"CARE, PROTECT, GROW": THE U.S.COMPLIANCE BLOG

Am I Required to Prepare and Implement a Spill Prevention Control and Countermeasure (SPCC) Plan?

The purpose of an SPCC Plan is to establish a comprehensive program that mitigates oil spills from reaching navigable waters and describes the necessary equipment, engineered controls, and procedures in place to prevent oil spills from occurring. The SPCC Rule is controlled under The Oil Pollution Prevention Regulation, which is outlined in Title 40, Part 112 of the Code of Federal Regulations. For a facility to be applicable under the SPCC Rule, they must: Be non-transportation-related; Have aggregate bulk oil

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Reducing Zinc and Total Suspended Solids in Stormwater Runoff

Many states require facilities covered under a general industrial stormwater permit to collect stormwater samples and have them analyzed for common pollutants. Stormwater pollutants vary by facility and industry because the potential pollutants will be dependent on the materials and equipment stored inside and outside of the facility. Two common stormwater pollutants are zinc and total suspended solids (TSS). It is not always clear where a pollutant is coming from, which makes lowering the level of that pollutant in the

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Refrigerant Management: The Scientific Basis to the Current Regulation

Chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) have historically been used in a variety of refrigeration applications in manufacturing, from large process chillers to small office air conditioning units. Sections 608 of the Clean Air Act and subsequent federal regulations under 40 CFR 82 regulate these refrigerants to minimize detrimental atmospheric changes caused by releases. As recent regulations have changed, it is important to understand the mechanisms by which the refrigerants can cause atmospheric changes and how to manage facility use. Understanding

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SPCC Transformers: Am I Responsible?

It is becoming increasingly common to find electric transformers at large commercial, institutional and industrial facilities. Although the transformer is located on the facility’s property, it is sometimes unclear who actually owns the transformers and is responsible for the maintenance and spills. The transformer may be owned by the facility, typically seen on older properties or those that require multiple transformers with high voltage, or by the local power company. Units that contain oil are called “wet” transformers as they

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Ozone Nonattainment: Impact to Air Permitting

Under the Clean Air Act, the U.S. Environmental Protection Agency (EPA) sets National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the environment. Any city or county that does not meet a NAAQS is classified as a nonattainment area. Ozone is one of the six criteria pollutants with NAAQS and is formed when nitrogen oxides (NOx) and volatile organic compounds (VOCs) react in the atmosphere in the presence of sunlight. The EPA set the 2008

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Hearing Conservation in the Workplace

The goal of the Occupational Safety and Health Administration’s (OSHA) hearing conservation standard (29 CFR 1910.95) is to protect the approximate 22 million workers that are exposed to hazardous levels of noise each year. Through the hearing conservation standard, employers are required to evaluate workplaces for employee exposures resulting in a personal time-weighted average (TWA) equal to or greater than 85 decibels (dBA). Results at or above this noise action level require the employer to develop a written Hearing Conservation

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Interim Guidelines – Safe Mask Usage During COVID-19

Companies With a Pre-Existing Mandatory N95 FFR Respiratory Protection Program: Because of the increased demand for N95 filtering facepiece respirators (FFRs) during the COVID-19 outbreak, and the resulting limitations on the availability of these respirators for use, OSHA has provided temporary compliance direction with 29 CFR 1910.134 (as it relates to mask selection and the associated requirements). First, if your company already has a mandatory respiratory protection program that requires N95 FFRs to be worn for protection against air contaminant

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Temporary/Contingent Worker Safety

The staffing, recruiting, and workforce solutions industry makes a vital contribution to the U.S. economy every year. It provides outstanding job and career opportunities for approximately 16 million employees annually. In 2013, the U.S. Occupational Safety and Health Administration (OSHA) launched its Temporary Worker Initiative (TWI) focused on compliance with health and safety requirements for workers that are employed under the joint or dual employment of a staffing firm and host employer. According to OSHA, both host employers and staffing

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PFAS – An Addition to TRI

Basic Information PFAS are man-made, manufactured chemicals that are used in many industries around the world for a variety of consumer products (non-stick cookware, Teflon, dental floss, water-resistant clothing, paints, and many other commercial household products). Some of the more common PFAS chemicals include PFOA (Perfluorooctanoic Acid), PFOS (Perfluorooctane Sulfonate), and GenX. PFOA and PFOS have been studied and manufactured the most in comparison to the rest of PFAS. These two chemicals can be found in the environment and within

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Stormwater Sample Collection and Logistics

Industrial facilities with stormwater permit coverage typically must conduct periodic stormwater sampling during a rain event. The most common type of stormwater permit for industrial activities is a Multi-Sector General Stormwater Permit (MSGP). The stormwater sampling parameters and frequency are often state-specific and dependent on the type of industrial activity occurring onsite. State MSGPs require stormwater sampling to determine the water quality of the stormwater leaving the site and reflect the effectiveness of best management practices (BMPs). These BMPs are

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OSHA’s Top 10 for 2019

Introduction Every year, OSHA publishes a list of the Top 10 Most Cited Violations from the fiscal year across general industry and construction standards. Even with increased attention to health and safety in the workplace, the Top 10 has many constants year after year. Complex standards lead to a direct relationship between the Top 10 Most Cited and the top 10 highest penalties from the year (ranging from $530,592 to $1.792 Million in FY 2019). As was the case in

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Hazardous Material Storage Reports with Non-Federal Thresholds

Background Hazardous materials storage reporting, or more commonly referred to as Tier II, is an annual report that was instated by the EPA through the Emergency Planning and Community Right-to-Know Act (EPCRA) under the Superfund Amendments Reauthorization Act (SARA) Title III in 1986. SARA Title III is a statute designed to improve community access to hazardous chemical information and facilitate the development of emergency response plans. Section 312 of the EPCRA requires the EPA to collect annual data from facilities

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