LOTO Standard Also on OSHA’s Update List

LOTO Standard Also on OSHA’s Update List

Recently we featured that OSHA was soliciting information on powered industrial vehicles to determine the need for an updated standard.  Now OSHA is soliciting information on the lockout-tagout (LOTO) standard.  The current LOTO standard was published in 1989.  

The focus of OSHA’s efforts with LOTO centers on control circuit devices.  The LOTO standard requires energy-isolating devices to be used to control energy during servicing and maintenance of machines and equipment.  In the current standard, control circuit devices cannot be used for this purpose.  However, OSHA says it “recognizes recent technological advances may have improved the safety of control circuit-type devices.”

Since 2016, OSHA has granted variances in compliance to several companies who have been able to prove that the control circuit devices they were using could be a safe alternative.  During an evaluation of a recent variance request, OSHA decided that the time had come and the potential technology was available to consider if there was a basis to allow these devices in certain circumstances. Also, their own research has shown that these devices aren’t typically used in short servicing tasks of a machine and don’t require an extensive disassembly of the machine or entrance into it. As a result, OSHA wants feedback from the public and industry about this.

OSHA is requesting information on:

  • How employers have been using control circuit devices
  • Information about the types of circuitry and safety procedures being used;
  • Limitations of their use, to determine under what other conditions control circuit-type devices could be used safely;
  • Use and limitations of using industry consensus standards for LOTO such as ANSI/ASSPP Z244.1;
  • How the evolution of robotics technology such as collaborative robotics, robotics that move freely, or robotic devices that can be worn by workers has affected risks of worker exposure to hazardous energy;
  • The anticipated economic benefits, impacts, and other offsets that would occur if the standards were updated, such as benefits to productivity or reduction of injuries vs. costs of new equipment, servicing, or need for new training.

LOTO and electrical-related issues are found to be among OSHA’s Top 10 violations each year.  The agency is accepting comments electronically until August 18, 2019 at regulations.gov and from there, OSHA will be making a determination of what actions, if any, needs to be taken.  More information can be found here.

Temporary Personnel

iSi can provide temporary and part-time personnel to help fill in at your company in times of vacations, maternity leaves, as a stop-gap between hires, or for special projects.

iSi can help you with lockout-tagout compliance issues — Contact us today!

EPA’s Mercury Inventory Report Due July 1

EPA’s Mercury Inventory Report Due July 1

Any person, company or organization who manufactures or imports mercury or mercury-added products, or intentionally uses mercury in a manufacturing process are required to file a report to EPA by July 1, 2019. 

Called the “Mercury Inventory Reporting Rule,” it is a part of the Toxic Substances Control Act (TSCA).  The final rule for this was published in June 2018.  TSCA requires EPA to publish an inventory on mercury supply, use and trade every 3 years.  EPA’s next inventory is due in 2020, so as a result, they are requiring those use and import mercury to get their data submitted by July 1, 2019.

Requirements

If you fall under this requirement, it doesn’t matter how much mercury you use, you still need to report to EPA.  Reporting is done through EPA’s Central Data Exchange.

The data you’ll use in the report are quantities from calendar year 2018.  Some of the items required to be reported include:

  • Amount of mercury produced, imported, stored, used, sold, or exported;
  • Types of products made;
  • Types of manufacturing processes and how mercury is used;
  • Business sectors to which mercury or mercury-added products are sold;
  • Country of origin of imported mercury or mercury-added products; and
  • Destination country for exported mercury or mercury-added products.

Once submitted, you’ll be required to submit this report again every 3 years.  EPA will not publish names or identifying information once they publish the results.

Exemptions

There are a few exemptions to reporting.  In the following instances you won’t need to report:

  • Your mercury activity isn’t for commercial advantage;
  • The mercury you use is only as an impurity;
  • You’re generating, handling or managing mercury-containing waste only (and not recovering it for commerce purposes)
  • The mercury is in an assembled product that contains a mercury component (EPA gives the example of a mercury light bulb for a car manufacturer); or,
  • You manufacture assembled products that contain a component that’s a mercury-added product but you didn’t manufacture or import that component.

EPA Webinar

EPA is having two webinars to explain this Mercury Inventory Reporting Rule.  One is Tuesday May 21, the other is Thursday May 23.  Click on those dates to go to the signup page for each.

Need Help?

Does this apply to you? What other environmental reports apply to you?  We can determine that for you!

iSi can help determine if this applies to you, and what other environmental reporting applies to you too. Contact us today!

PFAS Chemicals: What Are They and Where Are They Found?

PFAS Chemicals: What Are They and Where Are They Found?

EPA has announced its first ever comprehensive nationwide Per- and Polyfluoroalkyl Substances (PFAS) Action Plan. This action plan attempts to address two of the most common PFAS chemicals; PFOA and PFOS.  Despite having called this press conference, no definitive regulations have yet been set in place.  This has led to some frustrated state regulatory agencies deciding to move on without EPA in fear that EPA regulations may take 10 years or more to materialize and finalize, if ever.

So far, 8 states have adopted bills regarding PFAS chemicals and other states are already trying to determine what to do about them.  Because regulations may be seen on the state level before the federal, we believe an awareness of this issue – what is it, why is it important – will prove to be highly beneficial.  

In seminars and conferences, we’ve even heard these mentioned as potentially “the new asbestos” in terms of prevalence of exposure and need for elimination.

SO WHAT ARE PFAS CHEMICALS?

Simply put, per- and polyfluoroalkyl substances are a class of man-made chemicals that are widely used in industrial processes and can be found in many consumer products. They are split into two groups: Polymers and Non-polymers. To be a bit more specific, PFAS chemicals are chains of carbon atoms that are bonded by fluorine atoms. The chemistry is very complex, which is what allows for there to be thousands upon thousands of variations existing in commerce today.

WHERE CAN PFAS BE FOUND?

It would almost be easier to say where they aren’t found!  PFAS chemicals can be found anywhere; in pizza boxes, cookware, paints, polishes, electronics manufacturing, fuel additive, and more! There are even cases of the direct release of PFAS products into the environment. The use of aqueous film-forming foam (AFFF) for fire fighting, chrome surfacing facilities, landfills, and wastewater treatment all contribute to the release of PFAS chemicals in the environment.

Some applications where PFAS-containing materials are used include:

  • Water and stain resistance in textile and paper coating
  • Plastics manufacturing
  • Reducing surface tension in surface coatings
  • Stabilizing agents for metal finishing and electroplating
  • Industrial rinse agents
  • Solder wetting agents and coatings in semiconductors
  • Cable and wiring manufacturing
  • Building and construction
  • Anywhere that uses fire fighting foams (military, oil refineries, manufacturing, airfields)
  • Recovery in metal mining and oil extraction


WHY IS IT IMPORTANT?

