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,

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

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

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

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

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

Every year, millions of employers are required to keep track of their workers’ injuries and illnesses by recording them in what is often called an “OSHA Log.” The OSHA Logs consist of three separate documents: the Form 300 Log of Work-Related Injuries and Illnesses, the Form 300-A Summary of Work-Related Injuries and Illnesses, and the Form 301 Injury and Illness Incident Report. It is required for all applicable employers (employers with 10 or more employees in certain industries) to retain

Water from rain and melted snow washes dirt, oil, garbage and chemicals into nearby rivers and streams. This can be very hazardous to the health of these water channels and the land surrounding them. Keeping industrial materials in a storm-resistant shelter protects surrounding waterways from exposure to the potentially harmful effects of industrial stormwater runoff.       HISTORY The No Exposure Certification (NEC) is an option under Federal & State Industrial Stormwater Permits, commonly referred to as Multi-Sector General Permits (MSGPs).

HISTORY In 2017, the US EPA finalized updates to the RCRA regulations, called the Hazardous Waste Generator Improvements Rule (GIR). The purpose of the update was to increase compliance within the hazardous waste generator community and allow some additional flexibility for managing hazardous waste. The overall impact of the rule change will lessen the regulatory burden for the majority of hazardous waste generators. States with authorized hazardous waste programs will be required to adopt the more stringent provisions and have

As working environment temperatures increase due to the season or other factors, heat-related risks can be effectively reduced for employees working inside or outside using a combination of controls and knowledge. What do you need to know to protect your employees? The level of heat stress exposure at your facility The human body’s response to heat stress Steps that can be taken to prevent heat-related illnesses Let’s briefly review each of these topics to help reduce the risk of heat

For the 2019 year, OSHA has some notable updates in the areas of enforcement activities and recommended reduction efforts for training programs, along with the elimination of an agency board. The new annual budget for OSHA is $557,000,000, which is 5% more than the previous year of $531,500,000. This new budget will add 26 additional compliance officers and five full-time whistleblower investigators. Reduction areas include a severe decrease in funding to the Susan B. Harwood Training Program that has been

It’s the phone call every safety, plant or human resource manager dreads: “There’s someone from OSHA here waiting for you in the lobby.” Regulatory action isn’t the sole reason we work every day on our safety programs, but it does create an instance where the “rubber meets the road” so to speak. Being able to see your facility through the eyes of a regulatory inspector enables you to recognize potential issues and implement corrective actions to provide a safer workplace.