EPA Makes Final Rule to Update RMP Requirements

EPA Makes Final Rule to Update RMP Requirements

Mar 15, 2024

EPA has issued a change to its Risk Management Program, or RMP regulations for those who process, produce, handle or store hazardous substances or chemicals.  The changes are in an amendment to the rule, officially called the Safer Communities by Chemical Accident Prevention, or SCCAP.  These new rules hope to help increase protection for human health and environment from chemical hazards using lessons learned and process safety procedures.

First, What’s RMP?

RMP can be found in EPA’s Clean Air Act.  If you produce, process, handle or store one of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities, then you fall under RMP requirements.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

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

RMPs must include:

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

RMPs are similar to OSHA’s Process Safety Management (PSM) standard, but RMP is concerned with protecting the environment and human health while PSM is focused on protecting the worker.  Unlike PSM, RMPs are directly submitted to EPA and information is input into a public database for transparency purposes.

Program Levels

A number of the changes are related to specific program levels of RMP.  There are 3 levels to RMP:

Program 1

Processes which would not affect the public in the case of a worst-case release and with no accidents with specific offsite consequences within the past five years.  These sites have limited hazard assessment and minimal prevention and emergency response requirements.

Program 3: 

This is for processes not eligible for Program 1 and are either subject to OSHA’s PSM standard or have one of 10 specified North American Industrial Classification System (NAICS) codes (NAICS code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532).  This program requires using OSHA’s PSM standard as your prevention program plus there are additional hazard assessment, management, and emergency response requirements.

Program 2:

If you don’t fit into Program 1 or 3, then you are a Program 2.  This program imposes streamlined prevention program requirements, as well as additional hazard assessment, management, and emergency response requirements.

The Rule Changes

Emergency Response

  • RMP facilities must develop procedures for informing the public about accidental releases.
  • Release notification data must be provided to local responders.
  • A community notification system must be in place for RMP-reportable accidents.
  • Field exercises must be conducted every 10 years unless local responders indicate that’s infeasible.
  • Emergency response exercises are to follow mandatory scope and reporting requirements.

Third-Party Compliance Audits

  • A third-party must do the next scheduled compliance audit when an RMP-regulated facility experiences two RMP-reportable accidents within five years or when a Program 3 facility under NAICS 324 or 325 has one reportable accident within one year AND that facility sits within one mile of another NAICS 324 or 325 process facility.

Program Requirements

  • Facility siting must be considered in Program 2 hazard reviews and Program 3 process hazard analyses.
  • When facilities have a reportable accident, a formal root cause analysis incident investigation must be conducted.
  • Program 2 hazard reviews and Program 3 process hazard analyses must now address natural hazards (including those resulting from climate change) and power losses.
  • Whenever a recommendation from a hazard evaluation, facility siting, or a third-party compliance audit is not adopted, a justification needs to be put into the RMP.

Employee Participation

  • Employee participation is required in resolving process hazard analyses, compliance audit and incident investigation recommendations and findings.
  • Employee participation is required for stop work procedures in Program 3.
  • Program 2 and 3 sites must provide opportunities for employees to anonymously report RMP accidents or issues of non-compliance.

Safer Technologies and Alternatives Analysis (STAA)

  • A STAA evaluation is required for all Program 3 NAICS 324 and 325 processes.
  • A Practicability assessment of inherently safer technologies and designs (IST/ISD) should be considered if your process falls within one of these conditions:
    • It’s a Program 3 under NAICS 324 and 325 within one mile of another Program 3 NAICS 324 or 325 process,
    • It’s a process under NAICS 324 using with hydrofluoric acid alkylation,
    • You’ve had one RMP accident since the facility’s most recent process hazard analysis.
  • Implement at least one passive measure at the facility, or IST/ISD, or a combination of active and procedural measures equivalent to or greater than the risk reduction of a passive measure for the same facilities required to conduct the practicability assessment.
  • When STAA recommendations are not adopted, then you must provide justification.

Communication

  • The facility must now provide chemical hazard information, upon request, to residents living within 6 miles of the facility in the language they request.

Other

  • Hot work permits must be kept for 3 years.
  • Program 2 and Program 3 requirements should be consistent for recognized and generally accepted good engineering practices.
  • Program 3 process safety info must be kept up to date.

Compliance Dates

The SCCAP is effective May 10, 2024.  There are two separate compliance dates.  Emergency response field exercise frequencies are due by March 15, 2027, or within 10 years of the date of an emergency response field exercise conducted between March 15, 2017 and August 31, 2022.

The following items are due three years after Final Rule publication (May 10, 2027)

  • Root cause analyses
  • Third-party compliance audits
  • Safer Technologies and Alternatives Analysis (STAA)
  • Employee participation
  • Emergency response public notification
  • Exercise evaluation reports

More Information

If you have questions or need assistance in determining if your facility is required to comply with RMP, or if you need help getting one setup, contact us!

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Grade D Breathing Air: What Requirements Do I Have to Meet for My Breathing Air System?

