Always Make Safety Your Top Priority Reply

Extra! Extra! Read All About It!

The Assault on Health and Safety Begins!

Deregulation policies a threat to worker safety!

OSHA Delays Electronic Record-Keeping Rule!

Talk of scrapping two regulations for each new one adopted!

OSHA Further Delays Silica Rule Enforcement!

Proposed $2.5B Cut to Dept. of Labor’s Budget, Elimination of Chemical Safety Board

During the past six months, there has been lots of talk (and action) in Washington about reducing and eliminating regulations, repealing OSHA rules, and imposing major staff reductions and budget cuts in agencies dedicated to increasing worker health and safety (OSHA, MSHA, NIOSH, and The Chemical Safety Board). Despite all the headlines, businesses throughout the country must continue to operate and, unfortunately, workers continue to be injured or killed on the job on a daily basis.

Although safety regulations and enforcement actions can have a positive effect on reducing worker injuries, they do not prevent them. It still remains everyone’s responsibility within the workplace to promote, create, and maintain a safe and healthy work environment despite whether or not a formal regulation is in place.  From top management down through all levels of the business hierarchy to the employees on the shop floor, safety should be everyone’s top priority.

Regulations or the threat of enforcement penalties and fines should not be the sole driving force in providing safe and healthy work environments. Many highly successful businesses foster safe working conditions and decide on their own to implement safety programs that exceed the basic requirements spelled out in safety regulations.

Bottomline –Safety should remain at the top of your priority list every day for yourself, your fellow employees, and your family and friends while you are away from the workplace.

For more information or of you require assistance with your health and safety programs, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or bking@capaccio.com.

To “Air” is Human Reply

In our continuing series about auditing and how it can be similar to an annual physical, we will discuss an often overlooked area; a deep dive into air permitting. Just as an annual physical may gloss over some of the more specific parts of the body, air permits can also sometimes be overlooked but doing so can lead to a potential problem in the long run.

Every year, the Doctor asks a list of questions, such as, “Has anything changed in your immediate family’s health (diagnosed with diabetes, heart disease, ADHD)? Who lives at your home? Do you have any pets? Do you have any concerns at the moment?  In a similar fashion, prior to an air audit, the auditor will send you a list of questions. Do you have an air plan approval?  Do you have air emissions tracking sheets?  Do you have a control device? All of these questions help the Doctor/Auditor get an overview of your health/facility and any specific areas that may be of concern.

Your responses become the roadmap for the auditor. If you stated you do not have an air plan approval, the auditor may request a listing of how much solvents are used onsite to determine if the facility needs to further evaluate/justify whether a plan approval is needed or if there is an exemption that excludes a facility from obtaining an air plan approval.  The auditor will check if you are maintaining documentation that states how you are complying with the regulation or why your facility meets the listed criteria exemption.

As with your annual checkup, the more symptoms/details you can provide to the Doctor increases their ability to provide you with advice on what you need to do to maintain a healthy lifestyle. Are there warning signs that you may not have noticed with your air permits?

  • Your volatile organic compound (VOC) emissions from a small process is approaching permitting level
  • The state updated their Regulated Toxic Air Pollutant (RTAP) list and you missed the notice
  • EPA has finalized a regulation that applies to you
  • An emergency generator was installed at your facility and was not self-certified
  • Emission statements were not submitted

These are some of the most common findings found during an air audit. What happens if you don’t see the warning signs or you ignore them for too long?  The small warning signs can compound each other to create one larger issue. Just like your health, it is good to go through the annual checkup to help catch the small warnings before it becomes a larger issue and is too late to be fixed.

Just like there are apps to track your health on your phone, computer, or other electronic device, CAPACCIO’s EHS DashboardTM can help you track your facility’s data making an audit by the state or federal inspectors that much easier. Learn more about the dashboard at www.ehsdashboard.com.

For more information on air permits or other air compliance related questions, please contact Lynn Sheridan, EIT, at 508-970-0033 ext. 122 or by cell at 774-249-2565 or email lsheridan@capaccio.com.

