Who Needs DOT Hazmat Training?

Who Needs DOT Hazmat Training?

Apr 12, 2024

Photo of a person preparing a hazmat package for proper shipping.

Often we get the question, “Who needs DOT hazmat training?”  Not only are there nuances between the various agencies of DOT and the international transportation organizations DOT defers to, but often in companies there could be a number of people involved in the process – knowingly or unknowingly.

Basically, anyone involved in the process of sending hazardous materials (hazmat) will need to be trained. This would include anyone who:

  • Purchases the packaging and/or determines it’s the correct packaging for your materials;
  • Prepares the package for sending (boxes, labels, determines which box to use, etc.);
  • Fills out the paperwork, choosing labels or choosing placards;
  • Signs off on manifests or paperwork (including sending hazardous waste);
  • Loads, unloads, and handles hazmat;
  • Sells, tests, reconditions, repairs or modifies packaging for use in shipping hazmat;
  • Screens baggage, cargo, or mail;
  • Transports hazmat or operates a vehicle transporting hazmat;
  • Is a freight forwarder who accepts/transfers/handles/unloads cargo; and,
  • Anyone who supervises or conducts training for any of the above personnel.

Who Could be Involved?

So this could involve multiple departments or people at your company.  Roles such as:

  • Shipping & Receiving
  • Mailroom Clerks
  • Environmental, Health and Safety People
  • Hazardous Waste Handlers/Manifest Signers
  • Administrative Staff
  • Procurement/Purchasing and Finance
  • Warehouse
  • Plant Personnel
  • Operations Management

Take a look at your process. Who’s involved? Do they need to be involved? Have they been trained?

Training Content

DOT training is required by 49 CFR 100-185.  49 CFR regulates all hazmat shipments for the following agencies of the Department of Transportation:

  • Pipeline and Hazardous Materials Security Administration (PHMSA)
  • Federal Aviation Administration (FAA)
  • Federal Motor Carrier Safety Administration (FMCSA)
  • Federal Railroad Administration (FRA)
  • State agencies with authority to enforce DOT regulations

Your training content is required to include general awareness, security awareness, safety and then function-specific training to the role each person is doing in the process.  So the training durations could be different for different roles.

What if Someone Ships Hazmat For You?

Even if you have a third-party do the packaging for you, your company is still the shipper of record. That means anyone involved in the process from your end, even if it’s just one person signing paperwork that your vendor prepares, will need training.  By signing paperwork, that employee is legally certifying the hazmat is properly packaged and ready for transport. This would apply to companies you use for hazardous waste transports, crate building, or freight forwarding.

Planes, Trains and Automobiles (and Ships)

If your packages are going by ground, that is, truck or train, you’ll need DOT training with refreshers every three years. There are additional railroad regulations that need to be covered if you’re shipping by rail.

If packages are going by plane, such as overnight service, you’ll need separate IATA training with refreshers every two years. Please note that unless you specify your hazmat as “ground only”, there’s a possibility it could be put onto an airplane.  IATA has their own set of regulations in addition to the DOT, and air regulations are also covered in 49 CFR.

If packages are going on a ship, you’ll need IMDG training with refreshers every three years. This not only includes overseas shipments, but shipments to U.S. states such as Hawaii and Alaska or territories like Puerto Rico.

For more information about how the agencies work together, read our blog article, “Who Regulates Hazmat Shipments?”

If you need help sorting out who should be trained, or if you have employees you know need training or refreshers, contact us and we’d be happy to help! Check out our current hazmat shipping training schedule.

 

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What is PSM?

What is PSM?

Feb 26, 2024

Process Safety Management, or PSM, is an OSHA regulation that is concerned with processes at your facility that use highly hazardous chemicals.  PSM provides a compliance framework to evaluate each process with the end goal of no spills, fires, explosions, reactions, releases or other incidents arise from their use.  The official standard can be found at 29 CFR 1910.119.

PSM applies to

  • Processes which involve certain threshold quantities of chemicals listed in the standard’s Appendix A
  • Processes where there are 10,000 lbs. or more of a Category I flammable gas (per 1910.1200(c)) or flammable liquids with a flashpoint below 100 degrees on site in one location
  • Manufacturing explosives or pyrotechnics in any quantity

Exceptions to these include retail facilities, hydrocarbon fuels for workplace consumption of fuels, oil or gas well drilling or servicing operations and unoccupied remote facilities.  Facilities with flammable liquids with a flashpoint below 100 degrees that are stored in atmospheric tanks or that are transferred below their normal boiling point without being refrigerated are also exempt.

The 14 Elements of Compliance

There are 14 elements to a Process Safety Management compliance program.  These include:

 1.  Employee Participation

Those who are most familiar with the process need to be involved.  Facilities must have a written plan of action on how they’re going to incorporate employees into the process hazard analyses and development of other elements of PSM.  Both operations and maintenance personnel and any other employees that play a heavy role in facilities operations must be involved.  Employees must be represented at meetings and teams should include persons involved in the process being used.

2.  Process Safety Information

Facilities must first compile written process safety information before they can do their hazard analysis.  Process safety information looks at the hazards involved with the processes at the facility.  Information should include:

  • Toxicity
  • Permissible exposure limits
  • Physical, reactive and corrosivity data
  • Thermal and chemical stability data, especially the hazards in mixing different materials
  • Flow diagram of the process
  • Process chemistry
  • Maximum intended inventory
  • Safe upper and lower limits for temperatures, pressures, flows, compositions
  • Consequences of deviations

Facility equipment must be evaluated for its compliance with engineering standards, including:

  • Materials of construction
  • Piping and instrument diagrams
  • Electrical classification
  • Relief and ventilation system designs
  • Design codes and standards
  • Material and energy balances
  • Safety systems

3.  Process Hazard Analysis

Process hazard analysis should identify, evaluate and determine ways to control hazards involved within the process.  OSHA lists some suggested methods you can use to do your process hazard analysis.  The analysis needs to be updated, revalidated and documented every 5 years.  It’s suggested that not only persons knowledgeable in the specific processes be involved, but engineering and maintenance experts need to be involved as well.

Some of the items to be evaluated:

  • The hazards of the process
  • The identification of any previous incident that had a potential for catastrophic consequences
  • Engineering and administrative controls applicable to the hazards and their interrelationships, like detections to provide early warning of releases
  • Consequences of failure of engineering and administrative controls
  • Facility siting
  • Human factors
  • A qualitative evaluation of a range of the possible safety and health effects if a failure of controls occurs.

Facilities are required to develop and document a system to address the findings and get them resolved in a timely manner.

4.  Operating Procedures

Written operating procedures need to be developed with safety in mind.  Some of these include procedures for:

  • Initial startup and startups after turnarounds
  • Normal operations
  • Temporary or emergency operations
  • Shutdowns
  • Operating limits
  • Precautions to prevent exposures
  • Safety systems
  • Quality control for raw materials
  • Safe work practices

5.  Training

Initial PSM training is required for new employees or persons assigned to new processes.  Refresher training is required every 3 years.

6.  Contractors

PSM applies to contractors conducting maintenance, repair, turnaround, major renovation or specialty work adjacent to a covered process.   Facilities are responsible for gathering contractor safety performance and programs, informing contract employers of known fire, explosion or toxic release hazards, explaining the emergency action plan, developing and implementing safe work practices to control the presence, entrance and exit of contract personnel and maintaining contractor injury and illness log information.

7.  Pre-Startup Safety Review

Safety procedures must be reviewed in a pre-safety review before a new facility starts up or modified facility starts up again.

8.  Mechanical Integrity

Mechanical integrity requirements apply to pressure vessels, storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls and pumps.

Written procedures must be developed to ensure ongoing integrity of process equipment is   maintained and routinely inspected using good engineering practices.  Any deficiencies found must be corrected before further use.

9.  Hot Work Permit

Hot work permits are required to be issued for work on or near a covered process and kept on file until completion of the work.

10.  Management of Change

Any change to a process must be thoroughly evaluated for its impact on employee safety and health.  Written procedures must be developed to discuss the change’s:

  • Technical basis
  • Impact on employee safety and health
  • Modifications to operating procedures
  • Time period
  • Authorization requirements

Any affected employees must be informed of and trained in the change prior to startup.  Any changes that affect process safety information will mean changes in operating procedures or safety procedures as well.

11.  Incident Investigation

Each incident that resulted in, or could have reasonably resulted in, a significant release of highly hazardous chemicals must be thoroughly investigated to identify the chain of events that led to it. The investigation needs to be held no later than 48 hours from the incident and must include at least one person knowledgeable of the process and any contractors involved.  An investigation report needs to be developed and kept on file for 5 years.

12.  Emergency Planning and Audits

An Emergency Action Plan must be developed for the entire plant in accordance with 29 CFR 1910.138(a).  The plan needs to include procedures for small releases and may need to also follow HAZWOPER (Hazardous Waste Operations and Emergency Response) regulations 29 CFR 1910.120 (a), (p) and (q).

13.  Compliance Audits

Compliance evaluations must be conducted every 3 years to verify PSM practices are adequate and being followed.  A report of these evaluations need to be certified and the most recent 2 reports need to be kept on file.

