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Just about any facility that takes raw materials to make something has unwanted byproducts in the form of air emissions, residuals in wastewaters, and materials disposed of as solid and sometimes hazardous wastes. Federal, state, and local rules govern handling, management, and control of pollution from these and other “discharges”. Determining which rules and requirements apply and keeping up with the controls, monitoring, testing, and recordkeeping are not always straightforward tasks.
Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) requires owners/operators of facilities, with 10 or more full-time equivalent employees with covered operations meeting certain North American Industry Classification System (NAICS) codes, to submit a Toxic Release Inventory (TRI) Form A or Form R for each TRI-listed chemical manufactured, processed, or otherwise used in quantities above reporting thresholds by July 1 each year.
Onsite Occupational COVID Testing Methodologies -Breaking the Chain in 2021 During Vaccination and Post Vaccination
During 2020, occupational screening to identify potential COVID-19 carriers was limited to monitoring employee body temperature in conjunction with administration of a questionnaire aimed at identifying employees who exhibited coronavirus symptoms (headache, loss taste/smell, sore throat, cough or gastrointestinal issues) or workers who had close contact with a potential coronavirus carrier.
A roofer was inspecting along the edge of a roof three stories above the ground in preparation for replacing damaged shingles. His foot slipped and, having no fall protection, he fell to the concrete sidewalk below sustaining fatal head injuries. The ensuing OSHA investigation resulted in no citations because there had been no violation committed.
I was conducting a 3 year audit of a client’s injury and illness recordkeeping and ran across a very unusual case which had not recorded on the company’s OSHA 300 Log. Not sure myself, I called OSHA on behalf of the client to get a verbal interpretation. I was told the case should indeed be recorded on the Log.
Although this is not a hot take, we were reminded during a recent RCRA workshop that National Compliance Initiatives (NCI) established for 2020-2023 will remain on the EPA’s (and State’s) priority lists for 2021. Given a change in the administration, the priority may be heightened.
Five Lessons from the Pandemic that Perfectly Demonstrate the Challenges of Establishing a Safety Culture
Like almost everyone else with whom I come into contact (six feet between, of course), I have grown exhausted of COVID-19 and the constraints it places on how I live and work. My role as an EHS professional is already demanding, regardless of world health conditions, and the latest recommendations from the CDC only add to my never-ending list of daily considerations and responsibilities.
Being a long-time woodworker, I was always a big fan of Norm Abrams and his show, The New Yankee Workshop. One thing you could always count on was Norm, before powering up a table saw or any other shop equipment, would implore his viewers to “be sure to read, understand and follow the safety instructions that come with your power tools.” It doesn’t make any difference what the equipment is; forklift, aerial lift, scissor lift, hard hat, respirator, etc., manufacturers all advise potential users to read the instructions that accompanied the equipment.
As the COVID-19 pandemic continues to alter most aspects of business operations, questions surrounding the best options for employee training persist. Does it make more sense to complete training online or are classes with in-person trainers preferred when offered safely?
The pandemic has disrupted life as we know it and caused restrictions on public gatherings. How can Environmental, Energy, Health & Safety professionals learn from each other, and exchange ideas? For 2020, The North Carolina Manufacturers Associations (NCMA) is hosting its Environmental Energy Health & Safety (EEHS) School as a virtual event.
Lessons Learned from Occupational COVID-19 Screening – Part III: Tips for an Effective COVID-19 Screening Process
Maintaining continuity of technicians who perform screening is one of the most important aspects for the effective identification of coronavirus carriers. Developing rapport with employees during COVID-19 screening, especially when administering the COVID-19 screening questionnaire, is imperative. Having consistent personnel perform COVID-19 screening day after day creates an environment of trust.
Adequate planning for an occupational screening process is key for an efficient and effective operation to identify potential coronavirus carriers BEFORE they enter the workspace. Will the screening operation be staffed using the existing workforce or by engaging a third party? If staffed internally, do these “in-house” employees have sufficient training in PPE and bloodborne pathogen control? What types of PPE will be used?
Testing wastewater for the presence of pathogens as a surveillance tool has been used by for many years (Poliovirus and antimicrobial resistance (AMR) as an example). This public health tool is now being utilized during the current pandemic to detect SARS-CoV-2 (COVID-19) by analyzing wastewater samples from public and private wastewater systems for non-infective RNA fragments of the virus.
EI’s next two blog entries will focus on the major points garnered from our field experience during screening of 120,000 employees to identify potential COVID-19 carriers as they reported to work at numerous manufacturing/pharma/biopharma facilities over the past 6 months. During the COVID-19 screening process, in order to minimize potential COVID-19 transmission in the workplace, EI employed the New Rochelle Incident Command model for coronavirus testing, where employee body temperature and a standardized COVID-19 questionnaire was administered from their vehicles as employees arrived to work.
There is no doubt that the COVID-19 pandemic deserves the attention and resources it continues to receive in the American workplace. Numerous EHS managers who built their careers on anticipating the unexpected wonder how they failed to see this crisis coming. As businesses look for any light at the end of the tunnel, health and safety professionals vow to learn from this coronavirus experience and use its distinct lessons to prepare EHS programs for the future.
EI continues to closely monitor the ongoing COVID-19 pandemic and provide our clients and the general public with current, relevant guidance based on our experience with Occupational Health, Industrial Hygiene, Safety Compliance and Engineering services performed during the pandemic. We have documented our progress, shared our learnings, and offered our insight for managing/minimizing exposures through our blog, which launched on January 27, 2020.
Beginning this month, the Virginia Department of Housing and Community Development (DHCD) will launch a new statewide lead hazard reduction program. This $5.6 million grant award will provide lead paint remediation services to income-qualified families across the Commonwealth.
On April 10, 2020, OSHA issued a memorandum which relaxed the rules for recording cases of COVID-19 on the OSHA 300. EI first reported on this topic back on April 15, 2020. More recently, OSHA issued another memorandum intended to provide guidance for compliance officers, rescinding those earlier restrictions and returning to standard recordkeeping practices for all employers as of May 26, 2020.
In the early 1970s, OSHA was established by the Federal government to prevent work related injuries, illnesses, and fatalities. Given the comprehensive nature of OSHA compliance and the lack of familiarity by manufacturing company management with worker health and safety compliance, the demand for “in-house” medical and safety professionals grew rapidly. Between the mid-1970s and mid-1980s, the percentage of industrial operations with 250+ manufacturing employees, who had “in-house” occupational health nurse (OHN) support to assist with OSHA compliance initiatives, was high.
The COVID-19 virus has forced us to change our way of living…and working. While many employers are slowly beginning to resume business, it is not business as usual. Consider your emergency action plan (EAP) for example. While setting up barriers, teaching about social distancing and providing masks for your workers, did you remember to address, and update if necessary, your EAP?
Deep Breath: Respiratory Protection in the Growing COVID-19 Epidemic
February 13, 2020
RCRA Requirements: Does Your Facility Generate Hazardous Waste?
February 19, 2020
Minimizing Airborne Exposure to COVID-19 in Buildings
March 23, 2020
Is COVID-19 Recordable on the OSHA 300 Log?
April 15, 2020
Training Students in the Era of COVID-19
May 7, 2020