Some PFAS chemicals are known to be persistent in the environment, bioaccumulative in organisms, and toxic at relatively low levels. The fact that PFAS chemicals come in so many shapes and sizes and in so many industries and consumer products means that an alarmingly high percentage of people have been exposed to PFAS chemicals. Contaminated drinking water is the best documented source of known human exposure pathways, but food, house dust, and workplace exposure are amongst the top as well. In communities with contaminated drinking water, human health effects include higher cholesterol, increased uric acid, lower birth weight, lower response to vaccines, diabetes, cancer, and more.

EPA’s ACTION PLAN

EPA’s Action Plan covers a number of different areas.  However, most of these plans are in the development, research, and pre-regulatory phase.  They are focusing efforts on developing rules and tools for Cleanup, Monitoring, Research, Communication, and Drinking Water.  For more information on PFAS chemicals , visit EPA’S PFAS data and tools website at https://www.epa.gov/pfas/epa-pfas-data-and-tools.

Get Our Articles Each Week!

We send out our weekly compliance articles each week via email.  Sign up below to get our updates sent directly to your inbox!

Which EPA environmental regulations apply to your facility?  iSi can help determine which ones apply and what you need to do next!

Methylene Chloride Banned for Consumer Use, Industry Use Continues

Methylene Chloride Banned for Consumer Use, Industry Use Continues

Update:  As of November 23, 2019 it is now against the law for any person or retailer to sell or distribute paint removal products containing methylene chloride for consumer use, including online sales.

EPA has issued a final rule to ban the use of methylene chloride for consumer use.  This rule applies to the manufacture, import, process, and distribution of methylene chloride for consumer use.  Industrial use, for now, is still allowed.

Methylene Chloride, also known as dichloromethane, is a key ingredient used in paint strippers.  It also can be found in some acrylic cements for hobbyists.

EPA has been evaluating high-hazard chemicals through the Toxic Substances Control Act, or TSCA.  EPA found the hazards associated with the methylene chloride to be an unreasonable risk.  The fumes are heavier than air and can stay in an unventilated area for several hours.  The fumes can rapidly cause dizziness, loss of consciousness, and death due to nervous system depression.

Retailers have 180 days after the rule finalization to be in compliance.  However, many retailers made pledges to stop selling it long before the rule was finalized.  Lowes, Home Depot, AutoZone, PPG and Sherwin Williams agreed to stop selling methylene chloride-containing products by the end of 2018.  Walmart agreed to stop selling products online and in stores by the end of February 2019 and Amazon targeted March 2019.  Ace Hardware is targeting the end of July 2019.

Industrial Usage Continues

In industry, methylene chloride is used not only as a paint stripper, but for general cleaning, automotive care, bath tub refinishing, metal cleaning and degreasing, lubrication, pharmaceutical manufacturing, and lithography.

EPA is still allowing usage in industry in industry at this time, but are is soliciting public comment for future rulemaking which may include training requirements, limited access rules, and/or certification.

On the employee protection side, methylene chloride usage in industry is also subject to OSHA’s Methylene Chloride Standard.  This standard lines out specific requirements for usage, medical surveillance, respiratory protection, training, hygiene facilities, protective clothing, recordkeeping, and control measures.

Occupational Exposures

Which chemicals are your facility using and have you determined all of your employee exposure responsibilities?  Let us help!

iSi can help you with worker exposure plans, sampling and strategies — Contact us today!

iSi Adds Key Member to Team

iSi Adds Key Member to Team

Photo of Steve Hieger of iSi Environmental

iSi Consulting Services Director Steve Hieger

Steve Hieger has joined iSi as its Consulting Services Director. Hieger will oversee iSi’s entire Consulting Services department which includes management of iSi’s environmental, health, and safety consulting staff and overseeing departmental projects.

“iSi is a fast-paced, innovative, environmental services company and I was looking for a change. I want to participate and help grow the company and make it even more successful than it already is,” said Hieger.

iSi CEO, Gary Mason said, “Karma and I have known Steve for many years, mostly through various civic functions and have always admired his blend of technical knowledge and professionalism. Steve brings with him a tremendous amount of management experience along with strong background in chemical safety and engineering. This blended background makes Steve a great fit to our organization.”

Prior to joining iSi, Hieger was a Plant Manager with 38 years of experience in chemical manufacturing, research and development, and design engineering. Employers included Occidental Chemicals, Vulcan Chemicals, ERCO Worldwide and Dow Chemical. During those years, he has managed complex chemical manufacturing facilities with multiple operating plants. He also directed process engineering activities associated with design, construction and plant startup.

“Safety and environmental stewardship is the foundation of my professional career. I have spent many years dealing with federal, state and local regulations, rules and requirements, and making regulatory interpretations to achieve environmental and safety compliance. I look forward to doing the same for our clients,” said Hieger.

Hieger grew up in Andale, Kansas and graduated from Kansas State University with a B.S. in Chemical Engineering along with an MBA from Newman University. Hieger’s been married to his wife Kim for 38 years and they have four daughters. They are avid sailors and spend the majority of their recreational time sailing on Cheney Reservoir as members of the Ninnescah Sailing Association. They enjoy sharing time with family and grandchildren, traveling, and sailing in the British Virgin Islands.

The Federal Shutdown: EPA, OSHA and DOT

The Federal Shutdown: EPA, OSHA and DOT

We were working on preparing price proposals for two separate federal agencies this week and one greeted with a return email saying it was closed, while the other is still open.  This prompted the question…what about the other regulatory agencies we work with such as EPA, OSHA and the DOT?

EPA

In short, part of EPA is open while the other is closed.  Those functions still open involve ensuring there are personnel necessary to respond to emergencies involving safety of human life or the protection of property. 

Functions Still Open at EPA

  • Activities essential to ensure safe continued public health and safety including safe use of food and drugs and safe use of hazardous materials;
  • Superfund projects, where failure to maintain operations would pose an imminent threat;
  • EPA labs where it’s necessary to ensure physical integrity of research property and research conditions;
  • Law enforcement, legal counseling and criminal investigations;
  • Protection of federal lands/buildings/equipment; and,
  • Emergency response readiness and disaster service.

Functions Closed at EPA

  • Inspections;*
  • Non-emergency environmental site sampling;
  • New contract obligations;
  • Existing contract obligations and task orders;
  • Existing grant, cooperative agreement and interagency agreement obligations;
  • Payment activities including contracts, grants and payroll;
  • Travel;
  • New hiring; and,
  • Non-mission critical IT systems.

*While federal inspectors are on hold, please note that state environmental inspections are likely to continue using other sources of funding. 

For more information on EPA’s shutdown, take a look at their contingency plan.