14.  Trade Secrets

Some companies didn’t want to disclose PSM information to their employees because of trade secret concerns, so OSHA added that they must make compliance, emergency and operational procedures information available anyway, as well as incident information available to investigators.  A company can, however, ask an employee to sign a confidentiality agreement to protect trade information.

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Steve Hieger
Steve Hieger

Contributing:

Steve Hieger

Consulting Services Manager

Steve manages and oversees all of iSi’s environmental, health and safety consultants and provides as-needed technical support for all environmental and safety client projects.  A former plant manager for chemical manufacturing facilities, Steve brings a vast knowledge in process hazard analysis, process safety management, facility safety and environmental issues.  

Email  |  LinkedIn

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Which Annual Environmental Training Should You Add to Your Calendar?

Which Annual Environmental Training Should You Add to Your Calendar?

Jan 31, 2024

Recently we covered the required annual OSHA safety training requirements your company should be scheduling each year.  What about the most common annual EPA or environmental training requirements?

RCRA Hazardous Waste

Training is required for anyone handling or managing hazardous waste. For large quantity generators this training is required annually by federal regulations. For conditionally exempt small quantity generators and small quantity generators, annual training is not specified in the federal regulations but is considered a best practice.

Many states have their own hazardous waste regulations which can vary from the federal version and even be stricter, so be aware of the regulations for your area. For example, in Kansas, small quantity generators are specifically required to have annual training.

Stormwater Pollution Prevention Plan (SWP3)

Training is required annually for any facility required to have a Stormwater Pollution Prevention Plan, and in some locations, additional training may also be required. iSi did a stormwater training project for a client who had facilities in 48 states, and one of the modules we produced had a clickable state map where the learner could go learn about the rules for their state.   In our research, we found stormwater rules can vary greatly from state to state, and in some cases, from municipality to municipality.  State general permits have expiration dates on them and will be updated when the new one is issued, so check with your state’s environmental agency and find their general permit to see what the rules are.

[Don’t have time to look it up?  Contact us and we can get you pricing to have one of our environmental team members look up the most recent permit for your state(s) and determine what your requirements are, and what your training needs to cover.  (We can do the training too or make the slides for you if you need it.)]

Spill Prevention, Control and Countermeasures (SPCC)

Any company required to have an SPCC Plan must conduct training annually.  SPCC Plans ensure facilities have containment and other countermeasures in place to prevent oil spills from reaching navigable waters. Annual training is required for oil-handling personnel to ensure the prevention measures and procedures are in place, understood and followed.  This training should include the procedures and policies written in your SPCC plan.

Facility Response Plan (FRP)

FRPs are plans regarding oil spill responses after the spills occur. For those who are required to have FRPs in accordance with 40 CFR Part 112, there is training required as well as hands-on exercises. The National Preparedness for Response Exercise Program (PREP) is to be used for the hands-on portion and the U.S. Coast Guard’s Training Elements for Oil Spill Response can be used for the classroom training.

Qualified individual and emergency procedures exercises must be conducted quarterly, equipment deployment exercises must be conducted semiannually, and incident management team tabletop exercises must be conducted annually. There are additional requirements for unannounced and after business hour training.

This is different from HAZWOPER, which is an OSHA requirement, but you could incorporate some of the exercises as part of your annual HAZWOPER training.

Asbestos

Those certified as asbestos workers, contractor/supervisors, inspectors, planners and project designers are required to complete annual refresher training.

On the OSHA side, maintenance personnel who may disturb asbestos within the course of their duties are required to have annual awareness training. Although EPA addresses awareness training for these workers, it’s OSHA that requires the training annually.

Others Worth Mentioning

TSDF facility personnel must have RCRA emergency response training, and that training can be HAZWOPER if it meets the RCRA requirements. HAZWOPER refresher training is due annually.

There are other annual environmental training requirements for industrial processes which are not as widespread including municipal solid waste combustors, medical waste incinerators, and underground hazardous waste injection wells. Much of this training is also conducted by EPA or state-approved training providers.

Others Required, but Not Annually:

  • NESHAP Subpart HHHHH (6H) for Paint Stripping and Surface Coating Operations:  Every 5 years
  • Risk Management Plans: Every 3 years
  • Pesticides: Every 5 years
  • Lead-Based Paint (Lead Renovation, Repair and Painting Rule (RRP)): Every 3-5 years depending on the initial test you took
  • DOT (for hazardous waste manifest signing): Every 3 years
  • IATA (for air shipments of hazardous materials): Every 2 years
  • IMDG (for vessel shipments of hazardous materials): Every 3 years

Annual OSHA Safety Training

If you missed our blog on annual OSHA safety training needed, you can find that here.

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Which Annual Safety Training Requirements Should You Add to Your Calendar?

Which Annual Safety Training Requirements Should You Add to Your Calendar?

Jan 25, 2024

photo depicting annual OSHA safety training requirements for industry and constuction

Annual safety training is a best management practice and is most often required when conditions in the workplace change. However, the OSHA standards don’t specifically require annual safety training for all of its topic areas, just a handful of them.

Employee Access to Medical Records

This is one of the most overlooked requirements and one of the top items which pops up in our safety compliance audits. Annual notification for employee access to medical records is required. As a company you’re required to inform workers of their rights to access their medical records, where they’re kept, how to obtain them and who is responsible for keeping them.  This applies to both general industry and construction – the construction standard references the general industry standard, 1910.1020.

Respiratory Protection and Fit-Testing

Employees wearing respirators or participating in your company’s respiratory protection program are required to receive annual training regarding respirator use, care, inspection, maintenance, limitations and other requirements. In addition, employees must be fit-tested in their respirator annually. That is, each employee should be tested to ensure the seal is still fitting their face and protecting them. There are standard fit-testing procedures to use to accomplish this item.  This applies to both general industry and construction and the construction standard references general industry standard 1910.134.

Hearing Protection

If your employees are exposed to noise at or above an 8-hour time weighted average of 85 decibels, your company is required to have a hearing conservation program. As part of this program, annual training is required. Ensure you post a copy of the occupational noise exposure standard in your workplace and make any and all training materials related to this available to your employees.  Hearing conservation programs are required by both general industry and construction.

HAZWOPER

Employees responding to hazardous materials spills, conducting hazardous substance removals, or working at Resource Conservation and Recovery Act (RCRA) corrective action or treatment, storage, and disposal facility (TSDF) facilities are required to have hazardous waste operations and emergency response (HAZWOPER) training. There are various levels of HAZWOPER. Those with 24 and 40 hour initial training are required to have 8 hours of training annually per year.  Annual training requirements for HAZWOPER can be found in 1919.120 for general industry and 1926.65 for construction.

Bloodborne Pathogens

Anyone with potential bloodborne pathogen exposure potential in general industry must have annual training and additional training whenever procedures and tasks are changed.  Those who conduct first aid in construction are required to have training in hazards associated with bloodborne pathogens, as well as employees conducting maintenance activities, those collecting or separating wastes (sharps), or who could be exposed to blood or other potentially infections material as part of their job. 

Fire Extinguishers and Fire Brigades

If your company provides portable fire extinguishers or other fire-fighting devices for designated employees to use in the workplace, training is required annually. For employees designated to inspect, maintain, operate or repair fixed fire extinguishing systems, annual training reviews are required.   Fire fighters in shipyard operations are required to have semi-annual drills and annual training for fire watchers.

If your company houses an internal fire brigade that fight fires beyond the incipient stage, all fire brigade members are to be provided with annual training. Any members who are required to conduct internal structural firefighting are to have quarterly educational sessions or training as well.

Fire protection programs must be developed for all phases of construction and demolition jobs and, as a result, employers shall provide firefighting equipment and a trained and equipped fire fighting organization (fire brigade/group of employees that are knowledgeable, trained and skilled in the safe evacuation of employees during emergency situations and in assisting in fire fighting operations).

Confined Space Rescuers

Those who conduct confined space rescue are supposed to hold practice drills once per year.  This applies to both general industry and construction.

Asbestos and Other Chemical and Substance-Specific Training

Anyone exposed to asbestos at or above permissible exposure limits are required to have annual asbestos awareness training. Maintenance personnel who may disturb asbestos within the course of their duties are also required to have annual awareness training.  Those who conduct Class I through IV asbestos operations (removal activities) are also required to have annual training through the construction standards.

Employees with potential exposures to OSHA 1910.1003’s 13 carcinogens, vinyl chloride, polyvinyl chloride, inorganic arsenic, lead, cadmium, benzene, coke oven emissions, cotton dust, acrylonitrile (vinyl cyanide), ethylene oxide, formaldehyde, Methylenedianiline (MDA) and 1, 3-Butadiene are required to have annual safe usage training.  Many of these are referenced individually in both the general industry and construction standards, but the construction standards will often reference the general industry standard rather than having separate rules.  Construction has specific rules for cadmium, chromium, ethylene oxide, lead and MDA.

Others Worth Mentioning

Mechanical Power Presses – Operators of mechanical power presses with the Presence Sensing Device Initiation (PSDI) mode on them are required to have annual operator training.

