As we begin 2019, we enter another busy reporting year. With that being said, how familiar are you with the March 1st ECPRA Tier II reporting requirements? Whether you are a small distribution center or the largest manufacturing facility in the United States, chances are you may be failing to accurately assess your facility’s Tier II applicability. In brief, Tier II is a hazardous substance storage reporting that notifies both state and local authorities of potentially hazardous materials that facilities are storing onsite over threshold.

The three questions below may help you catch a common reporting mistake. If you answer “yes” to the questions, it is highly likely that your facility needs to report the extremely hazardous substance (EHS), sulfuric acid, for Tier II reporting.

1. Are forklifts, pallet jacks or lift trucks operated at your facility?
2. Are any of the above listed industrial equipment battery powered?
3. Is more than one industrial sized battery present onsite at any one time?

The EPA has established lower reporting thresholds for EHSs, such as sulfuric acid. Therefore, simply having three lead-acid batteries onsite could cause the facility to exceed the 500 lb. reporting threshold.

Be aware: For those of you located in New York City, California, Oregon, Denver or Las Vegas, your facility will most likely need to report sulfuric acid storage even if you only store one lead-acid battery onsite!

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The 10 most frequently cited standards across the country have been published by OSHA. Preventable injuries lead these violations from the 2018 fiscal year.

OSHA’s regular worksite inspections throughout the 2018 fiscal year (October 1, 2017-September 30, 2018) yielded the ten standards most often cited.

1. Duty to Have Fall Protection (Standard 1926.501)

The OSHA standard for fall protection requires employers to protect employees from sides and edges, steep roofs, excavations, etc. that pose the risk of falling. Lack of proper fall protection is the most common violation of worksites across the country.

1. Hazard Communication (Standard 1910.1200)

Disseminating information to employees regarding classified hazardous substances is an OSHA requirement. This includes posting on-site chemical exposure risks, creating proper container labels, and sharing safety data sheets.

1. General Requirements (Standard 1926.451)

This standard speaks specifically to scaffolds and the supports that assist in maintaining the safety of workers. Requirements for platforms, tiebacks, outriggers, ladders, etc. are outlined in this standards.

1. Respiratory Protection (Standard 1910.134)

Utilizing proper engineering control measures to prevent atmospheric contamination is the first step to minimizing employee exposures to contaminated materials in the air. Respirators are a protective requirement for workplaces with airborne contaminants.

1. The Control of Hazardous Energy (Lockout/Tagout) (Standard 1910.147)

Controlling energy in machines and equipment that is potentially harmful during servicing and maintenance is the focus of this standard.

1. Ladders (Standard 1926.1053)

This OSHA standard pertains to the load a ladder must be capable of safely supporting. Requirements for each ladder type are outlined and include beam specifications and rung distances.

1. Powered Industrial Trucks (Standard 1910.178)

The design, maintenance, fire protection and use of specified trucks is outlined in this OSHA standard, requiring proper labeling and on-truck markings.

1. Training Requirements (Standard 1926.503)

Training programs for employees who may encounter fall hazards are required. A competent, qualified person must train employees to recognize hazards of falling and employers must certify the occurrence of this training in writing.

1. General Requirements For All Machines (Standard 1910.212)

Focusing on types of machine guarding, this standard outlines the requirements necessary to protect machine operators and employees from sparks, rotating parts, etc.

1. Eye and Face Protection (Standard 1926.102)

Appropriate eye and face protection, with side protectors, is required for employees who may be exposed to hazards such as flying particles, acids, or chemical vapors. Eye and face PPE must fit adequately and remain fully functional throughout their use.

Call U.S. Compliance with any questions regarding your company’s compliance with these, or other, OSHA standards.

Working in cold temperatures increases the risk of cold stress injuries and illnesses. Prepare for cold stress with proper cold weather safety.

What is Cold Stress?

Cold stress is a condition caused by a significant decrease in your body temperature resulting in the inability to naturally warm up. Higher risks of illness and injury are associated with cold stress. Exposure to cold temperatures (winter weather, freezers, cold storages, cold warehouses) increases the likelihood of cold stress injuries. Wind chill, dampness, cold water and snow all draw heat away from the body and lower your body’s ability to maintain its core temperature, increasing your risk of cold stress related illness.

Types of Cold Stress

According to OSHA, the most common types of cold stress dangers include hypothermia, frostbite, and trench foot. Each cold stress hazard has unique warning signs, yet all can be prevented with proper cold weather safety procedures.

Hypothermia means your body can no longer sustain internal warmth. Symptoms may include shivering, slurred words, and confusion. Provide warmth immediately to prevent severe damage.

Frostbite is the freezing of parts of the body, most commonly fingers and toes. Numbness, tingling, and aching are symptoms of frostbite. Provide warmth quickly, but avoid massaging or walking.

Trench Foot is a non-freezing syndrome caused by prolonged exposure to cold and wet conditions. Tingling, swelling, numbness and blisters are the most common symptoms. Remove wet layers and provide warm, dry conditions as quickly as possible.

Cold Stress Prevention

Preventing cold stress requires adjustments in the working environment, proper cold weather gear, and warming breaks. Follow these winter preparedness tips for increased safety in cold workplace environments.

• Wear loose layers and moisture wicking clothing close to the skin to prevent moisture buildup.
• Hats and head coverings should be worn to prevent body heat from escaping.
• Wear loose, insulated, waterproof, and wind resistant outer layers to keep heat close to the body while allowing blood to circulate freely.
• Drink non-caffeinated liquids to reduce the risk of dehydration.

OSHA Standards on Cold Stress

The General Duty Clause, Section 5(a)(1) of the OSH Act of 1970, requires employers to furnish working environments ‘free from recognized hazards that are causing or are likely to cause death or serious physical harm’. Although OSHA does not specify regulations for cold stress, this clause mandates that employers understand cold stress injuries and illnesses and prevent these cold temperature dangers. Cold stress related injuries or illnesses must be documented and reported on the OSHA Form 300 log.

Be sure your workplace environment and employees are prepared for working in cold temperatures. Assess cold weather clothing prior to beginning tasks in cold temperatures. Regulate consistent breaks in warm temperatures throughout the work day. Encourage proper hydration. Preventing cold weather injuries in your workplace supports a strong  and safe community.

There’s a good chance you’re using RICE (Reciprocating Internal Combustion) engines to generate electricity or to power pumps or compressors at your facilities. There’s also a good chance that you may not know the latest environmental regulations applying to those engines.

While emissions from one RICE engine are relatively small, cumulative RICE engine emissions include toxics like formaldehyde, acrolein, acetaldehyde and methanol. In addition, they emit conventional pollutants such as carbon monoxide (CO), volatile organic compounds (VOCs), nitrogen oxides (NOx) and Particulate Matter (PM). Exposure to these pollutants can cause a variety of negative respiratory and central nervous system health effects.

For this reason, it’s important to know the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reciprocating Internal Combustion Engines (RICE Rule), and New Source Performance Standards (NSPS) for Stationary Internal Combustion Engines (ICE). In general, EPA air quality requirements differ according to whether stationary engines are new or existing, located at an area or major source, are used for emergency or non-emergency purposes, and are spark-ignition or compression-ignition engines.

If you think you might be subject to these stationary engine rules—and you need help sorting them all out and making sure that you attain and sustain compliance—call U.S. Compliance at (952) 252-3000.