Grade D Breathing Air: What Requirements Do I Have to Meet for My Breathing Air System?

Feb 27, 2024

Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air and then we’ll cover what its OSHA requirements are.

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility.  Some of the most common include:paint booth worker

  • Confined Space Entry
  • Sand/Media Blasting Operations
  • Working in Paint Booths
  • Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following:breathing testing

  • Oxygen content percentage by volume: Between 19.5% and 23.5%
  • Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
  • Carbon monoxide: maximum of 10 parts per million by volume
  • Carbon dioxide: maximum of 1000 parts per million by volume
  • Lack of noticeable odor

This breathing air gases are also commonly referred to as Grade D breathing air.  There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

Questions?  Need Help?

iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients.  We can also help you with the other breathing air system requirements of OSHA.  Contact us today!

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iSi can help with Grade D breathing air testing, required written plans, training and more! 

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Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air components, then we’ll cover its OSHA requirements.

paint booth worker

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility.  Some of the most common include:

  • Confined Space Entry
  • Sand/Media Blasting Operations
  • Working in Paint Booths
  • Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following:

  • Oxygen content percentage by volume: Between 19.5% and 23.5%
  • Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
  • Carbon monoxide: maximum of 10 parts per million by volume
  • Carbon dioxide: maximum of 1000 parts per million by volume
  • Lack of noticeable odor

breathing testing

This breathing air gases are also commonly referred to as Grade D breathing air.  There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

Questions?  Need Help?

iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients.  We can also help you with the other breathing air system requirements of OSHA.  Contact us today!

Need Help?

iSi can help with Grade D breathing air testing, required written plans, training and more! 

Get Pricing

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

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

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What is a Phase II Environmental Site Assessment?

What is a Phase II Environmental Site Assessment?

Feb 17, 2023

What is a Phase II?

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

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

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

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

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

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

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

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

When Do I Need a Limited Phase II ESA?

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

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

Who Pays For A Phase 2 ESA?

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

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

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

How Long Does a Phase 2 ESA Take?

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

How Much Does a Phase 2 Environmental Study Cost?

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

What Is The Final Goal of a Phase 2 Assessment?

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

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

Conclusion:

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

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

Need Help?

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

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

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

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

Dec 1, 2022

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

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

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

Electronic Reporting

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

HAP Content

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

Spray Gun Cups and Liners

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

Exemptions Became Easier

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

Military Equipment: Tanks and Submarines

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

OSHA Carcinogen References

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

No Non-HAP Solvents

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

Filter Test Method

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

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

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

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The Comprehensive Guide to an Environmental Audit Checklist

The Comprehensive Guide to an Environmental Audit Checklist

Nov 6, 2022

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

Decoding Environmental Compliance

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

The Importance of Environmental Audit Reports

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

The Role of an Environmental Compliance Audit

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

Unpacking the Audit Checklist

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

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

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

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

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

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

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

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

The Depth of Functional Environmental Audits

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

Understanding Environmental Laws

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

The Role of Regulatory Agencies

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

The Impact of a Company’s Environmental Performance

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

The Importance of a Detailed Regulatory Checklist

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

Final Thoughts on Environmental Compliance

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

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

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

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

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

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Mining Testing

Mining Testing

Oct 27, 2022

​

What is it?

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

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

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

What are the different types of mining tests?

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

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

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

How do you test for mineral content?

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

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

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

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

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

What does a mining consultant do?

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

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

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Waste Disposal Facility Audit Checklist

Waste Disposal Facility Audit Checklist

Sep 10, 2022

What is a waste audit?

There are two types of audits: manual and automated.

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

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

How do you plan a waste audit in an organization?

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

What are the steps involved in a waste audit?

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

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

What is included in a waste audit?

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

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

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

What are the 7 principles of solid waste management?

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

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

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

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

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

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

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

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

Steps following an waste disposal facility audit:

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

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Environmental Protection Agency (EPA) Audit Policy

Environmental Protection Agency (EPA) Audit Policy

Sep 4, 2022

United States Environmental Protection Agency Audit Policy: 101

The Environmental Protection Agency (EPA) is committed to protecting and preserving the environment for all of us, which means ensuring that businesses across the country are following EPA policies. To do this, the agency performs audits on companies in order to ensure compliance with EPA standards.

This includes checking documents and records, sampling chemicals and other materials, evaluating waste management practices, testing equipment, observing production processes, interviewing employees, etc. The goal of each audit is to identify any potential violations or areas of non-compliance with the law.

After completing an audit, the EPA will issue a report outlining its findings and recommendations. Typically, the report will include areas of non-compliance, along with suggestions for corrective action to ensure compliance in those areas. Companies are then required to submit a written response to the audit and provide evidence that steps have been taken to address any issues identified by the EPA.

