Care, Protect, Grow: The U.S. Compliance Blog

Batteries and Tier II Applicability

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!

 

U.S. Compliance: The Best Kept Secret!

At U.S. Compliance we hold three values close to the heart of our business. When we created “Compliance as a Service” (CaaS) it was a revolutionary model to offer OSHA and EPA compliance consulting services perfectly designed for growing industrial companies. We created the revolutionary CaaS model because it’s good for our clients, thanks to the elite team members who deliver it. U.S. Compliance is the inventor of CaaS and the only firm built to deliver it.

 

U.S. Compliance Values

Caring for our clients and our employees.

Protecting an environment that provides both physical and financial well-being.

Fueling growth for our customers, team members and company.

By offering comprehensive, customized EHS compliance services, we not only help you attain but sustain EHS compliance. We help you care for your people, protect your environment and grow your company. Thank you for naming us the best kept secret. We look forward to helping you care, protect and grow alongside U.S. Compliance.

Earn $500 with a U.S. Compliance Referral!

We’ve built our business and reputation on word-of-mouth, and we’d like to grow that even more. Compliance as a Service (CaaS) recognizes that today’s regulatory environment requires an “always-on” approach that keeps you in compliance and ahead of the game. We also recognize that many manufacturers need a third-party compliance resource to complement and support their existing personnel—many of whom have to wear multiple hats and can provide greater value if they’re free to work on the business rather than in it.

 

Let us know who you think could benefit from our unique Compliance as a Service safety and environmental compliance solution. If your referral leads to a new Fundamentals customer, we’ll reward you with a $500 on your next U.S. Compliance invoice. It’s that simple!

 

Your testimonials tell us how much U.S. Compliance means to your businesses and employees. We want to grow our company to support all businesses in search of the quality we deliver. Send us a referral today & earn $500!

OSHA Electronic Recordkeeping Due March 2

Saturday, March 2nd is the deadline to electronically report your OSHA Form 300A data for injuries and illnesses reported in the 2018 calendar year. Specified establishments are required to submit this electronic information.

Establishments, not the firm as a whole, with 250 or more employees are no longer required to electronically submit their OSHA Form 300A. Only a small number of establishments are required to electronically submit their Form 300A data electronically to OSHA. If your establishment meets any of the following criteria an electronic submission is NOT required.

  • Peak employment in 2018 was 19 or fewer
  • Establishment’s industry is on this list
  • Peak employment between 20 and 249 employees in 2018 AND establishment’s industry is NOT on this list

All establishments, regardless of size or industry, must post their OSHA Form 300A on site at each workplace (from February 1 through April 30). OSHA Forms 300, 300A, and 301 records must be kept for five years and readily produced for OSHA inspections. You can read the OSHA ruling on electronic submission requirements in its entirety through the Federal Register.

If you are required to submit the OSHA Form 300A, submissions can be made through the Injury Tracking Application. If you need further clarification on whether or not your establishment must electronically submit the OSHA Form 300A review the OSHA FAQs on Reporting or call U.S. Compliance for more information.

OSHA’s Most Frequently Cited Violations

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.

How Not to Wreck Your Back at Work

Common Causes of Back Pain

Back pain is often identified as an unavoidable ailment, most especially for those working physically demanding jobs. Back pain is commonly caused by:

  • Poor lifting techniques
  • Bad posture-seated or standing
  • Physical overexertion by force
  • Extensive amounts of inactivity

Preventing Back Pain at Work

Avoiding the most common causes of back pain will help you remain pain free at work. Preventative practices include simple changes and awareness of your body’s physical capabilities. Follow the guidelines below to reduce your risk of back related injuries and promote healthier choices in your workplace.

Proper Lifting Techniques

Lift with your legs as you tighten your core abdominal muscles. This method allows you to use the strength of larger muscles instead of the ligaments and smaller muscles in your back. Keep heavy objects close to your body. If an object proves too heavy to lift on your own, ask for help or use equipment designed to properly lift heavy items. Limit the time you spend carrying heavy items by taking short breaks.

