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

Parametric Monitoring: What It Is and How to Manage Abnormal Readings

The Clean Air Act (CAA) was established to protect public health and the environment from hazardous and harmful emission releases into the atmosphere. As part of the CAA, stationary source emissions monitoring was implemented; this provides data and information from a source to demonstrate compliance with certain regulatory requirements in federal or state rules, or in an operating permit. Parametric Monitoring Systems Parametric monitoring systems use observations of an operational parameter of an emission unit, emission process, or air pollution

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Environmental Reporting and Covid-19

The upcoming environmental reporting season includes major obligations for most programs. With business as usual disrupted for the past couple of months, it is important to prepare the necessary information in order to submit accurate reports despite furloughs and temporary closures. With the expiration of the EPA’s COVID Temporary Enforcement Policy on August 31, 2020, it is important to understand how regulatory agencies are exercising their enforcement. Are regulatory deadlines in effect? Yes. There has been consistent communication that all

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Ergonomics: Keys to Injury Reduction

Whether we spend our day sitting in an office chair or working on a production floor, we are all affected by ergonomic factors. Poor management of ergonomic risk factors may lead to Work-Related Musculoskeletal Disorders (WMSDs) such as repetitive stress injuries, lower back injuries, vibration syndromes, subluxation, and neck and shoulder injuries. In order to protect ourselves and our employees, we need to understand what ergonomic risks we are exposed to, and more importantly, how to control these risks to

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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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