It is important for companies to be aware of their responsibility and obligation when it comes to environmental protection. The Environmental Protection Agency Audit Policy provides businesses with an opportunity for self-evaluation and proactive strides towards ensuring compliance with all relevant regulations and laws. As such, it is essential that companies remain up-to-date regarding changes in policy or procedure, regularly review their operations and practices, and work diligently to resolve any violations or problems discovered during audits. By doing so, companies can help to ensure a safe and healthy environment for everyone.

An important part of the Environmental Protection Agency Audit Policy includes being able to respond effectively to any audit report issued by the agency. Companies should contact an environmental attorney who is knowledgeable about the requirements outlined in the EPA’s Audit Policy, as well as any applicable state or local laws that may be relevant. In addition, they should develop a detailed plan of action outlining how they intend to resolve any issues identified during an audit and provide evidence of their compliance with all applicable standards. By doing so, businesses can help demonstrate their commitment to protecting the environment and set a positive example for others in their industry.

At the end of the day, businesses have a responsibility to protect the environment and ensure compliance with all applicable laws. Companies who take advantage of this policy are helping to set a positive example for others in their industry and create a healthier future for everyone.

EPA’s Interim Approach to Applying the Audit Policy to New Owners | US EPA

The Environmental Protection Agency (EPA) has developed an Interim Approach to Applying the Audit Policy to New Owners, which provides tailored incentives for new owners of facilities that have been found to be non-compliant with environmental laws prior to acquisition. This approach allows new owners to make a “clean start” by addressing any noncompliance that began before they obtained ownership of the facility.

This Audit Policy incentives include compliance assistance and technical advice, potential reduction in penalties and civil enforcement actions, reimbursement for environmentally beneficial projects, and protection from certain criminal prosecution related to pre-acquisition violations. These incentives are designed to encourage responsible parties at newly acquired facilities to address existing noncompliance issues quickly and effectively through voluntary disclosure or corrective action. By taking advantage of EPA’s Audit Policy incentives, new owners can ensure compliance with environmental statutes and make a fresh start.

What are the benefits of an EPS audit?

The EPA believes that having audits conducted allows organizations to make better-informed actions, optimize performance levels, and ensure sustainable success over the long term..

An EPS audit is a valuable tool for assessing the financial health of an organization. It provides an objective overview of a company’s performance and can help identify areas where improvements or corrective actions may be needed. An EPS audit can also serve as an key preventative measure, providing insight into potential problems before they become catastrophes.

At the same time, it can help to enhance processes and procedures that are already in place by giving management a comprehensive look at their current operations and financial position.

What types of companies are required to perform and environmental audit?

Environmental audit reports are useful to a variety of businesses and industries, local, state and federal government facilities, as well as financial lenders and insurance companies that need to assess environmental performance. Audit reports can be extremely useful for businesses, governments, and financial lenders in understanding the environmental performance of a given facility. They provide detailed information on air emissions, water usage, waste management systems, hazardous materials management practices and storage procedures.

This data is key to ensuring that facilities are meeting regulatory requirements and following industry best practices. Additionally, environmental audit reports may be necessary to meet contractual requirements with customers or other third parties. Finally, financial lenders may use these reports to assess risk associated with a particular project or investment opportunity in order to make informed decisions on whether to lend money or not. Ultimately, environmental audit reports are an essential part of ensuring continual compliance as well as business sustainability.

Who conducts EPA audits?

EPA audits can be conducted by internal auditors, external auditors, and third-party verification organizations.

Internal auditors usually have knowledge and expertise in the specific area being audited, such as environmental protection, energy efficiency or sustainability. External auditors are independent third-party experts who assess and evaluate compliance with EPA ordinances Finally, third party verification organizations provide impartial assessments to verify the effectiveness of an organization’s systems for meeting specific standards. Each type of audit provides its own unique benefits, ensuring that thorough and comprehensive evaluations of facility operations take place.

Through careful review and assessment of procedures, policies and practices, these audits ensure that organizations remain compliant with EPA statutes.

How often are EPA audits required?

Once every three years.

According to the regulations at 40 CFR §§68.58(a) and 68.79(a), owners or operators must certify that they have completed a compliance evaluation of their prevention program every three years in order to ensure that established procedures and practices are adequately maintained and followed.

This process requires the tangible review of all applicable documents, including but not limited to safety protocols, emergency response plans, operating manuals, training records, inspection reports and other relevant documentation.

By completing this certification process on a regular basis, owners or operators can maintain regulatory compliance while helping to protect their employees and fix environmental issues.

What is an environmental audit protocol?

Audit protocols can help facilities evaluate their compliance with environmental laws. They provide guidance on how to develop a plan of action to address any issues and may include information on testing, monitoring, or other practices that are necessary for the facility’s success in meeting environmental requirements.

The protocols should be seen as a supplement to existing permits, statutes and laws; however, these guidelines must still be followed in order to ensure legal compliance. Audit protocols also provide a framework for more efficient evaluation of compliance status, helping facilities save time and resources when assessing their operations.

Why is it necessary for businesses to be sustainable?