Climate Change and Sustainability in Massachusetts in the Current Political Climate Reply

Deregulation around climate change has had scientists, citizens, and organizations deeply unsettled in recent months. If looking from the outside in at the message being sent by the federal government, it appears that the U.S. has deprioritized sustainability and is actively revoking its support for the fight against climate change. It wouldn’t be out of place to think this, either. For example, in recent months, the U.S. has pulled out of the Paris Agreement, passed an executive order to revoke the Clean Power Plan, and most recently, the U.S. has revoked a ruling to ban hydrofluorocarbons (HFC’s) in refrigeration and air conditioning.

Regarding HFC’s…

  • On 8/8/17, a federal court ruled that HFC’s cannot be banned.
  • The reversal is due to a technicality in how the Clean Air Act is being used to support the EPA’s effort to ban HFC’s.
  • HFC’s have been and are of increased concern due to their high global warming potential, relative to CO2. In other words, for every one unit of CO2 removed from the environment, a one unit addition of HFC’s to the environment negates the CO2 removed from a global warming standpoint, and leaves the atmosphere with even more greenhouse gas (GHG).

But not so fast! There is a very different story unfolding in Massachusetts (and many other states around the U.S.).

First, for some country-wide good news related to the revoked HFC ban, despite this ruling, U.S. chemical companies are still committed to producing climate friendly HFC alternatives, per the Montreal Protocol in which approximately 150 countries vowed to phase out HFC’s beginning in 2019.

Meanwhile in Massachusetts, on August 11, 2017, Massachusetts published six final regulations to reduce GHG emissions in the Commonwealth. Granted, this was in response to a Supreme Judicial Court ruling (Kain v. DEP, May 2016), requiring the Commonwealth to “beef up” its emission reductions efforts. Enter Governor Baker’s Executive Order No. 569 – “Establishing an Integrated Climate Change Strategy for the Commonwealth” – and the resulting amendments (or new regulations) made to meet 2020 statewide emissions limits set in the Global Warming Solutions Act (GWSA). Below, those regulations are summarized, and more details can be found on the MassDEP website.

 

Regulation 310 CMR 7.72

Reducing Sulfur Hexafluoride Emissions from Gas-Insulated Switchgear (GIS)

What is it? Establishment of annually declining, mass-based limits added to existing max leak rates for SF6.
Who is affected? -Large utilities

-Federal reporting GIS owners

Why Was it implemented? Adding the mass-based limits is accounting for potential SF6 increased emissions associated with deployment of new GIS equipment – not accounted for prior to revision.

 

Regulation 310 CMR 7.73

Reducing Methane Emissions from natural Gas Distribution Mains and Services

What is it? Establishment of annually declining emission limits on Massachusetts gas operators in 2018, 2019, and 2020. This regulation establishes the annually declining limits on GHG emissions.
Who is affected? -All Massachusetts gas operators

-Gas operators with a Gas System Enhancement Plan (GSEP) order from Department of Public Utilities (DPU)

Why Was it implemented? Emissions limits were not established in the Clean Energy and Climate Plan for 2020. It simply required updates and fixes to leaks. Per the GWSA, limits needed to be imposed to ensure reductions.

 

Regulation 310 CMR 7.74

Reducing CO2 Emissions from Electricity Generating Facilities

310 CMR 7.75

Clean Energy Standard

What is it? Two regulations to reduce CO2 emissions from Power plants in Massachusetts.

7.74 sets a minimum percentage of electricity sales that utilities and competitive suppliers must procure from clean energy sources.

7.75 sets a sector-wide, annually declining limit on aggregate CO2 emissions from twenty-one large fossil fuel-fired power plants in Massachusetts.

Who is affected? -All owners and operators of an electric generating facility
Why Was it implemented? These two regulations are intended to increase procurement of clean energy (from utilities) and ensure emissions reductions associated with fossil fuel-powered power plants.

