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

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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Preparing Your OSHA Logs – An Overview

Employers with 10 or more employees are required to prepare and maintain regular records of serious occupational injuries and illnesses using the OSHA 300 Logs unless they are deemed a low-risk exemption by OSHA. This information helps employers, workers, and OSHA in evaluating the safety of a workplace, understanding its possible hazards, and implementing worker protections to reduce and eliminate hazards. It is important to always maintain accurate injury logs as the requirements are enforceable under OSHA Recordkeeping regulation 29

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Forklifts in the Workplace – Protecting the Pedestrian

Forklifts and other powered industrial trucks frequently operate in the same areas as pedestrians and workers. Far too often, close calls or near misses occur when both forklift operators and pedestrians become complacent in their surroundings. This contributes to over 100 fatalities and 90,000 injuries annually in the workplace. Over 20 percent of forklift accidents involve employees or pedestrians being hit by forklifts, making it the number two cause of forklift-related accidents and injuries (just behind forklifts tipping or rolling

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EPA Finalizes RMP Reconsideration Rule

On November 20, 2019, the U.S. Environmental Protection Agency (EPA) signed the Risk Management Program (RMP) Reconsideration Rule as a result of three petitions submitted to reconsider the RMP regulations mandated in 2017. According to the EPA, this new rule rescinds and modifies certain revisions in order to “better address potential security risks, reduce unnecessary and ineffective regulatory burdens on facilities and emergency responders, harmonize rather than conflict with the Occupational Safety and Health Administration’s (OSHA) Process Safety Management standard,

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EPA’s Biennial Report – What You Need to Know

The EPA’s March 1 Biennial Reporting deadline is coming up faster than one might realize, which means Large Quantity Generators (LQGs) of hazardous waste should start preparing for what they will need to complete the report. The Biennial Report, more formally known as the National Biennial RCRA Hazardous Waste Report, is a requirement under Section 3002(a)(6) of the Resource Conservation and Recovery Act (RCRA) and must be submitted by March 1 of every even-numbered year. Who must report? Reporting is

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Assessing Wastewaters from Metal Finishing Operations for EPA Categorical Standards

Under the Clean Water Act, the EPA put the Metal Finishing Categorical Pretreatment Standards into effect on July 15, 1983, as 40 CFR Part 433. The regulations cover wastewater discharges from a wide variety of industries performing various metal finishing operations. More specifically, the metal finishing operations applicable to the standard mostly involve the process of changing the surface of a metal object to improve its appearance and/or durability. Applicability of the Metal Finishing Category is defined by the type

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Lockout/Tagout – Effective Implementation

How do I start a Lockout/Tagout Program? Lockout/tagout programs prevent injuries and ultimately, save lives. Lockout/tagout is an energy control procedure that requires an employee to isolate energy before doing any cleaning, adjusting, or repairing of a piece of equipment. In layman’s terms, it means that if an employee is going to access a piece of equipment by removing a guard or sticking a body part into a point of operation to clean, adjust, or repair it, then the power

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OSHA Inspections – Keys to Success

According to the latest statistics provided by OSHA, there were approximately 73,000 federal and state plan inspections that occurred throughout the 2018 fiscal year. Were you one of those companies? If so, how did your company fare during the inspection? Was your company prepared? OSHA inspections, like any regulatory inspection, can be positive experiences or they can go poorly. The state of your current safety program obviously plays a significant role in how successful you are at getting through an

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Defining “Oil” Under the SPCC Rule

As a refresher, a Spill Prevention Control and Countermeasures (SPCC) plan is required for facilities storing oil with an aggregate storage capacity greater than 1,320 gallons in containers greater than 55 gallons. The plan is a requirement under the Oil Pollution Act (OPA), an amendment made to the Clean Water Act (CWA) in 1990. Under the SPCC rule (40 CFR 112.2), “Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases

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