Sustainability is becoming increasingly necessary in the business world, as businesses look to adopt greener technologies and practices that benefit both their bottom line and the environment. Sustainable businesses are able to make better use of resources while reducing costs, resulting in greater profits and job security for employees. Smaller businesses can also benefit from sustainable practices, as they often find it difficult to compete with larger organizations due to lower capital investments. An example of such is the The Clean Air Act (CAA) (42 U.S.C. 7401 et seq.) is a comprehensive Federal law that regulates all sources of air emissions.

By adopting more efficient methods and technologies, smaller businesses have the potential to become competitive players in the market. Furthermore, sustainability has a positive impact on employment by ensuring better working conditions for employees; this helps create a more stable economy and helps protect human health. Ultimately, sustainability is essential for creating an economically viable future for businesses, employees, and the environment. By taking strides towards a more sustainable business model, companies can create long-term value for their stakeholders and ensure a brighter future for everyone.

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Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Jun 15, 2022

How to Incorporate a Sustainability Action Plans Into Your Preconstruction Submittals

A Sustainability Action Plans (SAP) is a critical part of any successful sustainable construction project and sustainable business. By creating and implementing a SAP, you can ensure that your construction project will be environmentally responsible and meet or exceed all applicable environmental sustainability standards. These action plans are designed to help both the environment and your build in the present and future. A few issues that it can aid is renewable energy, air pollution, climate change, as well as many other environmental issues. In this article, we will discuss how to incorporate Sustainability Action Plans into your preconstruction submittals.

If you’re a construction project manager, then you know that preconstruction submittals are a critical part of the process. If you are working on a federally funded project, then you have probably been asked to include Sustainability Action Plans and Sustainability eNotebooks.

Incorporating a sustainable action plan into your preconstruction submittals can be a challenge, but it’s worth the effort. Here are six tips to help you get started:

  1. Define what sustainable features are required to include in your project (ie. Sustainability performance, energy usage, etc.)
  2. Do your research on which sustainable materials are available and how they can be used (ie. recycling bins)
  3. Work with your architect and engineers to see how these materials can be incorporated into the design
  4. Make sure that the contractors you hire are aware of your sustainability goals and are willing to work with you to achieve them
  5. Be prepared to make some sacrifices – not all sustainable materials are going to meet project specifications, be prepared to clarify why they won’t work
  6. Remember that a sustainable project is an investment in the future, both for yourself and for the planet

By following these tips, you’ll be on your way to creating a more sustainable construction project!

Define what sustainable features are required to include in your project

Guiding principles and requirements for a viable project are essential and include elements of energy efficiency, bioswales, green roofs, renewable sources, and an effective waste management plan.

These guiding principles should be woven in with the initial design and planning stages of any project to ensure that it is both efficient and environmentally conscious. Any development must maintain the guiding principles set out as required by law. In addition, developing a waste management plan that can be implemented during construction and throughout the life-cycle could be beneficial from a cost perspective as well as from an environmental one.

Sustainable features should always factor into any project if you are looking to keep your operations on track, make your customers happy, and show you are a green business.

Do your research on which sustainable materials are available and how they can be used

If you’re looking to create a sustainability plan, one of the keys to success is researching and finding sustainable materials that can be used to reduce overall waste.

With a wealth of options available today, it pays off to put in the effort to find the viable and suitable sustainability initiatives that can be incorporated into your projects. Sustainable products come at various prices and have different strengths and energy efficiency profiles, so it’s important to evaluate them thoroughly for each project.

Doing your research upfront will ensure you are making informed decisions about incorporating sustainability into your operations. Time spent now creating a sustainability plan will pay off big time in the future!

Work with your architect and engineers to see how these materials can be incorporated into the design

Working with your architect and engineers is the key to successfully incorporating new materials into the design. It’s important to have a well-thought out plan for how best to use these materials so that you get the most out of them without wasting resources.

Take advantage of the insight, knowledge and experience available from your team of professionals – clearly communicate your vision and objectives, then take their advice on board to ensure a successful outcome. Time spent discussing with your architect and engineers upfront is much more profitable than trying to figure it out yourself later down the track.

Make sure that the contractors you hire are aware of your sustainability goals and are willing to work with you to achieve them

If you’re serious about sustainability, you need to make sure that the contractors you bring on have the same commitment. It’s not enough for them to just say they support your goals; they need to also be willing to put in the work and effort.

Do a thorough vetting process and make sure that any personnel working with you are willing to do their part in meeting environmental objectives. If not, it defeats the purpose of having those goals in the first place.

Don’t let anyone slip through the cracks — be vigilant and ensure contractors are up-to-speed on your sustainability plans or else keep looking until you find someone who is.

Be prepared to make some sacrifices – not all sustainable materials are going to meet project specifications, be prepared to clarify why they won’t work

Sustainable materials are integral to any project, but you’ve gotta be prepared to make some sacrifices along the way. While not all sustainable materials may meet your specifications, it’s paramount that you understand why and explain that reasoning.

