Always Make Safety Your Top Priority Reply

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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.

New OHS Standard ISO 45001: Progress Towards Finalization Reply

Each year, nearly 2.2 million workers die as a result of an occupational injury or illness. This statistic is burdensome to organizations and society as a whole. To encourage a strong occupational health and safety program, the International Organization for Standardization (ISO) has been working on the development of a new Occupational Health and Safety (OHS) Standard; ISO 45001. This standard aims to provide organizations with the framework to manage the prevention of work related injuries, illnesses, and deaths.

ISO 45001 has been drafted to include many of the same concepts set forth in OHSAS 18001. The main differences between the two standards is that ISO 45001 has a much stronger focus on the context of an organization and requires top management to provide leadership in the development, management, and tracking of their company’s OHS Management System. It is expected that OHSAS 18001 will be withdrawn once the new ISO 45001 standard is published. Organizations certified to OHSAS 18001 will need to transition to ISO 45001 within three years of its publication.

Currently the new OHS Standard is in its second draft. A preview of this version is currently available for review.  For the next four months, the OHS Standard will be undergoing the translation and ballot phase of the review process. If a Final Draft International Standard (FDIS) is not required, the new ISO 45001 standard could be published as early as November 2017. If a FDIS is required, publication could be pushed back to the second quarter of 2018.

For more information please contact Bob King at 508-970-0033 ext. 113 or bking@capaccio.com or Katie Grasso at 508-970-0033 ext. 134 or kgrasso@capaccio.com.

Changes to EPCRA Sections 311 and 312 hazardous chemical reporting forms (Tier I and Tier II) will become effective January 1, 2018 1

Summary of Changes:
The Environmental Protection Agency (EPA) has decided to revise existing hazard categories currently used for hazardous chemical inventory reporting under EPCRA Section 311 (Tier I) and Section 312 (Tier II) to conform to the hazard classes now used in the Occupational Safety and Health Administration (OSHA) revised Hazard Communication Standard (HCS). EPA has decided to replace the existing five hazard categories:

  • Fire
  • Sudden Release of Pressure
  • Reactive
  • Immediate (Acute)
  • Delayed (Chronic)

with the specific hazard classes listed in the revised OSHA Hazard Communication Standard:

Physical Hazard Health Hazard
Flammable (gases, aerosols, liquids, or solids) Carcinogenicity
Gas under pressure Acute toxicity (any route of exposure)
Explosive Reproductive toxicity
Self-heating Skin Corrosion or Irritation
Pyrophoric (liquid or solid) Respiratory or Skin Sensitization
Pyrophoric Gas Serious eye damage or eye irritation
Corrosive to metal Specific target organ toxicity (single or repeated exposure)
Oxidizer (liquid, solid or gas) Aspiration Hazard
Organic peroxide Germ cell mutagenicity
Self-reactive Simple Asphyxiant
In contact with water emits flammable gas Hazard Not Otherwise Classified (HNOC)
Combustible Dust
Hazard Not Otherwise Classified (HNOC)

EPA will be modifying the Tier2 Submit software developed for reporting under section 312 to include the new physical and health hazards. For states that have their own reporting software for section 312, EPA is providing flexibility to allow states to modify their software by January 1, 2018. Facilities are required to comply with reporting the new physical and health hazards on their Tier II inventory form for reporting year 2017, by March 1, 2018.

Dates:

Effective Date: This final rule was effective June 13, 2016.

Compliance Date: The compliance date is January 1, 2018.

Note: These changes will not affect reporting for the current year 2016 and existing forms and software will be used for completing Tier II reports which must be completed by March 1, 2017.

For more information, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or bking@capaccio.com.

Executive Order (EO) 13650 “Improving Chemical Facility Safety and Security” New Fact Sheet Issued Reply

A new fact sheet has been issued in June 2015 by the Executive Order (EO) Working Group for EO 13650 “Improving Chemical Facility Safety and Security.” A copy of the new Fact Sheet can be found at: https://www.osha.gov/chemicalexecutiveorder/EO13650FS-ImprovingChemicalFacilitySafety.pdf .

The June 2015 Fact Sheet provides updates on actions taken since EO 13650 was issued on August 1, 2013, as a response to catastrophic chemical facility incidents in the United States. The focus of the EO is to improve chemical facility safety in coordination with owners and operators. The Chemical Facility Safety and Security Working Group (Working Group) – co-chaired by the Department of Homeland Security (DHS), Environmental Protection Agency (EPA), and Department of Labor (DOL) – leads the effort to implement the Executive Order and improve coordination and regulation of chemical facilities across the various agencies and Federal, state, local, and first responder communities.

Through the analysis of the current operating environment, existing regulatory programs and stakeholder feedback, a consolidated Federal Action Plan was created to address five elements:

  • Strengthening community planning and preparedness 
    Update: Continue enhancing programs and assistance to State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs), including development of on-line training modules and new EPA fact sheet How to Better Prepare Your Community for a Chemical Emergency: A Guide for State, Tribal, and Local Agencies 
  • Enhancing Federal operational coordination 
    Update: Established regional working groups (RWGs) in all 10 federal regions to improve coordination among DHS, EPA, and the Occupational Safety and Health Administration (OSHA) 
  • Improving data management 
    Update: The Facility Registry Service (FRS) integrates facility data from across nearly 90 different Federal and State systems, and has been updated to include DHS Top-Screen submission for Chemical Facility Anti-Terrorism Standards (CFATS), as well as OSHA data (e.g. Process Safety Management (PSM)) 
  • Modernizing policies and regulations 
    Update: EPA issued a request for information (RFI) seeking public comment on updates to the Risk Management Plan (RMP) regulation 
    Update: OSHA issued an RFI seeking public input on possible improvements to the PSM standard 
    Update: The CFATS Program has been re-authorized for four more years 
  • Incorporating stakeholder feedback and developing best practices 
    Update: Launched an online best practices repository to collect industry best practices as they are identified A webinar is available, which provides an introduction to the EO 13650, highlights federal agencies involved in the EO and the primary regulations pertaining to the EO, and discusses local government involvement, and community involvement.

    Comments from the community participants are also included. You can access the webinar through the EPA’s website: http://www2.epa.gov/rmp/executive-order-improving-chemical-facility-safety-and-security#Webinars

    What does this mean for you?
    – Make sure that the chemical data you submit under different regulatory programs is consistent, because EPA, OSHA, and DHS are improving their coordination and review of submitted data
    – Get involved with your LEPC if you store extremely hazardous substances (EHS) onsite, and ensure that your emergency action plans and contingency plans are up to date
    – If your facility is subject to EPA’s RMP program, review the requirements and check regularly for program updates: http://www2.epa.gov/rmp
    – If your facility is subject to OSHA’s PSM program, review the requirements and check regularly for updates: https://www.osha.gov/Publications/osha3132.html

    For questions about the Executive Order, please email the Executive Order Working Group (Eo.chemical@hq.dhs.gov).

    To answer any questions or for more information, please contact Chris Walton, PE, BCEE, at CAPACCIO ay 508-970-0033 ext. 139 or cwalton@capaccio.com.

    Sources:
    EPA: http://www2.epa.gov/rmp/executive-order-improving-chemical-facility-safety-and-security#eopu
    DHS: http://www.dhs.gov/topic/chemical-security
    Department of Labor/OSHA: https://www.osha.gov/chemicalexecutiveorder/index.html