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.

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.

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.

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.