Agriculture Industry – In grain handling facilities annual training is required for workers at grain handling facilities. Topics to be covered include dust hazards, dust accumulation, ignition control and prevention, cleaning/clearing/housekeeping procedures, hot work procedures, preventative maintenance, lockout/tagout and bin entry and engulfment hazards (for those entering bins). In other agriculture-related workplaces where employees are required to use tractors, annual training regarding rollover protective structures is required and those using farm field equipment, farmstead equipment and cotton gins are required to have safe operating and guarding training annually.

Logging Industry – Supervisors and employees in logging industry operation are required to have annual CPR training, with first aid training every 3 years.

Every 3 years – Because of their prevalence in industry, we thought we’d also mention that forklift recertifications are due every 3 years as is refresher training for Process Safety Management.

Lockout/Tagout – Not necessarily a training requirement, but an annual requirement nonetheless, employers are required to review their energy control procedures at least annually to ensure the procedure and the requirements of the lockout/tagout standard is being followed.

Environmental Training

Looking for annual EPA and environmental training?  In addition to annual safety training, check out our article regarding annual environmental training requirements your company should schedule for the year.

Need Help?

Are you low on staff to conduct your own safety training?  Tired of dealing with generic videos?  We can help!  Check out our onsite safety training and customized training options.

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Environmental Training

Now that you’ve learned what safety training is required annually, learn more about what environmental training is required annually.

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State, Regional and National Safety and Environmental Conferences for 2024

State, Regional and National Safety and Environmental Conferences for 2024

Jan 22, 2024

We exhibit and speak at many different safety and environmental conferences throughout the region.  What’s the schedule look like for 2024?

Here is a list of some upcoming state, regional and national safety and environmental conferences that you may want to add to your calendar.  (For now, we’re listing the ones near where we have offices. )

We will work to keep this list updated as we find out changes, if any.

Central U.S. / Region VII

 

Region VII (KS, MO, IA, NE)

Midwest Environmental Compliance Conference (MECC)
Sept. 24-25 | Overland Park | In-Person and Online | Learn More

Region VII VPPPA Midwest Safety and Health Conference
TBD | Des Moines | Learn More

Kansas

KDHE Environmental Conference
Aug. 7-8 | Wichita | In-Person | Learn More

Kansas Safety and Health Conference
Oct. 1-2 | Wichita | In-Person| Learn More

Missouri

Mid-America Safety, Health & Environmental Conference and Expo
TBD | Springfield | In-Person | Learn More

Greater St. Louis Safety & Health Conference
Oct. 1 | St. Louis | In-Person | Learn More

Missouri Hazardous Waste Seminar
April 30 | Online | Learn More

Safety & Health Council of Western Missouri & Kansas SAFECONEXPO
May 14-16 | Lake Ozarks, MO | In-Person | Learn More

Nebraska

Nebraska Safety & Health Summit
Oct. 14  | Omaha | In-Person | Learn More

Iowa

Hawkeye on Safety
Sept. 5 | Coralville | In-Person | Learn More

Iowa Governor’s Safety & Health Conference
Oct. 29-30  | Des Moines | Altoona | Learn More

Central U.S. / Region VI

 

Region VI (OK, TX, NM, LA, AR)

Region VI VPPPA
April 30 – May 2 | Oklahoma City, OK | In-Person | Learn More

Oklahoma

Oklahoma Safety and Health Conference
July 24-26 | Norman | In-Person | Learn More

Environmental Federation of Oklahoma (EFO) Annual Meeting & Trade Show
Oct. 14-17 | Midwest City | In-Person | Learn More

Southeast / Region IV 

 

Region IV (GA, AL, MS, KY, TN, NC, SC, FL)

Region IV VPPA Safety + Symposium
Aug. 25-28 ​ | Aurora, CO | In-Person | Learn More

Georgia

Georgia Environmental Conference
Aug. 21-23 | Jekyll Island | In-Person | Learn More

Georgia Safety, Health and Environmental Conference
Sept. 4-6 | Savannah | In-Person | Learn More 

Tennessee

Chattanooga Regional Manufacturers’ Association Environmental, Health and Safety Summit
TBD | Chattanooga | In-Person | Learn More 

Tennessee Environmental Network Show of the South
May 15-17 | Chattanooga | In-Person | Learn More 

Alabama

Alabama Governor’s Safety and Health Conference
Aug. 26-28 | Orange Beach | In-Person | Learn More

Manufacture Alabama HR, Safety & Environmental Conference
TBD | Birmingham | Learn More

North Carolina

NC Statewide Safety Conference
TBD | Learn More

Carolina Star Safety Conference
Sept. 18-20 | Greensboro | In-Person | Learn More

Eastern Carolina Safety & Health Conference
Apr. 10-12 | Atlantic Beach | Learn More

South Carolina

South Carolina Environmental Conference
Mar. 10-13 | Myrtle Beach | In-Person | Learn More

ASSP Region VI Conference
Sept. 18-20 | Virginia Beach | In-Person and Online | Learn More

NSC Southeast Regional Conference & Expo
May 14-16 | Rosemont, IL | Learn More

National Conferences


American Industrial Hygiene Conference and Expo (AIHCE) EXP 2023 
May 20-22 | Columbus, OH | Learn More 

American Society of Safety Professionals (ASSP) Conference and Expo
Aug. 7-9  | Denver, CO | In-Person and Online | Learn More

National Safety Council (NSC) Safety Congress
 Sept. 13-19 | Orlando, FL | In-Person| Learn More

Associated General Contractors (AGC) Construction Safety, Health & Environmental Conference
July 16-18 | St. Louis, MO |  In-Person | Learn More

Associated General Contractors (AGC) Construction Safety & Health Conference
Jan. 10-12  | Newport Beach, CA |  In-Person | Learn More

Alliance of Hazardous Materials Professionals (AHMP) National Conference
July 14-17 | Kansas City, MO | Learn More

National Association of Environmental Professionals (NAEP) Annual Conference and Training Symposium
May 5-8 | Minneapolis, MN | Learn More

National Environmental Health Association (NEHA) Annual Education Conference & Exhibition
TBD | Spokane |  In-Person and Virtual | Learn More

Which safety and environmental conferences did we miss?  Let us know by emailing us here.

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Are You Required to Have IMDG Training?

Are You Required to Have IMDG Training?

Oct 27, 2023

Recently one of our clients had a shipment of their product rejected at a port in Europe.  They had been sending it there for years without incident, but this time was different.  Inspectors chose to verify their paperwork and they were missing crucial IMDG dangerous goods paperwork.  All methods of hazardous materials transportation have specific training requirements, but the one which often catches people by surprise is IMDG.

If you ship hazardous materials by vessel or over water, you are required to follow the rules of the International Maritime Dangerous Goods (IMDG) code.  This includes companies who are:

  • Loading shipping containers onsite;
  • Using third-party companies to load shipping containers for them onsite; and,
  • Sending hazardous materials to freight forwarders or third-parties to be loaded somewhere else.

You May Qualify Without Knowing It

Shipping containers are used for overseas transport, but also keep in mind they are used to transport products to U.S. states such as Hawaii and Alaska as well as U.S. territories.  For example, a different client of ours was responsible for gathering together all the products needed for opening a new Wal-Mart store, and some of those were hazardous materials.  When there were new Wal-Marts to open in Alaska and Hawaii, those products needed to be loaded into shipping containers.  As a result, that company became subject to the rules of IMDG.

Keep in mind that even small quantities can trigger requirements.  For example, we have clients who send vehicles and farm implements via vessel.  Along with the vehicles are boxes of oils and lubricants for operation once they are unpacked.  This triggers hazardous materials regulations.  Even residual fluids left over in the engines that got there when the factory tested it to make sure it worked triggers hazardous materials regulations.

Just like in DOT regulations for ground shipments and IATA regulations for air shipments, goods loaded into the containers must be packaged in certified packages that have design qualification reports for them.  Special IMDG dangerous goods paperwork called a Dangerous Goods Transport Document is also needed to accompany the shipment and all packages and the container need to be labeled and placarded accordingly. 

Even if you use a third-party to handle this for you, it’s still your company’s responsibility to make sure they are complying with the rules as you are the shipper and it’s your company who will be dealing with the regulators and with potentially unhappy customers the further the goods are delayed.

Training Requirements

If IMDG applies to your operations, the following personnel need to have training upon employment or assignment to hazardous materials duties:

Anyone who…

  • Classifies and/or identifies the proper shipping names of dangerous goods (hazardous materials);
  • Packs dangerous goods;
  • Marks, labels or placards dangerous goods;
  • Load/unload dangerous goods;
  • Prepare transportation documents;
  • Offers or accepts dangerous goods for transport;
  • Handles, loads or unloads dangerous goods into or from ships;
  • Prepares dangerous goods loading/stowage plans;
  • Carries dangerous goods in transport;
  • Enforces, surveys or inspects dangerous goods for compliance; and is,
  • Otherwise involved as determined by a competent authority.

As with other hazardous materials training, students are required to have general awareness, safety, and function-specific training.  Refreshers are required every 3 years.

Does this requirement apply to your company?  iSi has regularly scheduled IMDG courses and can provide them onsite on your own schedule, at your own convenience.  Check here for our course schedule or contact us here for more information and pricing for an onsite class at your facility!