 

Regulation 310 CMR 60.05

Global Warming Solutions Act Requirements for Transportation

What is it? Establishment of annually declining aggregate targets on CO2 emissions from Massachusetts’ transportation system.
Who is affected? -MassDOT; MPO’s; RTA’s; DEP; EOEEA
Why Was it implemented? Previous regulation did not include requirements for the MassDOT to meet enforceable limits on carbon dioxide (CO2) emissions.

 

Regulation 310 CMR 60.06

CO2 Limits for State Fleet Passenger Vehicles

What is it? New regulation setting limits on CO2 from passenger vehicles owned and leased by the Commonwealth’s Executive Offices.
Who is affected? Executive Offices that own or lease 30 or more passenger vehicles, as determined by the MassDEP.
Why Was it implemented? To reduce CO2 emissions from certain Commonwealth owned or leased vehicles through imposition of mass-based limits that decline each year from 2018 through 2025.   This requires each Executive Office to monitor, record, and report CO2 emissions from vehicles.

 

Industry in Massachusetts has stayed on course in terms of preparing for and doing their part to mitigate climate change through often extensive sustainability programs. Consistent with these efforts is the message that Massachusetts continues to stay the course as well, as evidenced by these new regulations.

For more information on this topic, please contact Cristina Mendoza at 508-970-0033 ext. 128 or by cell at 774-249-2418, or email cmendoza@capaccio.com.

Management Systems Internal Audits – Going Beyond the Annual Physical Reply

EH&S Management systems standards are developed to proactively address and continually improve how to protect the environment and how to establish and maintain a safe and healthy workplace. The environmental management system, ISO 14001, and occupational health and safety management system, OHSAS 18001 – soon to be converted to the new ISO 45001, help to manage risks and take advantage of opportunities. Just as an annual EH&S audit can be related to an annual physical, internal systems audits can be related to the ongoing monitoring of your overall health. Working with a general practitioner to consistently improve a functional area of one’s health mandates a certain amount of effort. However, if this area is of highest risk to us, we will devote that time.

Commitment to internal auditing has huge potential for risk reduction and continual improvement, just as commitment to ongoing monitoring of your health. Part of this commitment is ensuring that your EH&S management system is functioning as intended to promote environmental protection and a safe and healthy workplace. Having an effective management system achieves this.

Management systems are most successful when all those affected in some capacity by the system embrace the procedures and best practices shared with them from the system – making the role of an internal auditor for management systems essential. They can act as another set of eyes to review operations and to act as the catalyst to best practices and improvement.

The internal auditor has the platform to point out an internal audit finding, such as emergency procedures not being executed as stated in documentation. They also have the responsibility to identify areas where there are opportunities for improvement, such as posting significant aspects in areas affected by those aspects to increase awareness.

In order to show continued improvement for an organization’s management system or an individual’s health, concrete evidence of steps taken to do so are very important. In a management system, objective evidence that procedures are being followed and are effective is a must-have. Internal audit findings are meant to take an organization’s EMS to the next level of best practices and demonstrate improvement of the system.

Having a management system, or working with a healthcare provider, won’t be of value if we simply carry on with business as usual. We cannot expect there to be improvements each time we have an annual appointment or audit without acting to correct or address issues identified. The value comes from embracing the guidance from the internal auditor or healthcare provider to see the most concrete improvements.

Embracing this guidance means continually improving the management system itself, and for this scenario, improving the preparation, execution, and documentation of internal audits. Managing audit documentation, corrective actions, and audit schedules in discrete, siloed, files leaves room for error and inconsistencies. Tools are now available to transform the way in which this is accomplished. A tool like the EHS-DashboardTM has the capability to schedule audits, log findings, communicate internally to address corrective actions, and store documentation, while simultaneously linking each piece together.

If you have questions about internal audits for management systems or how to implement tools to enhance your existing systems, please don’t hesitate to reach out to our experts. Linda Swift can be reached at lswift@capaccio.com or 978-621-6433 and Cristina Mendoza can be reached at cmendoza@capaccio.com or 774-249-2418.