OSHA

At OSHA, it is business as usual because their agency is funded through September of this year.   The same goes for MSHA, so inspectors for both agencies are still out and active. 

DOT

At DOT, some agencies of DOT are busier than others are. 

It’s business as usual for the Federal Motor Carrier Safety Administration and the Federal Highway Administration because they’ve already been funded by multi-year appropriations. 

Functions Closed at DOT

At other DOT agencies, about half of the staff has been furloughed.  Much of what is closed has been administrative such as rulemaking and program development, training, research, purchasing, and grants.   

Functions Open at DOT

Those functions still operational include:

  • Hazardous materials (hazmat) inspections of shippers and carriers;
  • Hazmat enforcement activities;
  • Hazmat testing facilities and cylinder reconditioning facilities;
  • Hazmat approvals and permits for emergencies only;
  • Pipeline safety regulation inspectors;
  • Those who manage rail and pipeline accidents/incident investigations; and,
  • Pipeline operations/systems inspectors.

For more information about all the DOT shutdown activities, download their Shutdown Contingency Plan.

Free Webinar

Catch our free webinar on EPA environmental reporting!

We can help with EPA, OSHA & DOT concerns — Contact us today!

iSi’s Environmental Reporting Webinar

iSi’s Environmental Reporting Webinar

osha-silica-dust-construction-general industry-webinar

Webinar

Attend our webinar to determine how these regulations apply to your organization.

osha-silica-dust-construction-general industry-webinar

Webinar

Attend our webinar to determine how these regulations apply to your organization.

There are a number of environmental reports companies in general industry must prepare on an annual basis.

Some like EPA’s SARA Tier II, SARA Form Rs, Air Emissions Inventories and Hazardous Waste Biennial Reports have set dates.  Others for air, hazardous waste, wastewater, stormwater and boilers may be guided by your state or your permit itself. 

In this webinar, we’ll cover the basics of the most common reports you may be required to prepare for your facility each year and the due dates you need to know.  

Need help sorting out your reporting requirements? Let iSi help!

Mason Selected to Join EPA Policy and Technology Council

Mason Selected to Join EPA Policy and Technology Council

gary mason

iSi CEO Gary Mason

Acting EPA Administrator Andrew Wheeler selects iSi CEO Gary Mason to join EPA’s National Advisory Council for Environmental Policy and Technology, or NACEPT. 

“This is an amazing opportunity to participate on developing environmental policy for our nation.  I’m extremely excited and look forward to working with other members of the council,” said Mason.

NACEPT brings together representatives from the government, business and industry, environmental organizations, academia, and other groups to advise the EPA Administrator on issues relating to federal environmental statutes, executive orders, regulations, programs and policies.

As part of the Council, Mason will be providing advice and recommendations on:

  • Developing and implementing domestic and international management policies and programs;
  • Developing guidance on how EPA can most efficiently and effectively implement innovative approaches throughout the Agency and its programs;
  • Identifying approaches to enhance information and technology planning;
  • Improving approaches to environmental management in the fields of economics, business operations, and emerging technologies;
  • Increasing communication and understanding with the goal of improving the effectiveness of federal and non-federal resources directed at solving environmental problems; and,
  • Evaluating statutes, executive orders, and regulations and reviewing and assessing their progress.

As a co-founder of iSi Environmental and former Deputy Secretary for the Kansas Department of Health and Environment (KDHE), Gary has developed insight to the regulatory climate that businesses must operate under, and the systems and processes that facilitate compliance in a cost effective manner.

Mason’s term for NACEPT will run through November 30, 2020.

Snakes as an Indoor Air Quality Issue: iSi’s Memorable Projects

Snakes as an Indoor Air Quality Issue: iSi’s Memorable Projects

At iSi we get the opportunity to come across all types of industrial hygiene and indoor air quality projects.  One of our most memorable ones involved something that isn’t typically thought of as a indoor air quality problem:  snakes!

In Chapman, Kansas, employees at a 1930s office building were complaining about an unpleasant odor in the building. The employees suspected that the odor was coming from snakes that were nesting in and around the building.

chapman snakesIn the spring and fall over the past several years, employees frequently caught snakes in the building. The snakes often poked their heads out from the ductwork and slid over toes at work stations. The snakes were confirmed to be black racers, which produce a distinctive odor when they are disturbed or active. Some settling asphalt near the building provided a place for the snakes to den, and some snakes found paths which allowed them to enter the building. With winter approaching, the snakes had no reason to leave once inside the building.

iSi’s Industrial Hygienist, Constance Timmons, met with a local wildlife biologist from Kansas State University to do a walkthrough evaluation of the building to gather background information. With the indoor air quality information that they gathered, Constance and the wildlife biologist determined that the odor was in fact due to snakes.

Although the odor was not a health hazard, iSi recommended ways to prevent the snakes from re-entering the building in the spring such as using snake traps; a drift fence between the building and the field, consisting of silt about an inch deep; and using pea gravel as a filler around the building because it does not support tunnels.

Indoor air quality project and snakesFor ongoing snake control, iSi recommended placing glue traps along the inside walls of the building, making sure that the traps are not adjacent to standing pipes. A snake is able to wrap around the pipe and leverage itself off the trap. Also, turning up the heat in the building may increase the capture of snakes on the glue traps because they are not able to hibernate when they are so warm. Building personnel were advised that, if they chose to relocate the snakes, to release them at least two miles from the building during any season but winter. Racers have a home range of 25-50 acres, and would find their way back if not released far enough away.

In the 2 days after our visit, the employees were able to catch over 23 snakes!

Do You Have An Indoor Air Quality Issue?

If you’ve got an indoor air quality issue, we feel like we’ve seen it all! Let us diagnose the problem and find the solutions.

What indoor air quality or workplace exposure issue can we help you with? Contact us today!

Frequently Asked Asbestos Questions – A Free Webinar

Frequently Asked Asbestos Questions – A Free Webinar

asbestos frequently asked questions

As a long-time asbestos abatement, survey, inspection, sampling and training firm, we get a lot of questions about asbestos.

In this webinar we will be covering the questions we are asked the most, from who regulates asbestos to where it can be found, to training and licensing requirements, how the NESHAP regulations affects rules and more!

What questions do you have? Join us on Tuesday, December 11 at 1:30 pm CST.  There is no charge to attend, but space is limited!  Register Here

Register Today!

Register here for our free asbestos webinar on December 11!

iSi’s Industrial Services team can help you with your asbestos questions and issues — Contact us today!

What is an ISO 14001 Environmental Management System?

What is an ISO 14001 Environmental Management System?