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Health and Safety Consultants

Health and Safety Consultants

Oct 9, 2022

Consultants provide essential services to businesses, organizations, and individuals. They help ensure workplace safety by providing advice on health and safety regulations and policies, developing risk assessments, inspecting equipment or premises for safety hazards, conducting staff training sessions and developing emergency response plans.

These are knowledgeable in areas such as occupational health and safety regulation compliance, industrial hygiene principles, ergonomics, hazardous material management, fire protection engineering, accident investigations, construction site hazard recognition and more. Their expertise helps mitigate the risk of injury or illness within a work environment.

Additionally they can assist organizations in meeting all legal requirements for health & safety legislation in their respective countries or regions. Ultimately their work helps protect workers from potential hazards that may arise from working conditions.

Furthermore, safety consultants and safety professionals can provide a valuable service to businesses looking to expand or introduce new processes or practices. They can provide advice on the best practices for their particular industry, as well as how to best implement them with minimal risk of disruption to the operations.

Ultimately, this helps make sure that employees are working in an environment where their safety is paramount. Engaging with a qualified Health and Safety Consultant is essential for ensuring that an organization meets its legal obligations in terms of health and safety regulations and requirements.

Additionally, it allows companies to minimize risks, create a safe work environment for their staff, and ultimately protect their reputation should an incident occur.

OSHA Compliance Solutions

OSHA Compliance Solutions is a comprehensive suite of tools and services designed to help businesses stay in compliance with all applicable Occupational Safety and Health Administration (OSHA) regulations. The service includes access to the most up-to-date federal and state information, as well as an online library of safety training materials, safety programs, safety manuals, instructional videos, and other resources for your safety manager to use.

With these tools, businesses can easily create compliant work environments that protect employees from safety risks and injury. Additionally, OSHA Compliance Solutions can recommend a safety consulting company in which offers consulting services and technical assistance to further support companies’ compliance efforts.

These services include onsite visits for inspections or consultations, as well as identify workplace hazards and provide recommendations for corrective action plans when necessary. Your company will also be presented safety data sheets from these experienced safety professionals. OSHA Compliance Solutions helps businesses ensure their workplaces are safe, efficient, and in compliance with federal and regulations.

OSHA Training Solutions

OSHA Training Solutions is an industry leader in occupational safety and health training. With expertise on a wide range of topics related to workplace safety, OSHA Training Solutions provides comprehensive training courses, both online and in-person, to help employers meet their safety and health compliance requirements.

Their courses are designed to cover topics such as ergonomics, fall protection, hazardous materials handling, risk assessment, health programs, machine guarding, fire safety and more. They also offer a vast selection of online resources that provide easy access to up-to-date information on the ever changing regulations governing workplace safety. OSHA Training Solutions is committed to providing outstanding customer service and quality training solutions to ensure that workers stay safe while on the job.

With their commitment to excellence and dedication to helping employers protect their workforce from injury or illness, OSHA Training Solutions has become an industry leader in occupational safety and health training.

OSHA Compliance Evaluations

OSHA Compliance Evaluations are conducted in order to assess the safety and health conditions of a workplace and ensure that it is compliant with federal standards. During such evaluations, an inspector will look for potential hazards review company policies and procedures, inspect work areas, and verify compliance with OSHA regulations.

These evaluations also serve as an opportunity for employers to address any existing or potential safety risks before they become larger issues. Ultimately, OSHA Compliance Evaluations make workplaces safer places by identifying and preventing potentially dangerous situations.

Additionally, these evaluations can help employers save costs associated with employee injury or illness due to unsafe working conditions. By conducting assessments regularly, companies can protect the health and well-being of their workers while also avoiding violations of regulatory standards.

OSHA Inspection Guidance

The Occupational Safety and Health Administration (OSHA) provides inspection guidance to ensure compliance with federal safety standards. During OSHA inspections, OSHA inspectors conduct workplace inspections to assess compliance with safety regulations and identify any potential hazards that could cause harm to workers.

Inspectors may also speak with employers and employees during the inspection process in order to gather more information on working conditions. The inspector will then issue a report which includes recommendations for improvements or corrections based on their findings, along with a citation of violations if any were found. Employers must take the necessary steps to address the concerns raised in the report in order to come into full compliance with all applicable regulations.

By providing timely guidance and enforcement, OSHA helps keep workplaces safe from injury and illness, protecting both employers and employees.

Written OSHA Program Preparation

Written OSHA Program Preparation is an important part of any workplace safety program. It involves the development and implementation of policies and procedures for keeping workers safe from potential hazards. This includes identifying and addressing potential safety issues, training employees on safe practices, documenting all safety measures, and regularly auditing the system to ensure amenability with federal regulations. Taking these proactive steps helps to protect workers and create a safer work environment.

By setting up an effective written OSHA program, employers can ensure that their workplace is compliant with all applicable laws and regulations, while also protecting the safety and wellbeing of their employees. Written programs provide a roadmap for achieving workplace safety goals as well as creating an environment where employees understand the risks associated with their work and feel empowered to take action for protecting themselves and their colleagues.

Safety Data Sheet Preparation

A Safety Data Sheet (SDS) is a key document required by all employers to ensure the safety of workers in hazardous working conditions. SDSs are prepared to provide information about the properties of a particular substance or mixture, including its health and safety hazards, protective measures for handling, storing, using and disposing of it safely.

SDSs also include details on how to respond in case of an emergency involving the product. Preparation of SDSs requires knowledge of hazardous substances as well as knowledge of composition, toxicology and occupational health. Since many hazardous materials can exist in a number of different forms, it is important to ensure that the SDS accurately reflects the particular product’s characteristics. Furthermore, information must be regularly updated in line with changes in legislation and any new or revised hazard assessment data.

Health and Safety Program (HSP) Development

Health and Safety Program (HSP) Development is a comprehensive process that involves identifying potential risks, developing strategies to reduce risks and implementing those strategies in the workplace. A successful HSP requires proper planning, training, assessment and reporting of safety issues. The goal of HSP development is to protect workers from injury or illness associated with their job duties.

Emergency Response Plans

Emergency response plans are important to have in place for any organization, as they help to outline the steps that should be taken in the event of an emergency. These plans should include information about how to respond and evacuate a building safely, who is responsible for different aspects of the plan, and how to contact emergency services. This response plans should also consider potential risks, such as natural disasters or hazardous materials spills, and outline procedures for responding effectively.

Having a well-developed emergency response plan helps ensure employees are safe during an emergency situation, while also preventing costly damages if an incident occurs. Additionally, proper training on these plans allows staff members to become familiar with their roles so they can act quickly in the face of danger.

On-Site Health and Safety Management

On-site health and safety management is an essential part of any successful business. Effective management of workplace safety can help reduce risks, minimize injury and illness, protect employees’ rights to a safe work environment, and ensure that businesses meet all applicable safety regulations.

An effective on-site health and safety management system should include procedures for identifying hazards in the workplace, setting standards for worker protection, providing training for workers on how to safely conduct their job duties, responding quickly to reported or observed unsafe conditions or practices, conducting periodic inspections of the facility for potential hazards, and maintaining records documenting compliance with OSHA regulations.

LOTO Procedure Development

LOTO (Lock Out/Tag Out) Procedure Development is an essential element of workplace safety. Properly designed and implemented LOTO Procedures help to ensure that hazardous sources of energy are effectively isolated from equipment, thus preventing potential injuries or damages.

When creating a LOTO Procedure, it is important to accurately identify all potentially hazardous sources of energy, determine the proper type of lockout device needed for each source, and develop step-by-step instructions on how to properly de-energize and lock out the machine. Additionally, procedures should be regularly reviewed and updated as necessary in order to ensure they remain up-to-date and effective.

By following these steps in the development process, businesses can greatly reduce their risk exposure while also protecting their employees from potential hazards.

For more detailed information, businesses should consult OSHA regulations on LOTO Procedure Development as well as their own corporate safety policies. With the proper development and implementation of LOTO Procedures, businesses can ensure a safe and secure workplace environment while also adhering to all relevant safety regulations.

By investing in the proper protocols and procedures upfront, businesses can make sure that they are providing their employees with the necessary protection against hazardous energy sources. This is an important step toward ensuring a safe work environment for everyone involved.

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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Lithium Batteries: Safety Hazards and Their Impact on Businesses

Lithium Batteries: Safety Hazards and Their Impact on Businesses

Aug 12, 2022

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

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

Should I Really Worry About My Battery Catching on Fire?

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

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

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

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

DOT Issues Advisory Warning for Lithium-Containing Batteries

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

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

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

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

Battery Disposal Rules – for Consumers

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

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

Battery Shipping and Disposal Rules – for Businesses

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

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

Training and Consulting Resource

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

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Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

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Warehouse Inspection Checklist

Warehouse Inspection Checklist

Jul 22, 2022

Why is warehouse safety important?

Warehouse managers have a difficult job. Not only do they need to keep their facility running smoothly, they need to ensure the safety of their workers, and facilitate warehouse operations.

According to the Occupational Safety and Health Administration (OSHA), warehouse managers face a number of potential hazards in their workplace, including unsafe use of a forklift, improper stacking, and unsatisfactory fire safety provisions. These line items plus many more will be included in an osha inspection.

