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.

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.

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.