The International Organization for Standardization, or ISO, determines internationally agreed upon standards for businesses.  ISO standards that end in “001” are management systems. ISO 14001 is for environmental management systems as ISO 9001 is the standard for quality management systems and 45001 is for safety and health management systems.

Standards in the “ISO 14000 family” relate to environmental management.  There are actually other standards in the 14000 family such as 14004, 14006 and 14064-1 that complement ISO 14001 or take it a step further.

Who Is Required to Have ISO 14001 Certifications?

ISO 14001 is voluntary; however, many national and international companies are increasingly requiring their suppliers to become certified. 

Having the certification signals that your company conforms to pre-approved standards of environmental performance and has procedures in place for compliance and improvement. It also shows your company is committed to certain environmental objectives like waste minimization, pollution prevention and climate change mitigation as well as has perspective on the effects of life cycle and the value chain of a product/service.

What’s the Process for Creating an Environmental Management System?

An ISO 14001 environmental management system (EMS) is all about developing and documenting objectives and processes, implementing them, monitoring and measuring their success, reporting results, maintaining them, then taking actions to continuously improve upon them. 

Some of the elements of the EMS include developing procedures for:

  • Scope of the EMS
  • Leadership and commitment;
  • Defining and documenting your environmental policy;
  • Organizational roles and responsibilities;
  • Identifying risks, threats and opportunities
  • Identifying environmental aspects and impacts;
  • Establishing environmental objectives and plan for achieving them;
  • Resources;
  • Competence, training records, skills, experience and qualifications;
  • Internal and external communication;
  • Document control;
  • Operational control;
  • Emergency preparedness and response;
  • Compliance obligations and evaluation;
  • Monitoring and measuring results;
  • Internal auditing the EMS and the results from this;
  • Management review results;
  • Nonconformity and corrective action; and,
  • Continual improvement.

How Do You Become Certified?

Once you have your procedures developed, you will need to conduct an internal audit of the procedures.  From here, tweaks are made and deficiencies are corrected.  An external audit is next, that is, a third-party auditor such as iSi will review your system to verify it complies with the requirements.  After the external audit, corrections are made before an ISO certification agency does the final certification audit.

ISO 14001:2015

The most current version of ISO 14001 is 14001:2015.  Any company with the original 2004 certification had until September 15, 2018 to upgrade to the newest version.  Thus, the 2004 version is now out of date.

As with newer ISO standards such as safety standard 45001, the 2015 revision increases emphasis on commitment from company leadership.  ISO is required to be more prominent in an organization’s strategic direction and stakeholder-focused communication is important.  Other revisions require proactive initiatives for protecting the environment from harm and degradation and requires companies to consider life cycle, that is, how the entire process from development to end-of-life can affect the environment.

Benefits of an EMS

Even if you are not required to have ISO 14001 certification, developing an environmental management system can be beneficial to your company.  Having procedures in place can help improve your overall environmental compliance It can help give your company personnel a roadmap of how to manage environmental issues, which can be helpful in times of employee turnover.  An EMS will help ensure systems are continuously improved and evaluated.  In addition, there may be additional cost benefits through pollution prevention, increased efficiencies, consistency, better resource management, and good public relations.

ISO Audit

iSi can help you create your EMS and has the auditors to inspect it.

How can an environmental management system help your compliance? Let iSi help you put the pieces together!

iSi Covers Industrial Hygiene at Tennessee Conference

iSi Covers Industrial Hygiene at Tennessee Conference

ryan livengood

Ryan Livengood, iSi Project Manager

iSi Project Manager, Ryan Livengood, presents “How Can I Tell If I Have an Industrial Hygiene Issue and What Do I Need to Look For?” at the Chattanooga Regional Manufacturer’s Association Annual EHS Summit in Chattanooga, Tennessee.

The term industrial hygiene (IH) covers a wide variety of issues found in your workplace. Even seasoned safety professionals can overlook areas of concern. Which kinds of typical industrial operations trigger potential issues? How can you tell if you need sampling?  In this presentation, Ryan covers these topics plus gives specific examples of operations with their corresponding potential IH issue as well as examples of typical sampling events.

The CRMA EHS Summit brings together professionals engaged in creating and apply new methods to address and resolve environmental issues in various fields.  Learn more at http://cma1902.com/.

Have you identified the industrial hygiene issues in your facility?  Let iSi assess your operations and conduct your required exposure assessments!

Semiannual Regulatory Priorities Set by EPA and OSHA

Semiannual Regulatory Priorities Set by EPA and OSHA

Twice a year each of the President’s cabinets and executive agencies submits a regulatory agenda for the upcoming months.  It’s a list of priorities and which regulatory areas they intend to focus on.  The following items were listed as priorities in EPA’s agenda and in the OSHA portion of the Department of Labor’s agenda.

EPA – Air Quality

  • New Source Review and Title V Permitting – EPA hopes to simplify the New Source Review process (preconstruction air permits). There are two memos EPA wants to make law.  The first is EPA won’t second guess preconstruction analysis that complies with procedural requirements.  The other is the rescinding of the “once in always in” rule. A rule change will allow companies who are major sources to become area sources if their potential to emit falls below thresholds, reducing regulatory requirements.
  • Electric Utility Greenhouse Gas Rules – Recently EPA proposed a new rule for greenhouse gas emissions called the Affordable Clean Energy Rule. They will continue to look at this alternative approach to the Clean Power Plan Rule.
  • Oil and Gas New Source Performance Standards – EPA has been reviewing the rule including regulation of greenhouse gases through emissions limits on methane. A proposal for public comment will be issued.
  • Safer Affordable Fuel-Efficient Vehicles Rule – EPA will hold public hearings on their August 2018 proposal to amend and establish new Corporate Average Fuel Economy and greenhouse gas emissions standards for passenger cars and light trucks for model years 2021-2026.

EPA – Water Quality

  • National Primary Drinking Water Regulations for Lead and Copper and Perchlorate – EPA will be looking at the lead and copper drinking water rule in order to clarify, reduce complexity, modernize and strengthen it to make it more effective and enforceable. They will also be working on drafting a regulation for regulating perchlorate in drinking water.
  • Peak Flows Management – EPA will be updating permitting regulations for publicly owned treatment works that have separate sanitary sewer systems to deal with the excess wastewater collection that comes with wet weather.
  • “Waters of the U.S.” – EPA will be working on step 2 in the redefining of the term waters of the United States with a reevaluation of the definition, including redefining the term “navigable waters”.
  • Clean Water Act Section 404(c) – EPA will update the regulations concerning its authority in the permitting of dredged and fill material discharges. In reducing its power to veto a permit for any reason, it hopes to help increase predictability and certainty for the U.S. Army Corps of Engineers, landowners, investors, and businesses.
  • Steam Electric Power Generating Point Sources – EPA will publish a notice of proposed rulemaking for reconsideration of the Steam Electric Effluent Limitations Guidelines rule.