How to use a warehouse safety checklist?

Maintaining compliance with industry safety standards is critical for any business, but can be especially difficult for small businesses. One way to ensure compliance especially before a company is required to do a formal safety audit is to use safety inspection checklists that are compliant with OSHA standards. iSi offers a checklist free of charge to help companies start their compliance journey.

Additionally, using pre-written checklists can help reduce the amount of time spent on safety inspections, allowing business owners to focus on their core operations. Finding a warehouse safety checklist is the first step to this process.

What should be checked during warehouse safety inspections?

Forklifts:

In any warehouse, forklift accidents are a major concern that can facilitate numerous hazards. Forklift operators need to be properly trained and aware of potential safety risks, especially while loading docks. In order to avoid injuries, it is important to maintain haulage equipment, make sure it is in good working order, never exceed 5 mph outside or in a warehouse, examine the area before driving a forklift, and perform regular checks on all equipment.

Docks and Dock doors

Injuries can occur when warehouse employees are struck by items or equipment falling from the dock or while loading dock doors, when the forklift runs off the dock, or when employees engage in “dock jumping.” It is important for the safety of workers to drive slowly, never go in reverse, and wear a hard hat. Ladders and stairs should meet OSHA’s guidelines, and “dock jumping” should be prohibited.

Material Storage

A good item to examine on the warehouse safety checklist is material storage. Warehouses are often dangerous places to work, as the slightest mistake can lead to a worker being injured. In order to keep workers safe, it is important that warehouses implement safety measures to prevent falls and other injuries from occurring. One such way to prevent falls and protect employees is by positioning items evenly throughout the warehouse and on storage racks.

This means that when workers walk through the warehouse, they will not have to navigate around large piles of boxes or other items. This is important for the safety of the workers. Placing heavier loads in lower distances will also help to keep workers safe, as it will be easier for them to maintain their balance when carrying heavy objects. Implementing these simple safety measures can help keep your workers safe and injury-free.

Charging Station

In the warehouse, one of the most important safety steps you can take is to identify hazards and know how to prevent them. According to OSHA, there are a number of things that you can add to your warehouse safety inspection checklist to maintain warehouse safety, including banning smoking and open flames, keeping an adequate inventory of fire extinguishers, and properly positioning forklifts before charging.

Chemicals

In order to be compliant with local, state, and federal regulations, it is important for warehouses to have safety data sheets (SDSs) on hand. SDSs are documents that contain all the relevant information about hazardous materials and chemicals, including its hazards, proper storage and handling, first-aid and firefighting measures, toxicological information, and more.

For warehouses that store hazardous chemicals, it is especially important to be up to date with all regulations. This is because hazardous materials and chemicals can pose a danger to employees if not handled properly. In order to prevent accidents, employees will need regular training and management should preform regular inspections.

Warehouses should make sure they have up-to-date SDSs for all of their chemicals. Having these documents on hand will help ensure a safe work environment and the warehouse is in good standing with all regulations.

Person lifting or handling

For employees who are performing regular lifting and handling of heavy objects, quick is not safe. Most cases of back pain are caused by strain or injury to the muscles, ligaments, or discs in the back. The good news is that these injuries can often be prevented by using proper lifting techniques as well as storing heavy or cumbersome items preoprly on storage racks.

Security System

As technology advances, more and more businesses are turning to warehouse security systems to protect their investments. With the installation of alarms and surveillance cameras near all access points, business owners can rest easy knowing that their facilities are under 24/7 monitoring. While there are many companies that offer these services, it is important to do your research before selecting a provider.

One of the first things you will want to consider when hiring a security company is their experience in servicing storage areas and other sensitive locations. It is also important to look at the quality of their equipment. In addition, the company should offer cloud storage so that you can access videos from anywhere at any time.

Finally, be sure to ask about the company’s customer service policies. You should expect 24/7 support in case of an emergency.

Fencing

Most people know that fences provide a layer of security by keeping unauthorized individuals out of a designated area. What many people don’t realize, however, is that fences also need to be routinely inspected in order to ensure they are still structurally sound and haven’t been compromised. Just as you would perform maintenance on your car or home, it’s important to inspect your fence on a regular basis and identify safety hazards to prevent any unwanted access or damage from happening.

Employees

Employees that can identify when something doesn’t seem right can be your best protection against potential security breakdowns. This should be a part of your hazard communication. Security breaches can happen anywhere, at any time, so it’s important to have a plan in place for how to handle them. That means having employees who are alert and paying attention to their surroundings, and who know what to do if something seems suspicious.

What are the most common warehouse safety hazards?

Fire Safety

A warehouse is a large, open space where goods are stored and processed. Because of the nature of their work, warehouses pose a unique fire risk. In order to ensure that your warehouse is as safe as possible in the event of a fire, it is important to take some precautions.

The most important thing you can do is make sure that your warehouse is well-marked with clear exit signs and that there are adequate fire extinguishers available. You should also store flammable materials in a safe place and make sure that wires are properly insulated. Having proper emergency exits, fire exits, and fire alarms can and will save lives as well as products.

Falls

It’s no secret that safety is of utmost importance in the workplace. Every employee should be aware of the proper safety protocols to follow in case of an emergency. In addition, it’s important to take measures to ensure the safety of employees while they are working.

This may include using safety railings, harnesses, and other protective devices. It’s also beneficial to cordon off uneven or damaged areas while repairs are being made.

Heavy machinery

Heavy equipment is often essential to completing construction or other tasks. However, working with this equipment can be dangerous if not done properly. It is important that you take the necessary precautions to ensure your safety and the safety of those around you when using heavy equipment. All vehicles

Some tips to keep in mind are: being aware of your surroundings, safely entering and exiting equipment, sustaining communication with other workers, using appropriate spotter signals, creating buffer zones, and workers knowing when to stop so that they are not in a dangerous situation.

Trip hazards

It’s no secret that the warehouse industry is a dangerous one. Every year, workers in a warehouse are injured and killed on the job because of common hazards. In an effort to reduce these numbers, it’s important for employers to be aware of the most common warehouse safety hazards and take steps to correct them.

One of the most common types of accidents in a warehouse is a slip or trip. This can be caused by many things, such as poor lighting, loose materials on the floor, spills, or uneven flooring.

To avoid these accidents, it’s important for employers to take steps to improve visibility and make sure that all surfaces are even and free of hazards. Implementing hazard signs and caution tape can also help increase awareness among workers.

Overexertion

What are overexertion injuries? For example, injuries caused by lifting, pushing, pulling, holding, carrying, or throwing objects all fall under the category of overexertion.

To help prevent overexertion-related accidents, your workers must receive proper safety training. In particular, learning how to lift and carry objects without injury is a vital part of warehouse worker training.

Carrying heavy items improperly can result in a number of different types of injuries: back strains and sprains, hernias, neck strains and sprains, shoulder strains and sprains. Injuries like these can keep your workers off the job for weeks or even months at a time. That’s why it’s so important to make sure your workers know how to safely lift and carry boxes and other items in the warehouse setting.

Falling objects

Working in a warehouse almost guarantees that some materials will be stacked on racks above everyone’s heads. Hard hats, hard hats, hard hats… is the number one thing every person should be wearing to prevent injury. Therefore, it’s possible for items to fall from those racks and cause injuries or get lost in the flue space. In order to prevent these things from happening, a safety protocol should be put into place.

That protocol should include the use of a safety harness, regular inspections of the racks, and employee training on how to properly stack materials.

Lack of Awareness

The biggest hazard in warehouse safety is lack of awareness. When you go through your warehouse safety checklists make sure your warehouse workers, co-workers, and managers are practicing situational awareness.

To help maintain this level of awareness, your team should know all current regulations and latest regulations as well as provide effective training to all workers. When you provide training make sure to include hazard communication with warehouse workers and take preventive measures to keep everyone safe.

If an incident arises, take immediate corrective actions and safety procedures, create reports of the incident and leave the warehouse in good condition.

How do warehouse inspections work?

Warehouse safety inspections, also known as warehouse audits, are an important part of maintaining a safe and efficient working environment in a warehouse setting for warehouse staff. By following a set of documented processes, employers can ensure employee safety, protect inventory from theft or damage, and optimize workflows and procedures. A warehouse safety checklist can help to guide warehouse workers through the necessary steps to complete an effective inspection. Inspections is a warehousing industry standard.

Conclusion:

Having a warehouse is an important part of any business, and it’s essential to make sure they are functioning properly. A warehouse inspection checklist can help you do just that.

A good inspection checklist will cover all the key areas of a warehouse, from the inventory to the security systems. It should also be customized to your specific needs, so that you can be sure nothing is missed.

A well-executed warehouse inspection can help you identify any potential problems before they become serious issues. It can also help you ensure that your warehouse is running as efficiently as possible, which can save you time and money in the long run.

Where Do You Go From Here?

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

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

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

May 26, 2022

Does This Apply To You?

iSi can help determine which of these options apply to your facility, and help you make sure you’re on the right track in getting the necessary documentation and processes in place.

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

Who Does It Apply To?

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

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

General Duty Clause vs. RMP

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

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

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

RMPs must include:

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

 What is Required by EPA’s General Duty Clause?

