Since the Environmental Protection Agency’s (EPA) Risk Management Program (RMP) rules were first promulgated, the efforts to revise, improve, or otherwise change these rules has been like a slow-motion tennis match. The latest volley was a significant forehand shot to the back corner of the opposing court.
This summer will mark 44 years I have been in the safety profession and as the end of my career quickly approaches, the question recently came up, “What lessons have been learned during a 43-year career in occupational safety and health?”
Launching a Sustainability Program at Your Facility? Engaging Employees as Sustainability Stakeholders
Engaging employee stakeholders is critical to galvanizing corporate sustainability culture and the key driver for a long-term successful sustainability program. Eliciting employees to own corporate sustainability transform them into sustainability advocates by leveraging the actions of the entire workforce, which provide them an avenue to contribute to the future well-being of the company/society and become part of the larger, global sustainability movement.
OSHA recently announced its Top 10 Violations for 2020, and all ten violations from 2019 remain on the list with subtle changes to the positions of a few safety topics.
Developing a comprehensive sustainability program from the “ground up” can be an overwhelming task, requiring long term planning and the establishment of major milestones. Why not begin with some obvious and easy wins, with an eye towards engaging employees?
If you had a release of a hazardous air pollutant, you would have to notify your authorizing environmental agency under various rules, Federal RMP (112(r)), Title V, or maybe a State Air Toxics regulation. You might even be required to notify the National Response Center (NRC). As of March 23, 2021, you can now add the Chemical Safety Board (CSB) to your “must call” list.
When President Biden set a bold goal of re-opening schools in his first 100 days in office, public health experts quickly pointed out that regular COVID testing would have to be an integral part of the plan. While a questionnaire and temperature scan may have been provided peace of mind and screened some potential cases in 2020, more stringent measures are needed for student and teacher populations. Enter Rapid Antigen Testing (RAT).
Is Your Building Prepared for Post COVID Re-Occupancy? Control Measures to Reduce Airborne Transmission in the Workplace
As we move through this global pandemic, many of the buildings that we routinely entered pre-pandemic are now partially occupied or remain vacant. Buildings such as schools, churches, restaurants, and commercial office spaces have been significantly impacted by state and local restrictions aimed at mitigating COVID-19 transmission.
During 2020, the most effective method of screening employees who were potential carriers of SARS-CoV2 was the administration of a CDC recommended questionnaire, coupled with a temperature scan from a non-contact thermometer. The COVID questionnaire was utilized to identify those workers who were experiencing COVID symptoms or those employees who had potential contact with individuals who were COVID carriers.
On January 7, 2021, the US Environmental Protection Agency (EPA) published its intent to revise the 2001 dust-lead clearance levels (DLCL) for pre-1978 constructed residences and child occupied facilities. The new change in the standards will go into effect in the first quarter of 2021. It has been over two decades since the EPA has made a revision to these standards.
As we move into 2021 and the new Biden administration, we can, as with every new administration, expect to see changes. This includes changes in the areas of workplace safety and health as well. Although still a bit early, we can make a few safe assumptions based on discussions coming out of Washington.
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.
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.
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.
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?
Training Students in the Era of COVID-19
May 7, 2020
Is COVID-19 Recordable on the OSHA 300 Log?
April 15, 2020
Minimizing Airborne Exposure to COVID-19 in Buildings
March 23, 2020
RCRA Requirements: Does Your Facility Generate Hazardous Waste?
February 19, 2020
Deep Breath: Respiratory Protection in the Growing COVID-19 Epidemic
February 13, 2020