EPA – Waste and Land Contamination

  • Per- and Polyfluoroalkyl Substances – The use of these chemicals have been prevalent in a wide variety of items such as stain resistant fabrics and carpets, cosmetics and fire-fighting foam. EPA is set to designate them as hazardous substances and is yet to determine which mechanism to use, whether it be CERCLA or the Clean Water Act.
  • Accidental Release Prevention Regulations Under Clean Air Act – EPA has proposed changes to the Risk Management Plan rule to better coordinate with OSHA and DOT rules, lessen security concerns of sharing information with local emergency planning and response organizations and ease the economic burden caused by some provisions. In the next few months, public comment will be solicited on rule changes.
  • Disposal of Coal Combustion Residues from Electric Utilities – EPA is planning to modify the final rule on disposal of coal combustion residual (CCR) as solid waste and will be amending certain performance standards to give additional flexibility to states.

EPA – Chemical Safety

  • TSCA Amendments – 2016 TSCA amendments require EPA to evaluate existing chemicals for health risks to vulnerable groups and workers who daily use them. This action will be funded by user fees from chemical manufacturers and processors when they submit test data for EPA review, manufacture or use a new chemical, or process one subject to risk evaluation.  These fees will go into effect in 2019.  Also, EPA is on a deadline to do risk evaluations and issue any new proposed rules for persistent, bioaccumulative and toxic (PBT) chemicals by June 2019.
  • Lead Dust Hazards – EPA has proposed strengthening lead hazard standards on dust from floors and window sills in child-occupied facilities. Final action will be June 2019.
  • Pesticide Safety – EPA is considering changes to Certification of Pesticide Applicators regulations from 2017 and agricultural Worker Protection Standard regulations from 2015.

OSHA

  • Electronic Reporting – After requiring certain employers to submit OSHA recordkeeping information to a website which would provide publicly available data, OSHA realized it couldn’t guarantee that personally identifiable information from the 300 and 301 logs wouldn’t be published. Thus, OSHA is proposing to change the Improved Tracking of Workplace Injuries and Illnesses Rule to just include the OSHA 300A summary data.
  • Beryllium – After revising the beryllium standard, OSHA realized exposure in shipyards and construction was limited to a few operations so some of the provisions required within the standard wouldn’t improve worker protection and could be redundant with other standards. OSHA will be working to revise the rule.
  • Standards Improvement Project (SIP) – OSHA will be working on Phase IV of their SIP. SIPs are used by OSHA to fix standards to correct errors, update technical references, account for new technologies and practices, delete duplicate information and fix inconsistent information.  SIPs can affect one or a number of standards.  For example, items for SIP IV include removing the requirement to put social security numbers on records and allowing for storing digital copies of x-rays rather than on film only.

Want more details?  Read the full regulatory agenda for EPA here and for OSHA here.

Want us to write an article in more detail about any of these issues?  Email our team and let us know what you’d like to see!

Need Help?

Do you need help determining which regulations apply to your facility? Contact us today!

iSi can help you determine which regulations apply to your facility. Contact us today!

The Importance of Professional Organizations and Conferences to Your EHS Compliance

The Importance of Professional Organizations and Conferences to Your EHS Compliance

tami hadley

About the Author: Tami Hadley, iSi’s Marketing Director, has been involved in numerous professional organizations as a member and leader and has served on conference planning committees for over 23 years.

Fall is a busy time for iSi as there are a number of environmental, health and safety (EHS) conferences and professional organizations we’re involved in.  At a recent conference, I was reminded how important getting out to these events can be to an EHS professional’s job.

Although EHS professional groups and conferences have one big difference, that being the frequency in which they are held, they are quite similar in their advantages.

Stay Current on Regulations

Although you may subscribe to the Federal Register, blogs and newsletters, how often do you read them? Are you looking at all of them all the time? Do your sources encompass all aspects of EHS compliance that your company is required to follow?

It’s super easy to miss something. Professional groups and conferences allow you direct access to new information and discussion about upcoming regulations. Often the regulators themselves will be the speakers and will give you some extra insight into new regulations, what has changed and why, what’s on the horizon, and what the compliance nuances are. The regulators are also there to answer your questions.

Meet People Who Have the Same Issues You Do

One of the most valuable things about conferences and meetings are the people you’ll meet. At your company you may be the only person responsible for EHS, and perhaps that can be a lonely feeling sometimes. However, you are not alone. There others in your area who are in the same boat as you are. They can help and give you advice.

Besides commiserating with you, they can give you ideas on how to solve issues, can tell you what works for them, and who the good vendors are. I’ve seen people share templates and programs with each other, visit each other’s facilities, discuss what’s working for them, and share training classes with each other.

Connecting and Recruiting

Making connections can be very valuable. One of the number one keys to making a connection is bringing value and sharing value because what you are able to give often comes back to you multiple times over. Goodwill begets goodwill. The people that you meet can introduce you to people they know who may be able to give you information or recommend a solution or a vendor.  It’s the old adage, it’s not what you know but who you know.

Are you looking for good employees to help you at your facility? These events are great for determining potential candidates and seeing who the most respected and knowledgeable professionals in the area are. You may not need someone now, but having an idea of who is in the area and having them know you will save you a ton of time later. Conversely, it’s a chance for you to highlight your expertise as well.  If you are new to the industry or to your job, a group like this can expose you to a lot of different topics and help you learn a lot of things you may not get otherwise.

Unplugging is a Good Thing

Besides the list of tasks we’re expected to accomplish each day, we are inundated by phone calls, emails, texts, persons coming by, fires to put out, etc. The day-to-day grind can really get in the way of continuing education. How many times have you been in a training class at your site and have gotten pulled out for some reason, or have been watching a webinar at your desk only to get interrupted by someone coming in your office or calling you?

Getting offsite for a day or two, or even for a lunch or a breakfast, sets aside a time for you to get your focus back onto learning something new. Even if the speaker doesn’t teach you something new, the time away to immerse yourself in the topic may jolt some new ideas because you’ve had the time to unplug from the clutter and focus on the topic at hand.

It’s OK to Sit by a Vendor

Don’t discount the value of vendors and suppliers. Sure, it’s most likely they are there to make connections, but these people can be some of your biggest sources of information and intelligence in all things EHS. Vendors and suppliers will often have some of the latest and greatest in compliance technologies, methods, best practices, products, apps, etc. You may not need them now, but having them there gives you an idea of who you can call when you need something.

Vendors can also tell you a lot about what companies like yours are doing, how problems have been solved by others and what is going on in the industry. It’s also their job to know who the EHS people are in your area and so they can also be great connectors for you. They go to a variety of events, so you may learn about other specialty groups and conferences and opportunities you didn’t already know about.