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

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

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

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

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

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

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

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

Which One Applies to Your Facility?

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

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

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

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

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Fatigue Management

Fatigue Management

Apr 1, 2022

We’re all tired. There are so many things weighing on us — taking on more tasks and trying to keep up at work when there are not enough workers to get everything done, continuous pressure to maintain levels of service when supplies are delayed and staffing is short, COVID, Daylight Savings time, we’re approaching one of the busiest times of the year in the school calendar, you have stuff at home that’s not getting done, and on and on. When you get tired, mistakes and accidents happen.

Most adults need 7-8 hours of sleep in every 24 hours to feel well rested and without it, a sleep debt is built up. This debt may result in impaired performance, reduced alertness and higher levels of sleepiness and fatigue. A sleep debt can only be repaid with restful sleep. Fatigue contributes to accidents by impairing performance and in extreme cases causing people to fall asleep. Fatigue related “micro sleeps” are very hard to predict or prevent and can place the individual and others at risk.

According to the National Safety Council, more than 43% of workers are sleep-deprived, and fatigued worker productivity costs employers $1,200 to $3,100 per employee annually. Employees on rotating shifts are particularly vulnerable because they cannot adapt their “body clocks” to an alternative sleep pattern.

Fatigue Management Programs

More and more companies are including fatigue management in their list of safety programs.  For major manufacturers and industrial facilities that use contractor pre-qualification services like ISNetworld, Fatigue Management Programs are a requirement for contractors.

Fatigue Management Programs can be simple.  They can line out the responsibilities of supervisors, employees and the company.  They also discuss the hazards of fatigue, provide a overview of risk controls and make a plan for training.

Even if you don’t want to create a formal Fatigue Management Program, you still may want to consider including safety sessions about it to your teams.  Here are some elements you can include in your training:

Signs and Effects of Fatigue

Signs of fatigue include long eye blinks, repeated yawning, frequent blinking, bloodshot eyes, poor reaction time, slow speech, loss of energy, and an inability to concentrate.

Fatigue can result in a lack of attention, difficulty following instructions, reduced ability to think clearly, and slower response to changing circumstances.

Chronic fatigue can also lead to many different long term health issues such as high blood pressure, increased risk for diabetes and heart disease, weakened immunity, poor balance, mood changes and memory issues.

What Your Company Can Do:  Risk Controls to Consider

Rest, of course, is the most important control measure for managing fatigue. For companies, consider the following:

  • Is a ten hour or longer break between work shifts provided?
  • Are safety critical tasks planned during “circadian low” hours, 2am-6am and 2pm- 4pm?
  • Are complex tasks planned on the first or final shift of a nightshift work cycle?
  • Does the break between work shifts provide a sleep opportunity of 7 or more hours of continuous sleep?
  • Is a minimum of one break provided between each 4 hours of work with one break of sufficient length to have a meal (i.e. 30 minutes)?
  • Are more frequent short breaks allowed during strenuous activities?
  • Are on-call responsibilities limited?
  • Is ready access to drinking water provided?
  • Do Call-Out/On Call schedules provide for adequate rest before returning to a regular work shift?

What the Worker Can Do: Combating Fatigue

  • Try to maintain a consistent sleep schedule — if you’re sleeping more on days off, you’re not sleeping enough on work days. Try to go to bed and wake up at roughly the same time per day, even on the weekends.
  • Try to get a minimum of 7 hours per night
  • Don’t eat big meals close to bedtime, but if you’re hungry before bed, don’t go to bed hungry as that will affect sleep too — have a healthy snack.
  • Caffeine, nicotine and alcohol can all affect sleep patterns
  • Make your bedroom conducive to sleep — quiet, dark, not too hot or too cold
  • If you have daytime sleepiness, snoring or breathing pauses, get checked out for sleep apnea
  • Just like kids need a bedtime routine, so do you. Establish a relaxing bedtime routine and stick to it.
  • Avoid stressful activities before bedtime and don’t associate your bedroom and sleeping with anxiety
  • Don’t go to bed for sleep unless you’re truly sleepy — trying to sleep is counterproductive and can make it harder to fall asleep.
  • Avoid long naps during the day that may throw off your nighttime schedule.
  • Avoid blue light exposure at night (from electronic devices) – use glasses that block blue light or install an app that blocks it.
  • When was the last time you changed your mattress and pillow? Are they causing pain? Upgrade your bedding every 5-8 yrs.

Working together to try to incorporate just even a few of these into our lives and work days should make a real difference in workplace health and wellness — both physically and mentally.

If you need help developing a Fatigue Management written safety program, we can help.  Contact us today!

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The Top 4 Facility Response Plan Issues Found by EPA

The Top 4 Facility Response Plan Issues Found by EPA

Dec 9, 2021

EPA has reviewed inspection data from its regional offices to get an idea of the most common Facility Response Plan and SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies.  The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations.  [Check out the SPCC Plan deficiencies here.]

What is a Facility Response Plan (aka, an FRP)?

Facility response plans are required per 40 CFR 112. If you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet certain criteria, you are required to have a Facility Response Plan. Both the SPCC Plan and Facility Response Plan are from the Federal Water Pollution Control Act.

EPA’s Review

The data was reviewed for companies who also had both Facility Response Plans and SPCC Plans, with a preference for companies with higher oil storage capacity.  The Facility Response Plans facilities had an average aggregate oil storage capacity of 69,000 to 857 million gallons of oil, with a worse case scenario discharge planning volume of 94,000 to 20 million gallons.  EPA found an average of 4 issues per plan.

Top 4 Facility Response Plan Deficiencies (in Order)

  1. Diagrams (1.9) – 31 of the 55 had this deficiency
    • This includes site plans, evacuation plans and drainage diagrams.
  2. Discharge Scenarios (1.5)
    • This includes discussion and plans for worse-case discharge.
  3. Vulnerability Analysis; Hazard Evaluation (1.4. 2 and 1.4)
    • This would be spill history and analysis of discharge potential.
  4. Plan Implementation  (1.7)
    • This would be a description of containment and drainage planning, disposal plans and response resources.

Other Issues Found

  • Lack of details about response equipment. (1.3, 1.3.2)
  • Companies didn’t include key information from their Emergency Response Action Plans (ERAPs) (1.1)
  • Not conducting required preparedness drills and exercises (1.8)
  • Not training personnel on appropriate oil spill response measures.

Do you have any of these issues with your own Facility Response Plan? Are you required to have an FRP? We can help! We can review your plan for compliance to these issues, prepare updates, or provide the required training or scenarios you need to conduct to your employees. Contact us today!

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The Top 5 Respiratory Protection Issues Cited by OSHA in 2021

The Top 5 Respiratory Protection Issues Cited by OSHA in 2021

Dec 3, 2021

The list of the most cited OSHA standards is out for 2021.  As you may know, the list contains the same issues each year, usually just in a different order.  Fall protection in construction is number one for the 11th year in a row. Hazard communication, usually towards the top of the list, surprisingly fell to 5th.   Respiratory protection in general industry is the new overall number two for this year, and the top issue found in general industry.

So what are the issues most commonly cited for respiratory protection?   

1. 1910.134(e)(1) Medical Evaluations

The most commonly cited relates to medical evaluations. Employers are to provide medical evaluations to determine the employee’s ability to use a respirator, before fit-testing and before they’re required to use the respirator in the workplace. 

There is a medical questionnaire in Appendix C that you can choose to use, or you can choose to do a medical examination instead as long as the examination contains the same information found in the questionnaire.  As an employer, you cannot look at the answers, and must provide employees with instructions on how to deliver or send the completed questionnaire to a physician or other licensed health care professional (PLHCP) for review. 

Seasonal and temporary workers are required to have evaluations if their jobs require respirator use.  Those workers who voluntary choose to wear dust masks (after you’ve determined there is no hazard in that area) are not required to have medical evaluations but must be made aware of the limitations of the dust mask as outlined in Appendix D of the standard.

2.  1910.134(f)(2) Fit Testing

Employers are to ensure employees wearing tight-fitting facepiece respirators are fit-tested:

  1. Before use
  2. Whenever a different respiratory facepiece is used (size, model, make, style)
  3. Annually

Fit-testing is done qualitatively or quantitatively.  Qualitative fit-testing uses items such as saccharine, Bittrex, banana oil 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, full-face and N95 filtering facepiece respirators that have an Assigned Protection Factor (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 APF over 10.  Full-face tight fitting respirators that are quantitatively tested have an APF of 50 .

3.  1910.134(c)(1) Written Program

In any workplace where there is respirator use, there needs to be a written program with site-specific procedures. The program is to be administered by a “suitably trained” program administrator.  Whenever conditions in the workplace changes, the program should be updated.  If you have people voluntarily wearing respirators, you still are required to have a program.

The program is to contain the following elements:

  • Procedures for selecting respirators;
  • Medical evaluations of employees required to use respirators;
  • Fit testing procedures for tight-fitting respirators;
  • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations;
  • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators;
  • Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators;
  • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;
  • Training of employees in the proper use of respirators, including putting on (donning) and removing them (doffing), any limitations on their use, and their maintenance; and
  • Procedures for regularly evaluating the effectiveness of the program.

