In September of 2006, OSHA announced that it would be aligning its Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). To date, 67 countries around the world have implemented some form of GHS, and many chemical manufacturers, suppliers, and end users of chemical products are anxiously awaiting its implementation in The United States. In a recent web chat, OSHA announced it has updated its timeframe to publish a final rule on GHS alignment with HCS in September 2011. However, it also stated that the proposed rule is still undergoing an internal agency review and has yet to be submitted to the Office of Management and Budget (OMB) for its usual 90-day review, so it is likely that the final rule will not be published until early 2012.
When the rule is finally published, it may include an implementation schedule that would allow up to three years or more to achieve compliance. OSHA has stated it is not changing the major components of the HCS but instead is modifying it to align with the major elements of GHS which include guidelines for hazard classifications, hazard warning statements, container labels, and safety data sheets (SDS). The immediate impact will be to chemical manufacturers and suppliers who will have to rewrite, publish, and distribute new chemical safety data sheets and also provide new labels for chemical containers.
The anticipated impacts to employers in the US will include:
- Modification of written hazard communication programs
- Modification of employee training programs to cover the new chemical classifications, labeling, and hazard warnings (pictograms)
- Obtaining new SDSs to replace existing MSDSs
- Re-labeling of in-house chemical containers with the new labels
When the final rule is published, CAPACCIO will provide a summary of its major requirements and the implementation timeline for compliance in an e-blast. A series of webinars to discuss the new rule and its impact on our clients will also quickly follow.
For more information, please contact Bob King at 508.970.0033 x113 or firstname.lastname@example.org.
On August 8, 2011, the Environmental Protection Agency (EPA) published a proposed rule that suggests changes to the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 (Tier I and Tier II) reports (40 CFR 370). The proposed regulations include additions and revisions to the Tier I and Tier II forms so the forms can be more useful to state and local agencies and better inform the public on the chemical hazards in their communities. Although the proposed regulations refer to Tier I and Tier II forms, most state and local authorities only require a Tier II form from facilities that trip reporting thresholds.
EPA proposes to add the following to Tier I and Tier II forms:
- Add entries for the facility’s identification number under EPCRA 313 (Toxic Chemical Release Inventory – Form R reporting) and Clean Air Act Risk Management Programs, if applicable.
- Add an entry for the number of occupants at the facility.
- Add entries for the facility’s parent company name, address, and phone as well as the company’s Dun and Bradstreet number.
- Add entries for name and contact information of the facility representative required under EPCRA Section 303.
- Add entries for name, title, and phone number of the person knowledgeable or responsible for completing the information on the Tier II form.
- Add an entry to indicate whether the facility is also subject to Extremely Hazardous Substance (EHS) notification requirements under EPCRA Section 302.
EPA is also proposing to revise the following existing entries currently on the Tier II form:
- Revise the current range codes for maximum and daily average amounts of hazardous chemicals to narrower codes than the existing codes to be more useful to Local Emergency Planning Committees (LEPCs) for effective emergency response planning.
- Revise the reporting of chemicals (i.e., pure chemicals versus mixtures) to make it more user friendly for state and local authorities by providing separate entries for pure chemicals and mixtures.
- Revise the form to allow for description of the types of storage and storage conditions rather than using codes.
EPA is soliciting comments on the proposed rule until October 7, 2011.
Please contact Linda Swift at 508.970.0033 ext. 119 or email@example.com with any questions you may have regarding these proposed changes to EPCRA 312 reporting.
You can now manage your energy conservation program or lower your greenhouse gas emissions by using a new international standard, ISO 50001. This new ISO Management System Standard for Energy has all of the same “plan-do-check-act” provisions of the ISO 14001 Environmental Management System.
To save on the cost required to implement and certify a new management system, some companies are choosing to instead integrate the key energy management features of the ISO 50001 standard into their existing ISO 14001 or ISO 9001 management systems. Also, if a customer is not requiring certification to this standard, companies can use the integration option to achieve certification to ISO 14001 while seeking “verification” of the use of the energy management components. It is also possible to self-certify to the ISO 50001 standard through this integration option.
Should you choose to implement or integrate the new ISO 50001 Energy Management System Standard, CAPACCIO can help you make decisions on the options you have regarding the use of this new international energy management standard and guide you through the process.
For more information, contact Wayne Bates at 508.970-0033 ext. 121 or firstname.lastname@example.org.
The Department of Homeland Security (DHS) has issued a proposed rule regulating the sale and purchase of Ammonium Nitrate. The proposed rule was published in the Federal Register on August 3, 2011 and can be found at:
There is a comment period for this proposed rule that closes December 1, 2011. The proposed regulation establishes a registration program for sale and purchase of 25 lbs or more of ammonium nitrate. Regulated entities will receive a registration number and will need to maintain transaction records and have procedures in place to promptly report theft.
Although ammonium nitrate is mostly used in the fertilizer industry, this regulation highlights a more important topic for all chemical users. With every new regulation, the ability for a company to quickly determine how much of a chemical a facility uses, stores, produces, or puts into a product is becoming more and more important. In addition to being able to track the chemicals at your facility, to be proactive, it is also important to stay abreast of new or proposed regulations. The next regulated chemical could be integral to your process and a change in the procurement, management, or use, could have major consequences for production. This topic will be addressed in more detail in our upcoming fall newsletter.
For more information, please contact Travis Wheeler at 508-970-0033 ext. 115 or at email@example.com.