List of Organizations

I want to be a valuable connection for you, so below is a list of professional organizations which focus on EHS issues and may have chapters in your area. In addition to these organizations, look for other local groups in your area which are not affiliated with national chapters. There are a lot of them out there.

For conferences, I’ve seen that almost every state has a safety conference and an environmental conference. Sometimes they are combined or sometimes they are conducted within other conferences.

I can give you some specific ideas for groups and events in and around the areas in which iSi has offices: Kansas (state of Kansas and Kansas City area), Oklahoma, Georgia and surrounding states. Contact me and let me know which area(s) you’re interested in and I’ll get back with you with some ideas. In the meantime, here are some national organizations with chapters all across the U.S.:

American Society of Safety Professionals (ASSP)

American Industrial Hygiene Association (AIHA)

Alliance of Hazardous Materials Professionals (AHMP)

National Safety Council (NSC)

Air and Waste Management Association (AWMA)

Which national EHS organizations am I missing? Let me know and I’ll add them to this article!

Did we miss a national EHS group? Are you looking for groups and conferences in your area?  Contact us today!

OSHA’s Ammonium Regional Emphasis Program

OSHA’s Ammonium Regional Emphasis Program

Need Help?

iSi can help you determine what you need to do to get ready for enforcement.

OSHA has announced it has developed a regional emphasis program for ammonium starting October 1, 2018.

Who is Affected?

The emphasis program targets fertilizer grade ammonium nitrate and agricultural anhydrous ammonium.  Both create a significant hazard of fire and explosion and are toxic to those who handle them.  Companies who store, mix, blend, and distribute these products will be targeted in this program.

Ammonium nitrate storage issues came into prominence with the 2013 West Fertilizer facility explosion.   This regional emphasis program was a recommendation of the Chemical Safety Board’s report following the incident.

Which States are Included?

The regional emphasis includes particular states from OSHA Region VI and OSHA Region VII.  These include Oklahoma, Texas, Arkansas and Louisiana from Region VI and Kansas, Missouri and Nebraska from Region VII.

What is the Enforcement Date?

Affected companies will have 90 days from October 1st to get their compliance activities in order before OSHA starts issuing penalties, roughly until the end of the year.   Storage of ammonium nitrate falls under 29 CFR 1910.109(i), and storage and handling of anhydrous ammonia falls under 29 CFR 1910.111.  There are other OSHA regulations and requirements which apply to the handling of these chemicals.

What’s Next?

If your company will be affected by this OSHA ammonium regional emphasis program, iSi can help you determine what you need to do to comply and be ready for any upcoming inspection.  If you don’t know if you are affected or not, we can help you make that determination.  Contact us today for pricing, or fill out our online form!

Let iSi help you determine you ammonium compliance elements!

Overheul to Discuss Link Between Safety Prequalification and Sales

Overheul to Discuss Link Between Safety Prequalification and Sales

Photo of James Overheul from iSi Environmental

James Overheul
iSi Manager of Safety & Industrial Hygiene

iSi’s Manager of Safety and Industrial Hygiene, James Overheul will be presenting “The Safety Prequalification: Where Sales and Safety Meet” at the 69th Annual Kansas Safety and Health Conference.

In recent years, you may have seen an influx of companies requiring safety data to be included within vendor prequalification documentation. Some companies use online programs such as ISNetworld and Avetta, and others have their own programs. These programs can be used to weed out vendors on the basis of safety performance, causing a bad safety record to affect your ability to do business. James will discuss the common safety statistics used in grading, methods for improving performance, and ideas on how to use these programs to boost safety support from upper management.

James will also be participating as a panelist in the open forum question and answer general session “Learning From Each Other, An Interactive Panel Discussion.”

This year’s Kansas Safety and Health Conference will be in Wichita on October 2-3, 2018.

If you’d like to see this presentation, or another safety or environmental-related presentation at your next conference, seminar or event, please email us or give us a call at (888) 264-7050.

Your company’s safety record can affect your business bottom line.  Let iSi help you find the gaps in your program! 

Livengood to Cover Identifying Industrial Hygiene Issues

Livengood to Cover Identifying Industrial Hygiene Issues

ryan livengood

Ryan Livengood, iSi Project Manager

iSi Project Manager Ryan Livengood will be presenting “How Can I Tell If I Have an Industrial Hygiene Issue and What Do I Need to Look For?” at the 69th Annual Kansas Safety and Health Conference.

The term industrial hygiene (IH) covers a wide variety of issues found in your workplace. Even seasoned safety professionals can overlook areas of concern. Which kinds of typical industrial operations trigger potential issues? How can you tell if you need sampling? In this presentation, Ryan will cover these topics plus give specific examples of operations with their corresponding potential IH issue as well as examples of typical sampling events.

This year’s Kansas Safety and Health Conference will be in Wichita on October 2-3, 2018.

If you’d like to see this presentation, or another safety or environmental-related presentation at your next conference, seminar or event, please email us or give us a call at (888) 264-7050.

Do you have an industrial hygiene issue at your facility? Do you need help determining what you need to sample for?  Let iSi help!

Who Regulates Hazmat Shipments?

Who Regulates Hazmat Shipments?

In the environmental and safety world, it’s pretty simple to determine who’s the regulatory authority. For safety, in most cases it’s OSHA, and if you’re in a “state plan” state or if you’re a public entity, your state has an additional safety regulatory agency. For environmental issues, it’s EPA and for many states there is an additional state agency which covers environmental regulations plus you have municipal environmental rules. However, when it comes to shipping hazardous materials, it gets a little more complicated.

In the U.S., the shipment of hazardous materials is covered by federal regulation 49 CFR. 49 CFR addresses the shipment of hazardous materials by ground, air and vessel. The Department of Transportation (DOT) is responsible for enforcing 49 CFR.

DOT contains a variety of agencies which are responsible for ensuring specific parts of 49 CFR are being followed:

  • Pipeline and Hazardous Materials Security Administration (PHMSA);
  • Federal Aviation Administration (FAA);
  • Federal Motor Carrier Safety Administration (FMCSA); and,
  • Federal Railroad Administration (FRA).

In addition to the federal agencies, there are additional state agencies with the authority to enforce DOT regulations. For example, this could be your state’s department of transportation and additional agencies which govern the highway patrol, rail lines or pipelines. Thus, you could receive inspections from a variety of state officials and highway patrol in additional to the federal agencies.

If there was one arm of DOT which takes the lead in hazardous materials, it’s PHMSA. PHMSA’s focus is safe shipments and it creates and publicizes regulations. Thus, if you wanted to learn new information about shipping hazardous materials, start with PHMSA.