Don’t expect every viable alternative to perfectly fit your criteria – compromise is the name of the game in order to ensure that our work is as future-proof as possible. Taking shortcuts here will likely come back to bite you down the road, so don’t be afraid to get into the nitty-gritty of why a particular material won’t work for your needs – it could end up being an invaluable lesson.

Remember that a sustainable project is an investment in the future, both for yourself and for the planet

When it comes to sustainability, no effort is too small. Investing in projects that are meant to minimize human damage and preserve the planet for generations to come is essential; if we don’t look out for our environment, nobody else will.

It’s a matter of personal responsibility – taking charge of our own impact on the world around us and recognizing that every action we take can have positive or negative ramifications. It may be expensive up front, but a sustainable project is an investment in both your future and the future of the planet, guaranteed to pay dividends in more ways than one.

For instance, the resources in your project specific Sustainability Action Plans can be converted directly in to a corporate level sustainability program, helping to reduce waste on future projects as well.

Sustainability is important for a number of reasons. It’s not just about being environmentally friendly or socially responsible – though that is certainly part of it. It’s also about creating a project that will be able to stand the test of time, both in terms of its physical durability and its relevance to the needs of future generations.

Developing a sustainable project can be challenging, but it’s definitely worth the effort. If you need help getting started, don’t hesitate to reach out. We’re happy to assist you in developing and implementation of a Sustainability Action Plan for your next Federal Project.

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EHS Management Software

EHS Management Software

Jun 9, 2022

What does EHS stand for?

EHS stands for Environmental, Health, and Safety. This is an important area of focus for many organizations, as it involves making sure that the environment is safe and healthy for employees to work in. It includes creating policies and procedures related to air quality, safety observations, hazardous materials, fire safety, ergonomics, waste management, electrical safety and more. EHS also ensures that employees are trained and kept up to date on safety protocols in order to reduce the risk of accidents and injuries.

EHS professionals and EHS managers strive to create a safe work place and prevent accidents , which is beneficial for both workers and employers alike. By promoting safe practices, companies can save money by reducing liability risks as well as improve employee morale due to a healthier work place. Ultimately, EHS is a key factor in ensuring the safety and well-being of everyone in the workplace.

What are the responsibilities of EHS department?

EHS stands for Environmental, Health and Safety. It refers to the practices of protecting the environment and ensuring that safe health and safety standards are maintained in a workplace or facility.

EHS involves monitoring air quality, assessing hazardous materials and waste disposal as well as ensuring a safe working environment for employees. It also involves educating employees on safe work practices and ensuring that all laws and regulations are followed.

EHS is an important factor in any workplace, as it ensures that employees are safe, the environment is well protected and health risks minimized. It also helps businesses meet their legal obligations to protect the earth and ensure a safe working environment for its workers.

What is an EHS hazard?

An EHS hazard is any activity or circumstance with the potential to cause harm to people, property, or the environment. These hazards can range from physical dangers such as working with hazardous materials, slips and trips in the workplace, and confined space entry to more intangible risks such as mental health issues due to stress and fatigue.

Identifying EHS hazards and developing strategies to address them is an essential part of any safety management system. It is important to take the time to assess all potential risks and develop a comprehensive safety plan before beginning work in any area. Doing so will help protect employees, customers, and the environment from harm while also keeping fines and costs low.

What is an EHS management system?

An EHS management system (or EMS) is a comprehensive approach to managing an organization’s environmental, health and safety program. It covers the full range of activities necessary to meet legal obligations, improve performance and reduce risks.

An effective EHS management system helps to identify and prioritize areas of risk or concern as well as create consistent processes for dealing with any identified risks. It provides a structured framework for continuous improvement and sets out procedures for monitoring and auditing the system to ensure that it is effective.

Additionally, an EHS management system can be used as a tool to manage regulatory compliance, identify operational efficiencies and support organizational sustainability initiatives. An EHS management system can help businesses move towards a more sustainable and responsible future.

Why is EHS management needed?

EHS management is essential in any institution or organization, regardless of its size or industry. It establishes a safe and healthy work environment while minimizing the risk of injury, illness, and damage to the environment.

EHS management programs seek to identify, manage, and mitigate potential hazards by implementing a systematic approach to safety and health. They ensure compliance with regulatory requirements and help avoid costly fines and legal liabilities.

Furthermore, adopting EHS management practices can boost employee morale, increase productivity, and improve a company’s reputation as a responsible and sustainable business. Organizations that prioritize EHS management can decrease workplace incidents, enhance operational efficiency and performance, and ultimately add significant value to their business.

EHS and The Environment

EHS is a vital component of corporate social responsibility, and it is essential to preserve our natural environment. EHS departments work tirelessly to ensure that buisnesses do not harm the environment through their activities. EHS protects the environment in several ways.

Firstly, it formulates strict guidelines for waste disposal, air quality, and water management, which companies must comply with. Secondly, EHS conducts environmental audits, monitor energy consumption, and tracks carbon emissions to ensure companies adhere to sustainable practices. Furthermore, EHS also collaborates with government agencies to design new environmental policies and keeps abreast of the latest regulatory changes to ensure businesses comply promptly and maintain a clean slate.