Annual reviews are not required, but reviews should be done periodically in accordance with the complexity and factors of your hazards, types of respirators used, and worker experience using them. Workplace changes are an automatic trigger for updates.  For instance, if your workplace conditions change such as different exposure amounts or types, if you change respirators, or change fit-testing protocols, an update would be necessary.

In your review, employees should be questioned on factors affecting their performance such as difficulty in breathing, limits of motion, impacts to vision/hearing/communication, discomfort and if they have any concerns on effectiveness.

4.  1910.134(k)(1) Training

Employers need to make sure employees can demonstrate their knowledge of the following:

  • Why the respirator is necessary
  • How proper fit, usage and maintenance can compromise its protective effect
  • Limitations and capabilities of a respirator
  • How to use it in an emergency
  • What to do if it malfunctions
  • How to inspect, don, doff and check its seals
  • How to properly clean, disinfect and store the equipment
  • How to recognize medical signs and symptoms that may limit or prevent the respirator’s effectiveness; and,
  • The general requirements of this section of the standard.

Employees need to be trained BEFORE using a respirator in the workplace, and ANNUALLY (within 12 months). Training needs to include the above elements each year. Besides the annual training requirement, retraining is required whenever there are changes in the workplace, when you see the employee has inadequacies in his/her knowledge or use of it, or any other case in which it looks like the employee would benefit from retraining.

To determine the employee’s understanding, you can ask the employee in writing or orally about the information and observe their hands-on use of respirators.

5.  1910.134(d)(1) General Requirements

The general requirements are the general rules for selection of respirators. That is, it is the employer’s duty to:

  1. Select appropriate respirators based on the hazards to which they’re exposed and the workplace factors that will affect them such as temperature/humidity, need for unimpeded vision, need for communication with other workers, usage in conjunction with other PPE, amount of time to be worn, etc.

  2. Select NIOSH-certified respirators and use them in compliance with the conditions of that certification. So don’t use parts for one brand on a different brand of respirators and for airline respirators use in accordance with operating procedures and hose specifications.
  3. Evaluate the respiratory hazards of the workplace. This includes quantifying exposures, identifying the contaminant’s chemical and physical form. You must do an analysis to determine if respirators are needed.  If it’s not possible to identity or estimate, the atmosphere should be considered to be IDLH, or immediately dangerous to life or health.
  4. Select respirators in a sufficient number of models and sizes so that they are acceptable and correctly fit. Not everyone’s face is the same.  We’ve found in fit-testing that not only are there size variances between people, but some just cannot successfully fit test in certain brands and shapes of respirators.

Need Help?  Have Questions?

After reviewing these 5, does your program have all of these bases covered? 

If you have questions, or need help shoring up your respiratory protection program, iSi is here to help!  We can write or review your written programs, help you determine workplace exposures, help with sampling plans, help with respirator selection, and conduct training. Contact us today!

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Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

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OSHA Proposes Changes to Hazcom Standard

OSHA Proposes Changes to Hazcom Standard

Mar 19, 2021

UPDATE:  OSHA has announced an informal public hearing for Sept. 21.  If you’d like to testify or question witnesses, submit your notice by June 18.

OSHA has announced it’s planning on making changes to its Hazcom Standard (29 CFR 1910.1200) and they are soliciting your comments, due by May 19.

OSHA’s changes are to help align the standard with Global Harmonization Standard (GHS) Revisions 7 and 8.  OSHA is also wanting to correct issues it’s found since the last update in 2012 and to make the standard more in line with related federal agencies such as DOT and international trading partners such as Canada.

Here are the items currently up for comment:

 Relabeling Containers and “Released for Shipment” Dates

Right now the standard says that once a chemical manufacturer, importer, distributor or employer knows there is hazard information changes significant enough to affect the SDS, the SDS needs to be updated.  Labels must be revised within 6 months and containers shipped thereafter must have that information on its labels.

OSHA is proposing chemicals released for shipment and awaiting future distribution wouldn’t need to be physically relabeled to incorporate that new information.  Instead, the chemical manufacturer/importer will still need to provide an updated label for each individual container with each shipment. This would help containers with long distribution cycles.  This also reduces the chemical exposure and ergonomic hazards for workers who would be going in and actually physically relabeling containers.

As a result of this, labels on shipped containers will be required to note the date the chemical is released for shipment.  The standard will specifically call out chemicals released for shipment and awaiting further distribution as part of the no relabeling requirement, so they’ll need a date on them to meet that requirement.

Bulk Shipments

Labels for bulk shipments can be placed on the immediate container, or you will be able to transmit them with the shipping papers or bills of lading electronically as long as there’s a printed version available to the people on the receiving end of the shipment.

Changes to bulk shipments are an effort to facilitate inter-agency cooperation with DOT.

Labeling for Small Containers

Labels for small containers less than or equal to 100 mL must include just the product identifier, pictogram, signal word, chemical manufacturer’s name and phone number, and a statement that the full label info for the hazardous chemical is provided on the immediate outer package.  This will be applicable for those containers where it’s not feasible to use pull-out labels, fold back labels or tags with the full information on them.

There will be no labeling requirements for containers less than or equal to 3 mL if the manufacturer, importer, or distributor can demonstrate that any label would interfere with the normal use of the container.  A product identifier that can be identified and linked with the full label info on the immediate outer package would be required on that small container.  OSHA uses an example that a glass vial could be etched with the product identifier instead of needing the label.

Immediate outer packaging would then need to include the full label information, and a statement indicating when not in use, the small containers inside must be stored in this outer packaging that has the label on it.

Trade Secrets

Allow manufacturers, importers and employers to now withhold a chemical concentration range as a trade secret.  Use prescriptive concentration ranges instead of actual concentration or concentration range when they’re claimed as a trade secret.  This change is categorized as help to better work with trading partners as this is something that Canada does.

OSHA wants to know from commenters if this is something that you have worked with and does this give enough information downstream for manufacturers to conduct hazard classifications and protect workers.

 SDS Terminology

A terminology change will replace the word “design” with “stored.”  This will allow SDSs to be stored in a way that covers groups of hazardous chemicals in a work area. They believe the word “designed” is confusing because now SDSs have specific design requirements (16 section format) so they don’t want anyone redesigning an SDS for groups of chemicals in a work area.

Appendix D Changes

  • Changing Section 2 of the SDSs to emphasize that hazards identified under normal conditions of use that result from a chemical reaction must appear on the SDS, even though the hazards don’t need to be listed on the label. This would be a reorganization of the info on the SDS.
  • The Hazcom Standard currently requires SDS Section 3 to include chemical name and concentration/concentration ranges of all ingredients classified as health hazards. OSHA wants to know if this should be expanded to include not only the health hazard classified chemicals, but all classified chemicals such as physical hazard chemicals to help manufacturers better understand hazard potentials when handling these chemicals. This would be similar to what the REACH regulations require in Europe.
  • OSHA would also like to hear comments about using electronic labels, RFID and QR codes on chemical packaging as a form of communicating hazards fully and in real-time. If your company is using electronic labeling, they’d like to know what kind of system you’re using and what benefits you’ve been able to see from it.

Other Appendix Changes

  • Considering revisions in the Skin Corrosion/Irritation section to expand non-animal testing, recognizing in vitro test methods, and reorganizing that chapter. (Appendix A)
  • Adding a new hazard class for desensitized explosives (Appendix B)
  • Adding hazard categories for unstable gases and pyrophoric gases in the Flammable Gasses class and nonflammable aerosols in the Aerosols class (Appendix B)
  • Making editorial, clarifying and reorganizing changes and using more standard language in line with GHS Revision 8. (Appendix C)
  • Requiring prioritization of certain precautionary statements related to medical response. Currently some of the medical response statements give options such as call poison control center or call a doctor or choose between medical advice vs. medical attention.   This can lead to confusion on which choice is best, so they want to standardize that with the best option. (Appendix C)

Definitions and Terminology

  • In the SDS section, a terminology change will replace the word “design” with “stored.” This will allow SDSs to be stored in a way that covers groups of hazardous chemicals in a work area. They believe the word “designed” is confusing because now SDSs have specific design requirements (16 section format) so they don’t want anyone redesigning an SDS for groups of chemicals in a work area.
  • Adding definitions for Combustible Dust, Bulk Shipments, Immediate Outer Packaging, Released for Shipment and Physician or Other Licensed Health Care Professional
  • Revising definitions of a Gas, Liquid and a Solid to align with GHS Revision 7
  • Revise the definition of a hazardous chemical to delete the reference to pyrophoric gases because those will now be a physical hazard in the Flammable Gas hazard class

Training Required

OSHA believes in its economic impact analysis that training updates will be minimal and only apply to certain types of employees.  OSHA says that additional HAZCOM training will be needed to alert those who work with impacted aerosols, desensitized explosives, nonflammable gasses not under pressure, and flammable gasses about the changes in the SDSs.  Those where labels may change may require some additional training and instruction on what to do such as with bulk packagings and small containers.

How Often Should There be Changes?

OSHA is soliciting feedback on how often changes should be made to the Hazcom Standard.  GHS is updated every 2 years. OSHA wants to stay current with GHS revisions.  Only the European Union has updated their guidelines in less time than OSHA (2016) while other countries have only said they planned on it, but haven’t done anything yet.