When it comes to air and vessel shipments, you’ll find that although 49 CFR has rules regarding these types of shipments, in parts, 49 CFR defers to two other agencies, the International Air Transport Association (IATA) and the International Maritime Organization who publishes the International Dangerous Goods Code (IMDG). These are international organizations, as the shipment of hazardous materials will often cross country boundaries via ocean or air. Thus, when you’re required to have training, you need the training of both 49 CFR and IATA or IMDG. IMDG can also be applicable to shipments within in the U.S. when shipping to Hawaii, Alaska or Puerto Rico.

Radioactive materials shipments are regulated under the U.S. Nuclear Regulatory Commission (NRC).

Both OSHA and EPA mention and defer to DOT within its regulations. Thus, you need to be aware AND trained in both the regulations of OSHA/EPA and DOT when dealing with environmental or safety issues.

49 CFR regulations can become very confusing. If you need help determining which regulations apply to you and how you need to ship your hazardous materials, contact us and we’d be happy to help!

Need Help?

Need help sorting out your hazmat shipping requirements? What about your required training?

iSi can help you with hazmat shipping regulations — Contact us today!

Live Chat Now Available

Live Chat Now Available

Click on this button below to open up our live chat window!

iSi has added live chat as another way to contact us.  To open the chat window, click on the blue button which is hovering at the bottom of each of our pages.

Use this new feature to ask about our training, request quotes, or find specific information you’re looking for.  Right now, this is just something that will be available during the business day.  The chat window should be available Monday through Friday from 7:30 am to 5:30 pm (central time).

Give it a try today!

Ben Smith Named iSi CFO

Ben Smith Named iSi CFO

Photo of iSi CFO Ben Smith

Ben Smith, CMA
CFO of iSi

iSi is pleased to announce that Ben Smith has been promoted to Chief Financial Officer.  Ben is a Certified Management Accountant (CMA) and has been with iSi since January 2009.  He was most recently in the position of Controller.

In his position as CFO, Ben manages all finance and accounting functions for the company.

Ben has a Masters of Business Administration (MBA) with a concentration in international business from Newman University and a B.S. in Business, Accounting from Emporia State University.

Mason Promoted to Strategic Channel Manager

Mason Promoted to Strategic Channel Manager

Photo of Marc Mason from iSi

Marc Mason
iSi Strategy Channel Manager

iSi is pleased to announce that Marc Mason has been promoted to Strategy Channel Manager.  In this role, Marc will be responsible for the overall management of the Marketing and Sales department, as well as exploring new business opportunities and technology developments.

Marc has been with iSi since May 2009 and was most recently the Strategy and Business Development Coordinator.  Marc recently relocated back to Wichita after spending nearly two years in iSi’s Atlanta office.

Marc has a B.S. in Finance and Management from Kansas State University.

James Overheul Named Manager of Safety and IH

James Overheul Named Manager of Safety and IH

Photo of James Overheul

iSi Manager of Safety and Industrial Hygiene James Overheul

iSi is pleased to announce that James Overheul has been promoted to Manager of Safety and Industrial Hygiene in the Consulting Services division.  James has been with iSi since August 2014 and was most recently a Project Manager in the Consulting Services division. 

James has over 20 years’ experience in EHS and operations in the manufacturing and chemical industries.  As a project manager for iSi, James worked with various companies to help them manage their EHS programs, mitigate risk, find solutions to issues, make culture changes and complete tasks.  James has helped companies with safety culture development and implementation, onsite safety and environmental compliance, safety and environmental auditing, and employee training. 

Livengood Joins iSi

Livengood Joins iSi

Ryan Livengood is a Project Manager with iSi

Ryan Livengood, iSi’s Newest Project Manager

iSi is pleased to announce Ryan Livengood has joined iSi’s Consulting Team as a Project Manager.   As a former corporate environmental, health and safety manager, Ryan has a vast experience in working with both environmental and safety compliance issues.

Prior to joining iSi, Ryan was the HSE Division Manager for Pepsi North America, managing safety and environmental compliance issues for all Pepsi facilities nationwide, from manufacturing and bottling plants to warehouses to maintenance sites to fleet facilities. His specialties include environmental compliance, safety compliance, industrial hygiene, and ISO 14001.

Ryan is finishing his MSPH in Industrial Hygiene from Tulane University and has a B.S. in Biology from Kansas State University.

iSi to Discuss SPCC’s Substantial Harm Criteria at Environmental Conference

iSi to Discuss SPCC’s Substantial Harm Criteria at Environmental Conference

rohn hamilton

Rohn Hamilton, P.E.

iSi’s Rohn Hamilton, P.E. will be presenting Ramifications of Triggering “Substantial Harm” Within the SPCC Plan at this year’s Midwest Environmental Compliance Conference.

SPCC Plans, or Spill Prevention, Control, and Countermeasures Plans, are EPA-required plans that are implemented at sites in order to prevent the discharge of oil into navigable waters or adjoining shorelines.  SPCC Plans outline the procedures that will be used to cleanup a spill should it reach a navigable water and the measures to be implemented to prevent spills from occurring in the future.  Companies who need SPCC Plans need to further identify whether or not their company additionally qualifies as a substantial harm facility. Facilities which meet any of the substantial harm criteria are then required to develop Facility Response Plans in addition to the SPCC Plans. Rohn will be covering how to determine if your facility needs an SPCC Plan and how to tell whether or not your facility additionally meets the substantial harm criteria.

Rohn is a professional engineer providing environmental engineering compliance (spill, stormwater prevention, facility response plans) for iSi. He’s a retired Air Force Colonel, who served as the 184 Intelligence Wing’s (McConnell AFB, KS) Chief Bioenvironmental Engineer (environmental, industrial hygiene) and Medical Group Commander. He is also an Airbus 320 Captain for American Airlines.

This year’s Midwest Environmental Compliance Conference will be held April 11-12 in downtown Kansas City.  iSi is a Silver Sponsor for this year’s event and will be an exhibitor as well.  Learn more here.

midwest environmental compliance conference

Does your facility meet SPCC’s Substantial Harm Criteria?  iSi can help you determine that…contact us today!

EPA Proposing Changes to Aerosol Can Hazardous Waste Regulations

EPA Proposing Changes to Aerosol Can Hazardous Waste Regulations

EPA is proposing to allow generators to handle aerosol cans as a universal waste rather than a hazardous waste. As a result, EPA hopes to encourage more recycling, ease regulatory burdens on generators, reduce the amount of cans going to landfills, and save over $3 million per year.