Finally, EHS promotes environmental awareness throughout the company and educates employees about sustainable practices that can help save energy and reduce waste. Therefore, EHS is one of the most crucial departments in preserving our planet’s health, and we should support their work.

What Is EHS Software?

EHS software is a technology solution that helps organizations manage workplace safety and reduce environmental risks. The software typically includes modules for occupational health and safety, environmental compliance, incident management, risk assessments, audits, and reporting.

EHS system enables businesses to implement their EHS processes and improve visibility into their EHS performance, allowing them to proactively identify and address potential risks. Additionally, EHS software helps businesses comply with regulations and standards such as OSHA, EPA, and ISO 14001, which can ultimately reduce legal and financial risks.

With the increasing focus on sustainability and corporate social responsibility, EHS system is becoming an essential tool for businesses to ensure they operate ethically and responsibly.

ComplianceQuest and Salesforce – a winning combination

ComplianceQuest is the leading cloud-based enterprise compliance and quality management platform. It offers integrated solutions for a wide range of industries, including healthcare, aerospace, manufacturing and life sciences.

The platform provides tools that streamline processes such as document management, audit tracking, risk assessment and corrective action management. The platform can also be customized to fit any organization’s unique needs. ComplianceQuest is seamlessly integrated with Salesforce, providing customers with an even more powerful solution for meeting their compliance and quality goals.

By leveraging the power of Salesforce, customers can easily access compliant data, improve risk management and optimize operational efficiency. With ComplianceQuest’s integration into Salesforce, organizations have an easy to use, comprehensive tool to ensure compliance and quality in their operations.

How can CQ EHS Management Software help companies?

ComplianceQuest EHS Management Software provides companies with a powerful, easy-to-use platform to help them meet their environmental, health and safety (EHS) goals. Its cloud-based system offers an intuitive user experience and advanced analytics to provide comprehensive visibility into organization’s EHS status.

With ComplianceQuest, companies can create customized dashboards to track data, manage tasks and stay on top of issues in real-time. The software also features automated workflows, notifications and corrective action tracking that help ensure compliance with local, state, national and international regulations.

By using ComplianceQuest EHS Management Software, companies can proactively manage their risks and resources to achieve a better environmental health and safety performance.

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Sustainability Consulting for the 21st Century

Sustainability Consulting for the 21st Century

Mar 1, 2022

The modern world is a sustainable one. It’s time for your business to join the ranks of those who are making a difference.

Sustainability has become one of the most important topics of our time. As the world becomes more and more aware of the environmental, social, and economic challenges we face, more and more businesses are looking for ways to operate in a more sustainable way.

That’s where sustainability consulting comes in. A sustainability consultant helps businesses identify opportunities to operate in a more sustainable way. This can mean anything from reducing energy consumption to increasing employee engagement in sustainability goals.

Sustainability consultants come from a variety of backgrounds, but all share a common goal: to help businesses move towards a more sustainable future with sustainability services.

The good news is that sustainability consulting is one of the fastest growing industries in North America and the world. The bad news is that it can be hard to know where to start when it comes to finding a sustainability consultant that’s right for your business.

Here are four tips to help you find the right sustainability consultant for your business:

1. Define your sustainability goals and ESG strategy.

What does your business want to achieve by working with a sustainability consultant? Do you want to reduce your carbon footprint in your global business? Develop more robust sustainability strategies? Achieve sustainable development goals? Incorporate sustainability solutions and a sustainable infrastructure into your business strategy? Improve employee engagement? Need risk management? Find ways to save money.

Once you know what you want to achieve, you can start looking for consulting firms that specialize in those areas.

2. Identify a budget.

Do your sustainability ambitions match resources available for the project? Does the ESG (Environmental Social and Governance) strategy align with your corporate growth strategy?

It is recommended to present a sustainability strategy internally, that outlines tiers of investment and the types of sustainability performance to be expected per expenditure.

3. Do your research.

Do a deep dive in the sustainability consulting services universe. Once you’ve identified some consulting firms that might be a good fit, take some time to learn about their backgrounds and experience and nail it down to your favorite consulting firm.

How long have they been working in a sustainable business? What are some of the clients they’ve worked with? What do other people say about them? Top consulting firms offer diverse corporate responsibility solutions and professional services across a wide swathe of industry sectors.

4. Ask for recommendations.

Talk to other businesses in your industry and see if they’ve worked with any sustainability consulting firms that they would recommend. If you know someone who works in sustainable business, ask them for their thoughts on different consultants.

The best way to find a good consultant in the large world of the consulting industry is through word-of-mouth from people who have worked with them before.

A global management consultancy will have the general pulse on corporate social responsibility. Top sustainability consulting firms will be a global leader in change management and integrated business planning.

The best ones possess deep expertise in the management of business risk and climate risk, while working with you to embed sustainability into your culture.

These days, there’s no excuse for not being sustainable, not manage risk, and not create sustainable business models.