OSHA would like to know if they should install a regular schedule of updating every 4 years, every 2 revisions of the GHS, or if they should wait until there are significant changes before doing any updates.

Where Can You Make Comments?

You may submit comments identified by Docket No. OSHA-2019-0001, electronically at http://www.regulations.gov, which is the Federal e-Rulemaking Portal.  Formal comments were due in May 2021, however, If you’d like to question witnesses or testify at OSHA’s informal hearing on September 21, 2021, submit your request by June 18, 2021 to the regulations.gov site.

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5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

Mar 4, 2021

5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

Getting Value Out of the “Same Old List”

OSHA’s Top 10 Violations for 2020 have been announced.  So what!   OSHA’s Top 10 hasn’t changed much in the past 5 or 6 years and most of the time it’s the same violations with the order switched around.  The only “exciting” part is to see if a newcomer violation got on list.  The list still didn’t even really change in a pandemic year either.

Well as un-newsworthy as this is, believe it or not, the annual confirmation that it’s the same stuff can actually make your job easier.

First, What’s on the List?

Below is a list of the Top 10 OSHA Violations for 2020

  1. Fall Protection – General Requirements (1926.501): 5,424 violations
  2. Hazard Communication (1910.1200): 3,199 violations
  3. Respiratory Protection (1910.134): 2,649 violations
  4. Scaffolding (1926.451): 2,538 violations
  5. Ladders (1926.1053): 2,129 violations
  6. Lockout/Tagout (1910.147): 2,065 violations
  7. Powered Industrial Trucks (1910.178): 1,932 violations
  8. Fall Protection – Training Requirements (1926.503): 1,621 violations
  9. Eye and Face Protection (1926.102): 1,369 violations
  10. Machine Guarding (1910.212): 1,313 violations

Respiratory protection moved 2 spots up the list this year along with eye and face protection up one spot as well.  Ladders moved up a spot too.  Your top 2 violations were the typical fall protection and hazcom.

Well…It’s the Top 10 for a Reason

First, companies continue to have problems with these issues.  Many of them can be affected by employee behaviors such as how they choose to wear (or not wear) their PPE, conducting (or not) inspections, using (or not) injury saving controls, and situational awareness pitfalls.  As a result, some of these are going to be easier to come across on any given day.

Next, these top 10 may also be considered the low hanging fruit of inspections.  If these are the most common violations, then you could surmise inspectors are going to be looking at these.  Further proof comes from OSHA’s national, regional and local emphasis programs.  Emphasis programs allow an inspector to add to their investigation. For example, if you are having an inspection related to an employee complaint for respirators and there is an emphasis program in your area for powered industrial vehicles, OSHA inspectors can broaden their inspection if they see a forklift in your building.

A check of OSHA’s current emphasis programs includes items from the top 10.  Out of 10 OSHA regions, there are emphasis programs for:

  • Amputations (including machine guarding) – National Emphasis
  • Falls – 9 Regions
  • Powered Industrial Vehicles – 5 Regions
  • Electrical – 2 regions
  • Respirators – 1 region
  • Construction Worksites – 10 regions

Make Your Job Easier Tip 1:  Break it Down

The top 10 have specific standard references with them and from there we can see it’s a mix of general industry and construction standards.  All 10 areas of safety are important.  However, if you break the list down by the standard your company typically operates under, your focus areas are nearly cut in half and this becomes much more manageable. 

General Industry-Related ViolationsConstruction Industry-Related Violations
Hazard CommunicationFall Protection – General Requirements
Lockout-TagoutHazard Communication**
Respiratory ProtectionScaffolding
Powered Industrial TrucksLadders
Machine GuardingFall Protection – Training
Face and Eye Protection

**The 1926 standard for hazard communication refers to the 1910 standard.

Make Your Job Easier Tip 2:  Instant Safety Topics!

Dealing with the immediate site-specific injury-causing issues should always be your first focus.  However, you likely have safety committees, employee safety briefings, toolbox meetings, newsletters to write, safety emails to send, etc.  The shortened list can now be easy go-to topics. 

Get your co-workers and safety teams talking about them.  As mentioned before, some of these items are going to be related to their behaviors and decisions anyway.  Head off the top 10 one person at a time and don’t feel bad if you need to continue to cover them.  The world of sales tells us that most people need to hear about something 7 times before it sticks.

Make Your Job Easier Tip 3:  Get Your Documentation in Order

A number of these areas have specific training and/or inspection requirements.  Document, document, document! 

For training, keep records of who took training, when training was conducted, who the trainer was and what the content of the training included.

For inspections, find a way to document these and have a process in place for taking equipment which fails out of service. This will be important information for you during an inspection and can go a long way in staying away from the top 10.

Make Your Job Easier Tip 4:  Incorporate These Into Your Walkthroughs

If you’re not doing so already, set aside a little bit of time each week to conduct a safety walkthrough and incorporate these items into your checklist.  Routine walkthroughs will allow you to keep up on what’s going on at your site, gives you a chance to correct deficiencies, and gives you an opportunity to take advantage of teachable moments to the workers in those areas.  Get your employees involved in inspecting their workplace.  Have them be on the lookout for these same issues in walkthroughs and peer-to-peer observations.

Make Your Job Easier Tip 5:  Get Help

You are not Superman/Superwoman.  There are too many tasks, crises, and other forces that can get in the way of getting it all accomplished. A good manager needs a supporting cast.  If you can get someone at your company to help you with tasks, that would be great.  However, if you cannot, consider getting an outside company or safety professional to help. Consultants like iSi are here for a reason.  We have people on-staff who have been in your position and have experience with the regulations.  We can often do what needs to be done (and done correctly) in a fraction of the time it would take for you to do it, or for you to train someone else internally to do it.  This can be as simple as getting help a writing program or conducting training.  It could be having an audit done to see where you stand on compliance or a bigger project such as revamping a safety program or day-to-day onsite assistance.

In Conclusion

Use the data from the Top 10 as your instant to-do list.  If you can tackle the items that pertain to you, you can help do your part in avoiding those common fines and maybe shaking up the list for next year.

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2020 ERG – Emergency Response Guidebook Updates

2020 ERG – Emergency Response Guidebook Updates

Oct 28, 2020

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

What is the ERG?

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

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

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

Updates

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

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

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

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

Orange Pages [Response Guides]

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

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

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

Green Pages [Isolation and Protective Action Distances]

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

Where Can the Current ERG Be Found?

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

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12 Tasks for Safety Managers Working From Home

12 Tasks for Safety Managers Working From Home

Apr 16, 2020

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

1. Develop Your Pandemic Plan

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

2. Review/Develop Cleaning Procedures

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

3. Review Your Emergency Plans

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

4. Review Your Written Safety Programs

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

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

5. Take Advantage of Web Conferencing for Safety Training

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

6. Spruce Up Your Training Materials

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

7. Write your RFPs

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

8. Get Quotes for Services and Products

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

9. Develop a Presentation for a Local Organization or Conference

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

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

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

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

11. Permit Reviews

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

12. Clean Up Your Email

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

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Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

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

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

Apr 2, 2020

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

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

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

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

Overall EPA Guidance

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

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

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

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

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

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

Hazardous Waste

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

Ensure you document everything and put it in your records.

Air Emissions

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

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

Wastewater

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

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

Stormwater 

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

Spill Prevention, Control and Countermesure (SPCC)

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

Public Water Supply

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

Accidental Releases

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

Questions?

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

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Electronic EHS Training: Maintain Certifications, Complete Requirements Now

Electronic EHS Training: Maintain Certifications, Complete Requirements Now

Mar 25, 2020

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

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

Viewing Options — How It Works

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

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

March and April Scheduled Classes Moved Online

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

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

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

Other Classes Available

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

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Potential Employer Requirements in an OSHA Emergency Standard for COVID

Potential Employer Requirements in an OSHA Emergency Standard for COVID

Jan 26, 2020

UPDATE: 

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

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

What’s an OSHA Emergency Temporary Standard?

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

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

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

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

Conducting a Workplace Assessment

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

Develop an Exposure Control Plan

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

Implement Controls 

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

Training Employees 

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

Maintain Records of Training, Screenings, and Notifications

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

How Often Have Emergency Standards Been Used Before?

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

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

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

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Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

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

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The Importance of Professional Organizations and Conferences to Your EHS Compliance

The Importance of Professional Organizations and Conferences to Your EHS Compliance

Oct 12, 2018

tami hadley

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

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

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

Stay Current on Regulations

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

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

Meet People Who Have the Same Issues You Do

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

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

Connecting and Recruiting

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

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

Unplugging is a Good Thing

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

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

It’s OK to Sit by a Vendor

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

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

List of Organizations

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

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

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

American Society of Safety Professionals (ASSP)

American Industrial Hygiene Association (AIHA)

Alliance of Hazardous Materials Professionals (AHMP)

National Safety Council (NSC)

Air and Waste Management Association (AWMA)

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

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

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Who Regulates Hazmat Shipments?

Who Regulates Hazmat Shipments?

Sep 21, 2018

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

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

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

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

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

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

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

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

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

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

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