Changes to the Hazardous Waste Biennial Report Reply

Large Quantity Generators are required to report hazardous waste (HW) activity by March 1st of each even numbered year (every two years) for the preceding calendar year.  Reports are to be sent to the facility’s state authority (in Massachusetts, MassDEP).

Previously, there was an independent software used to prepare these reports. This year (reports to be submitted in March 2018) HW Biennial Reports have to be prepared and submitted using the EPA RCRAInfo Industry Application (RIA) software.

Here’s what’s new:

    • The Biennial Reporting software is a part of the EPA RCRAInfo Industry Application (RIA) which is also a part of the EPA CDX system – so everyone who prepares and submits a HW biennial report needs a CDX account and to register in the RIA system.
    • MassDEP noted to be sure you understand that there are a number of roles for RIA and whoever signs up as the Site Management Role will have control not only of the HW Biennial Report roles and content but also any roles related to the eManifest (expected this summer), and Generator Notification form (expected in the near future), etc.  (Basically anyone with a waste role on CDX related to the client’s facility). So CAPACCIO is advising clients to be careful who they assign to that role.  Once roles are assigned, you need to make sure that those people have CDX accounts.  If they don’t have accounts, one of the first things you need to do is set a up CDX account and then register on RCRAInfo. 
Having trouble submitting your Hazardous Waste Biennial Report?
  • That’s because EPA has not loaded the SI form template (form with your site information) into the RCRAInfo Biennial Report site and you cannot submit the report without completing an SI form.  The form will likely be available in mid-January.
If you have questions regarding the Hazardous Waste Biennial report, contact Linda Swift at lswift@capaccio.com or Alexis Dallaportas at adallaportas@capaccio.com.

New OHS Standard ISO 45001 Update Reply

The International Organization for Standardization (ISO) has been working on the development of ISO 45001, a new standard aimed at providing organizations with an established framework for preventing ill health, preventing workplace injuries, and providing a healthy and safe workplace.

ISO 45001 is now in the final draft stage international standard (FDIS).  The ballot on the FDIS must be completed by January 25, 2018.  If it is successful, it could be published as an approved standard in March 2018. The new ISO 45001 standard will replace OHSAS 18001 as the primary standard for occupational health and safety. It is noted to be an improvement on OHSAS 18001, credited to the new standard’s risk-based approach. ISO 45001 will also align with the new ISO standards format, Annex SL, facilitating integration of ISO systems and enhancing their roles in operations and business strategy.

Organizations that are currently certified to OHSAS 18001 will need to transition to ISO 45001 within three years of its publication. Taking a systematic approach to data collection, process execution, and responsible party assignments during the transition will be key in achieving certification. Consider a data management and procedural excellence system like the EHS-DashboardTM to do so!

For answers to questions or help with the transition from OHSAS 18001 to ISO 45001, please contact Linda Swift at (508) 970-0033 x 1119, or at lswift@capaccio.com.

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.

Neglecting Your Health and Your EHS Program’s Health Can Be Hazardous Reply

Our series about auditing and how it resembles an annual physical comes to an end
with this article that discusses risk management and process safety management
(RMP and PSM) assessments. In the same way that an annual physical may alert
you of weight gain or poor nutrition, an annual assessment of your chemical
processes provides a grasp of the current state of the management of your
facility’s hazards.

An annual physical typically begins with a weigh-in. Your weight is tracked and observed by your doctor, and when unhealthy dietary choices and lack of exercise
have led you to pack on some pounds, your doctor will suggest that you modify
your food choices and increase your activity level.

Likewise, mismanaging your RMP and PSM program could lead your processes
down a slippery slope of poor condition. Does your maintenance group maintain
each part of your process in a way that prevents known hazards? Have your
operating procedures been reviewed and certified as current and accurate each
year? Is your frequency of training your employees on RMP and PSM often enough
so that employees are refreshed on the hazards of the process and can perform
their jobs in a safe manner? Answers to these questions are asked during a required
and enforceable 3-year Compliance Audit; however, wouldn’t it be a good idea to
catch these issues ahead of time by performing an annual program assessment?

These pieces to the healthy PSM and RMP puzzle need constant attention, review,
and care. Just as easily as you can get out of the exercise groove, you can also fall
off the wagon with your awareness and upkeep of your PSM and RMP processes.
An annual program assessment is non-enforceable, kept internal, and ensures
that you regularly evaluate your PSM and RMP targets for compliance, the plan
to reach those targets, program milestones achieved, the resources available
to get to the next step, and program areas in need of work.

Just like there are apps to track your food and exercise plan on your phone,
computer, or other electronic device, CAPACCIO’s EHS Dashboard can help you
track your PSM and RMP action items from an annual assessment to help you
reach your goals for a safe and healthy process.

Don’t wait for an inspection to uncover your program’s health issues; call or
email Christine Silverman 508-970-0033 x 127 or csilverman@capaccio.com
for assistance.