Upright Posture

Good posture, whether standing or sitting, improves overall back health and maintains spinal alignment. When standing, balance your weight evenly on both feet. Keep your shoulders raised and level; slouching can add pressure and tightness to your back. When sitting, choose a chair that allows you to rest your feet flat on the floor and comfortably supports the curves of your spine.

Modified Exertion

Small tasks, when repeated throughout the day, can cause strain on your body. Slow build up in the body of these repeated movements can lead to chronic back pain if not addressed properly. Alternate physically demanding tasks with less demanding actions, giving your body recovery breaks.

Activate Your Body

Inactivity over long periods of time can lead to tight muscles and achy limbs. Activating your body gives your muscles an opportunity to engage, recover properly, and renew strength. Take a walking break if you work at a desk for long stretches of time. When seated, march your legs in place or move your arms in circles to keep blood circulation flowing.

 

Taking part in periodic exercise helps improve overall health and wellness, which helps prevent back pain or injury. Walking, swimming, or aerobic exercises strengthen your back muscles and abdominal core. Improving balance with exercises such as yoga or tai chi decreases your risk of falling and injuring your back.

OSHA Safety Guidelines

The OSHA Technical Manual associates back injury with common workplace activities. Employers should observe employee postures and lifting mechanics. Suggestions for evaluating behaviors that can lead to back injuries are outlined and include surveying employees for safety understandings related to workplace incidents of back pain. In the event of a back injury, employers must record the injury on the OSHA Form 300 log and make any necessary safety adjustments to prevent future incidents.

How to Prevent Cold Stress This Winter

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.

Reminder: Post OSHA 300A Form Friday, February 1st

The OSHA Form 300A ‘Summary of Work-Related Injuries and Illnesses’ for the 2018 calendar year must be posted beginning Friday, February 1. The summary log must be posted at each establishment in a common area where employees are accustomed to viewing notices until Tuesday, April 30.

All employers that are required to maintain an OSHA 300 Injury and Illness log must post the accompanying OSHA 300A summary sheet in their workplace. A company executive must review the related OSHA 300 log and certify that the documented information is correct and complete by signing/dating the OSHA 300A summary form prior to posting. Companies with no recordable injuries or illnesses must post the summary form showing zeros on the total line.

If you are concerned about maintaining these records and/or meeting this deadline, call U.S. Compliance today for support. If you have questions about what injuries and illnesses must be documented, read OSHA Guidelines for Recordkeeping or call U.S. Compliance for more information.

Get Your Facts About Stationary Engines

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.

5 Things That Could Trigger an Environmental Inspection on Your Facility Today

Environmental regulatory inspections aren’t slowing down any time soon. In fact, evidence suggests that manufacturers are seeing even more facility inspections and higher penalties these days. If inspectors showed up at your door today, would you be ready for them?

Whether you receive regular inspections or haven’t had one in years, it isn’t a matter of if it’s going to happen, but when. Being prepared starts with knowing the various ways an environmental inspection can be triggered on your facility. Here are the top five:

  1. Routine Inspections. These are typically focused on one area (e.g., air, waste, storm water). Regulatory agencies often employ advanced technologies to identify sites for inspection or follow materials of concern up (or down) the supply chain.
  2. Referrals. Inspectors from one area will sometimes notice potential areas of concern in other areas, then inform inspectors from the relevant departments.
  3. Report Discrepancies. If significant changes or inconsistencies appear in your facility’s environmental reporting from one period to the next, it can raise flags for regulators and trigger an inspection.
  4. Permit Status or Permit Changes. If you apply for a new permit status or make a change to an existing permit, inspectors might be prompted to visit your facility prior to approving the application.
  5. Public Notification. An agency might be prompted to visit your facility based on an incident report, a tip from a neighbor, a story in the media or some other third-party source.

What can you do to better prepare yourself for any of these triggers? We recommend three specific preparations:

  1. Develop an Environmental Compliance Monitoring System for your facility.
  2. Designate primary points of contact on-site.
  3. Conduct mock inspections or drills.

These steps will help make an environmental inspection a successful and low-stress event. For more information on what they involve, give U.S. Compliance a call at (952) 252-3000.