Future leaders and businesses that don’t take steps to operate sustainably will not only be missing out on opportunities and losing business value, but will also be left behind as society progresses towards a more sustainable future.

These can be complex problems. Sustainability consulting is one of the best ways for businesses to make sure they’re operating sustainably and making a positive impact measurement on the world around them.

iSi Environmental is a leading provider of environmental consulting and management consulting services in the United States and we are committed to protecting the planet and its inhabitants with the skills and knowledge of our people. With us you get long term value.

Senior Executives and Sustainability Teams turn to us when:

  • Their team is short on time and resources to achieve organizational sustainability strategy
  • They need hands-on implementation of new compliance processes
  • They need to integrate sustainability at multiple locations
  • Also turn to us when looking to roll local best practices into a global corporate system

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Sustainability is Much More Than Just Being Green

Sustainability is Much More Than Just Being Green

Feb 22, 2021

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

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

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


Goals of Sustainability

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

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


Sustainability Areas

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

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

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

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


What Can Sustainability Include?

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

Internal

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

External

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


Other Applicable ISO Standards

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

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

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


Where Do You Start?

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

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

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

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

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

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


How Do You Track Success?

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

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

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


In Conclusion

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

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


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

iSi's Sustainability Services

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

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Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

Nov 19, 2020

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The effects of chemical exposures in the workplace has been highly documented.  Chemicals can affect you when you breathe them in, ingest them, inject them or absorb them through your skin.  However, did you know that chemicals can cause hearing loss too?

What is Ototoxicity?

Chemicals which can contribute to hearing loss are called “ototoxicants” and the hearing loss itself is considered to be “ototoxicity.”  Ototoxic chemicals reach the inner ear, connected pathways and nerve fibers through the blood stream or through the ear’s hair cells.  Hearing losses can range from sound distortion to the inability to detect two sounds with similar frequencies to inabilities to detect time gaps between sounds or localize sound.

The problem increases when there is a noise exposure combined with the exposure to an ototoxicant.  Ototoxic chemicals make a bigger impact on noise exposure, especially impulse noise.  Ototoxic chemicals plus noise becomes worse than just the noise alone or the chemical alone.   The noise levels do not even need to be above OSHA’s Permissible Exposure Limit (PEL) standards.  It’s the combination of the two which causes the greatest damage.

Which Chemicals Are Considered Ototoxic?

  • Pharmaceuticals: aspirin, some antibiotics, NSAIDs, loop diuretics
  • Tobacco smoke
  • Solvents, degreasers and paints containing toluene, p-xylene, styrene, ethylbenzene, methylstyrene, trichlorethylene, carbon disulfide, n-propylbenzene or n-hexane
  • Carbon monoxide
  • Hydrogen cyanide
  • Nitriles: 3-butenenitrile, cis-2-pentenenitrile, acrylonitrile, cis-crotononitrile and 3,3’-iminodipropionitrile
  • Metals and compounds: mercury, lead, organic tin and germanium dioxide
  • Pesticides: pyrethroids, hexachlorobenzene, insecticides or organophosphates
  • Some limited research has also speculated arsenic, cadmium, halogenated hydrocarbons, bromates, alkylic compounds and manganese may also affect ototoxicity

Which Industries or Operations May be Affected?

  • Manufacturing
  • Construction
  • Printing
  • Painting
  • Fueling vehicles and aircrafts
  • Firefighting
  • Weapons firing (Military)
  • Pesticide spraying

How Do You Test for Otoxicity?

Determining whether you have the potential for this condition is primary.  First, conduct a risk assessment to determine if your operations could be affected. 

Check the Toxological Information section of the chemical’s Safety Data Sheet (SDS Section 11) to see if the chemical is considered a neurotoxicant.  If there is nothing listed in this section, often other clues can be found in the SDS such as general toxicity, nephrotoxicity or if the chemical produces reactive free radicals.

From there, exposure limits and thresholds are dependent on different factors such as the chemical itself, exposure routes, concentration, duration, noise exposure and individual risk factors such as age.  Workplace sampling will be able to help you quantify your exposures. 

Audiogram tests can show early onset of hearing impairments and threshold shifts.   However, they cannot tell you the difference between whether the impairment is noise-related or ototoxic-related.  If you have complaints of hearing loss, investigate whether ototoxicity could be a factor.

The American Conference of Governmental Industrial Hygienists (ACGIH) recommends periodic audiograms for those who have noise exposures combined with carbon monoxide, hydrogen cyanide lead and solvent mixtures.  When there’s not a noise exposure, ACGIH still recommends audiograms be used when workers have the potential to be exposed to ethylbenzene, styrene, toluene or xylene.

PPE and Training Requirements

Make sure you reduce the effects of ototoxic chemicals in your workplace either through controls such as isolation, limiting exposures, or eliminating unnecessary tasks, or through the use of PPE.  Conduct your PPE assessment per OSHA rules.  You may need to include proper hearing protection, as well as PPE which can prevent inhalation (respirators), or absorption through the skin (chemical gloves, arm sleeves, aprons).

