ve never been a fan of “spring” cleaning, but it’s a necessary part of good housekeeping around the home or at your facility. When was the last time your facility did a “spring cleaning” walkthrough to see if there are any materials around your workplace that are expired, or you don’t need?  Flammable cabinets, chemical storage, research/QC labs and maintenance shops are likely places these items accumulate.

What is a Lab Pack?

Since most of the items in these locations are likely to be in smaller containers, they aren’t treated like regular waste streams. Lab packs are a practical solution. Lab packs are consolidation packaging of “like” materials from the smaller containers into larger containers to satisfy proper DOT shipping and EPA RCRA hazardous waste management.

The lab pack was designed for managing expired materials in labs, however, it’s something that can be used for any facility that needs to do a cleanout of smaller containers usually less than 10 gallons each.

What Items Are Candidates for a Lab Pack?

Look for jars, jugs, vials and cans of hazardous materials, including chemicals, solvents, paints, thinners, acids, cleaners, strippers, inks and more. These are typically out of date, off-specification, partially used, and no longer needed.

Who Does Lab Packing?

There are strict regulations about who is qualified to do lab packing. These persons need to determine which containers can be put together and which ones may cause harmful reactions when mixed. Typically, hazardous waste carriers provide this service.

How is Lab Packing Accomplished?

First, items are segregated, that is, sorted, for combining into one larger container.  Items are segregated by:

  • Hazard class — most common are flammables, corrosives, and toxics
  • Type of material — liquids, solids, etc.
  • Compatibility

“Paper pack” is the term used to show the segregation by container. An initial inventory list is converted into lab pack inventory sheets (what goes into each container). This is what waste companies use to create approval numbers for compliance under RCRA. It is also how they establish price. Pricing is based on disposal, transportation and labor associated with packaging.

Packaging is accomplished by:

  • Putting the segregated materials into their respective larger containers;
  • Filling with a packing material (vermiculite is most common) to create stability and containment while shipping;
  • Vermiculite will be in the base and surrounding each of the internal containers; and,
  • The smaller containers are placed into the larger container vertically, so the label with the double arrows pointing up is on the outer packaging.

RCRA Regulation Implications

A lab pack counts towards your waste generation status if you’re a Very Small Quantity Generator (VSQG) or a Small Quantity Generator (SQG), so be mindful of the amount of hazardous waste generated in the process.

For states that have already adopted the Generator Improvements Rule, this is a good use of the episodic event and would not count against your generator status.

If you have any questions regarding lab packs or hazardous waste regulations, contact us!

iSi can help with hazardous waste compliance and facility walkthroughs to find environmental and safety issues.  Contact us today!

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