The Current Aerosol Can Hazardous Waste Regulation

Aerosol cans, when discarded, are handled as hazardous waste. Entities with these are required to follow all hazardous waste rules regarding them. The number of days you can store these cans ranges from 90 to 270 depending on generator status and transportation. Retail stores who discard aerosol cans must also follow all hazardous waste rules. In some states, generators can recycle the cans for scrap metal by puncturing them and draining the contents into other containers. The can becomes non-hazardous, but the container of leftovers may be considered hazardous waste. Some states don’t allow the puncturing and recycling of cans at all, even under carbon filtration.

The Proposed Aerosol Can Hazardous Waste Regulation

The proposed regulation would make discarded aerosol cans a universal waste. Other EPA universal wastes include batteries, mercury-containing equipment, and hazardous waste mercury lamps. Universal wastes can be stored and collected for up to one year and don’t need a hazardous waste manifest as long as they’re properly packaged and labeled.

As for aerosol can recycling, the proposed rule would encourage generators to collect and send their cans to a centralized hazardous waste handler for recycling. Any company recycling aerosol cans would be subject to special requirements. Only approved commercial devices for safely puncturing cans could be used. These facilities would also be required to have written procedures for operations and maintenance of the machines, how incompatible wastes would be segregated, proper hazardous waste management practices to be followed, and what emergency spill procedures would be followed.

EPA’s intent is to ease the retailer’s burden of managing aerosol can as hazardous waste, ease the generators’ burden of managing aerosol cans as hazardous waste, and to encourage more states and more entities to recycle aerosol cans.

Gaps

There are still some gaps and unknowns within the regulations such as: What is the exact definition of an aerosol can, that is, would cans that do not aerate (such as shaving gel cans), be included? At what point between full, empty, “RCRA empty”, and used would the cans be eligible for universal waste consideration? Should there be a size limit on the cans; would cylinders be included? Would the equipment that some generators have already invested in to puncture and recycle their own cans be suitable under the new regulation?

EPA is accepting comments until May 15, 2018. To read more about the proposed regulation and where to send your comments, read here.

More Info

Need help sorting out your hazardous and universal waste issues?
Leiker Joins iSi Team

Leiker Joins iSi Team

Curtis Leiker, CSP is a project manager with environmental and safety experience

iSi Project Manager Curtis Leiker, CSP

iSi is pleased to announce Curtis Leiker, CSP has joined iSi’s Consulting Team as a Project Manager.   As a former environmental, health and safety coordinator from manufacturing and agricultural-related facilities, Curtis has experience in working with both environmental and safety compliance issues.

In the environmental field, Curtis is an ISO 14001 Lead Auditor who has worked with directing and strengthening corporate environmental management systems.  He also has extensive experience in environmental compliance auditing, air permitting, water, wastewater, tanks and waste as well as energy and water conservation. In the area of safety, he’s a Certified Safety Professional with experience in safety compliance auditing, program development, safety culture development, employee training, emergency preparedness, and contractor orientation.

Curtis has an M.S. in Biological and Agricultural Engineering, with an emphasis in Air Quality Engineering and a B.S. in Biological and Agricultural Engineering with an Environmental, Natural Resources and Environmental Sciences emphasis, both from Kansas State University.

iSi Discusses Safety at Petroleum Packaging Council National Meeting

iSi Discusses Safety at Petroleum Packaging Council National Meeting

Photo of James Overheul from iSi Environmental

James Overheul
iSi Project Manager

iSi Project Manager James Overheul presented “Manufacturing Plant Safety and the Downstream Impact on Sales” at this year’s Petroleum Packaging Council national conference and tradeshow.

Company safety and injury statistics are increasingly becoming a tool for companies when choosing the vendors and suppliers they want to work with.  Safety is now looked at in pre-qualification reviews, annual contract updates, in publically-available data, and in other locations.  Now more than ever, your company’s safety record can affect your bottom line not only from the impact of worker’s compensation, but in being chosen as a supplier in the first place. In this presentation, James explains what manufacturers need to look for, which statistics are most important and what they can do to improve their record.

This year’s Petroleum Packaging Council was in Tampa, Florida from March 4-6.

If you’d like to book one of iSi’s safety or environmental professionals for an upcoming conference, seminar or event, email us or give us a call at (888) 264-7050.

Your company’s safety record can affect your business bottom line.  Let iSi help you find the gaps in your program! 

iSi Covers Industrial Hygiene at Tennessee Conference

iSi Discusses Environmental Compliance at Chattanooga EHS Summit

Photo of iSi's Consulting Services Manager

Nikki Chavez, CHMM – iSi’s Consulting Services Manager

iSi’s Consulting Services Manager, Nikki Chavez, CHMM, presented “Lessons Learned:  The Most Common Issues and Gaps Found in Environmental Compliance Audits” at the Chattanooga Regional Manufacturer’s Association Annual EHS Summit.

Environmental audits can serve as a useful tool when looking to identify gaps, or even a starting point, for new and existing facilities. Nikki has conducted over 80 environmental audits at industrial facilities.  She is also an ISO 14001 Certified Lead Auditor. In this presentation, Nikki identifies the most common environmental gaps and trouble points she’s observed in the areas of waste, water, air and overall compliance.

The CRMA EHS Summit brings together professionals engaged in creating and apply new methods to address and resolve environmental issues in various fields.  Learn more at http://cma1902.com/.  If you could not make it to the conference, get the highlights on our previous blog post.

Environmental audits can help you determine where you stand on EPA and state compliance.  Let iSi help you find the gaps in your program! 

Changes Coming to OSHA’s Electronic Injury Reporting Rule

Changes Coming to OSHA’s Electronic Injury Reporting Rule

The deadline to submit your injuries and illnesses for 2016 electronically through the new OSHA Injury Tracking Application website is December 1.  However, recent actions by OSHA suggest this rule has the potential to look differently next year.

In January, a lawsuit against the rule was filed in the U.S. District Court for the Western District of Oklahoma. The court stayed its ruling to allow OSHA to review the rule. As a condition of the stay, the court required OSHA to file status reports with the court. In the final status report recently issued, OSHA acknowledged they had reviewed the rule, have drafted regulatory text, summaries and explanations for proposed changes, and their economists are currently working on the economic impact analysis of the proposed changes.

Thus, the electronic recordkeeping rule is likely to be changed, but there are no indications of what will be changed or when. The two most contentious parts of the rule have been making injury/illness data for each company publicly available online and additional anti-retaliation rules which affect certain types of employee safety incentive programs and post-accident drug testing procedures.  There is some thought that both of these previsions may be altered or removed from the rule.

In the meantime, if your company is required to submit electronically, the rule stands as-is and you will need to get your data uploaded by December 1.   Who is required to submit electronically?  Check out our previous blog describing which companies are affected and what the process for submitting electronically entails.  Need help with the data upload or sorting this all out?  Contact us today!

 

Pin It on Pinterest