If you have a potential for ototoxic chemical exposure, this also needs to be included in your Hazard Communication (HAZCOM) training. 

Does This Affect You?

Do you have the potential for ototoxicity in your workplace?  iSi can help you make that determination, conduct your risk assessment, and/or quantify your exposures through sampling.  Contact us today!

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

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

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

Jul 23, 2020

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

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

What is Beryllium?

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

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

Exposure Assessments and Limits

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

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

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

Written Exposure Control Plan

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

PPE

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

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

Beryllium Work Areas

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

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

Medical Monitoring

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

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

Worker Training 

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

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

Recordkeeping 

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

Other 2020 Changes

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

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

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

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

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

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Industrial Hygiene in Construction: Focus Four Health Hazards

Industrial Hygiene in Construction: Focus Four Health Hazards

Jul 9, 2020

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

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

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

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


Manual Material Handling

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

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


Noise

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

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

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


Air Contaminants

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

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

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

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

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

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


High Temperatures

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

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

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

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


In Closing

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

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

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

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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.

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EPA Adds 1-BP to Clean Air Act Hazardous Air Pollutants List

EPA Adds 1-BP to Clean Air Act Hazardous Air Pollutants List

Jun 25, 2020

EPA has added 1-bromopropane (1-BP), aka n-propyl bromide, to its list of hazardous air pollutants under the Clean Air Act.  This is the first time since 1990 that EPA has added a chemical to the list from a petition request.

The CAS number for 1-BP is 106-94-5.

How is 1-BP Used?

1-BP is found in products for the following applications:

  • Adhesive sprays
  • Solvent sprays for asphalt production, aircraft maintenance, and synthetic fiber manufacturing
  • Vapor and immersion degreasers for cleaning plastics, metals, electronic components and optical components
  • Dry cleaning
  • Spot removers
  • Coin cleaners
  • Paintable mold release products
  • Automotive refrigerant flushes
  • Lubricants

Which EPA Compliance Obligations Will This Affect?

Since the change is part of the Clean Air Act, you will need to take note that this will affect the following EPA reports and permits:

You should also now start tracking the quantities purchased and used to help you with these reports.

What is the Hazard?

1-BP can be inhaled as a vapor or mists of spray and can also be absorbed through skin contact.   It is colorless with a sweet odor.  It can cause irritation of the eyes, nose and throat, and can damage the nervous system.  Women of childbearing age are cautioned that prolonged exposure can cause developmental and reproductive effects.  Extreme cases can cause kidney and liver issues as well as neurological issues such as dizziness, loss of consciousness, slurred speech, confusion, twitching and difficulty walking.  

Some people have experienced symptoms with use as little as 2 days, but most cases have effects after long-term exposure.

Make Sure You Know Your Exposures

If your company is using products with 1-BP, please make sure you are conducting industrial hygiene sampling of your employees and their usage of 1-BP to identify what their exposures are.  The American Conference of Governmental Industrial Hygienist’s (ACGIH) threshold limit value for 1-BP is a very low 0.1 ppm, so any exposures over that will require respiratory protection.

iSi has conducted 1-BP sampling for two of our clients within the past year.  Each were using vapor degreasers with 1-BP in them.  Exposures measured at 3.74 ppm for one company and 49.5 ppm for another.  These were very well above the recommended 0.1 ppm and each company needed to change protocols to get the exposures down.

PPE and Administrative Controls

Besides respiratory protection when limits are over the thresholds, both EPA and OSHA recommend usage of chemical protective gloves/clothing and eye protection when handling 1-BP. 

OSHA has specific recommendations for eliminating the hazard altogether through isolation, ventilation and other engineering controls.  Some administrative controls they recommend include reducing both the time and number of workers exposed to the chemical, purchasing and storing the least amount possible and keeping containers closed between use.

Because of the hazard, there are other products now on the market that can be used for the same functions that do not have 1-BP in them.

Get 1-BP fact sheets on the EPA website here and on the OSHA website here to learn more.

Questions?

If your company is using 1-BP and you have questions on how it will affect your compliance reporting and tracking obligations, we can help!  Email us or contact us by phone.

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1-BP Assistance

If you need help determining how this new rule will affect your air reporting, or if you need 1-BP exposure sampling to see where you stand, contact us today!

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

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

May 28, 2020

UV Light for Your HVAC

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

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

What is UVGI?

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

Ultraviolet light can be broken down into 4 different bands:

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

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

UV light spectrum

How does UVGI work?

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

UV light

Wall-mounted UV light system.

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

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

iSi light frame

UV light for HVAC system.

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

UV Safety Considerations

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

UV Lighting for Your HVAC Units

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

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

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Return to Work Building Issues: Stagnant Water

Return to Work Building Issues: Stagnant Water

May 1, 2020

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.

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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

Mar 20, 2020

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.

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

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

Oct 18, 2019

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!

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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!

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

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

Dec 6, 2018

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.

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