What Confuses Everybody About Secondary Containment

September 20th, 2017

What are the specific requirements for secondary containment of oil containers at SPCC-regulated facilities?

The entire containment system, including the walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs (40 CFR 112.7(c)).

Exceptions apply to qualified oil-filled operational equipment and flowlines and intrafacility gathering lines at oil production facilities.

Here’s more on simplifying secondary containment requirements. Read the rest of this entry »

Setting environmental objectives and targets for ISO 14001 Compliance

September 20th, 2017

Setting environmental objectives and targets for ISO 14001 Compliance 

What is an Objective? What is a Target?

Environmental objectives are goals that you would like to meet in the future.
Targets are the means for providing verifiable evidence that you have actually met the objective.  For example, your environmental objective may be to reduce the generation of hazardous wastes.  Your may then set your target at 20 percent reduction within 12 months.  In the parlance of ISO 14001, objectives are “documents” whereas targets are “records.”  Documents can be modified while records cannot.  For example, you can modify your objectives, but you cannot change having missed your targets. Read the rest of this entry »

OSHA Enforcement and News

September 20th, 2017

Florida roofing company issued $1.5M in penalties after repeatedly exposing workers to fall hazards

Jacksonville, Fla., roofing company, Great White Construction Inc., has been cited and fined after OSHA inspectors observed employees – without the use of proper fall protection – removing shingles and plywood sheeting from the roof of a multi-story residential structure. Although the employees wore harnesses, they were not tied off to the rope grabs and roof anchors. Great White was cited with 14 violations and proposed penalties totaling $1,523,710. Given the employer’s extensive prior history of violations, OSHA issued 11 separate willful citations for failing to protect employees from fall hazards. The company was also cited for three repeat violations for failing to ensure employees used eye protection while operating nail guns and for ladders used to access roof sites, again exposing employees to fall hazards. OSHA has investigated the company 12 times since 2012, and issued 22 citations for similar violations. Great White is now in the agency’s Severe Violator Enforcement Program. For more information, read the news release. Read the rest of this entry »

Natural Disasters – Is Your Workplace Prepared?

September 20th, 2017

The Federal Emergency Management Agency recognizes each September as National Preparedness Month. This is the perfect time to make sure that not only your household is prepared for disaster but also that your workplace is as well.

If your organization does not have plans such as these in place already, follow these steps to begin the process of preparing your workplace for natural disasters.

Assess Your Local Hazards

In order to best prepare, evaluate your area and determine which natural disasters could pose a threat. For example, if your office is located in Wichita, Kansas, it would better serve you to prepare for tornados rather than tsunamis. Don’t exclusively assess your locality, but take your office building into account as well. You’ll need to consider which floor your office is on, exit routes, hazards within your building, and more when creating your plans. Aside from personal dangers your company could experience, identify the ways in which your business would be impacted. This is critical for the planning process to bounce back after disaster hits. Read the rest of this entry »

Fire Drills – Why, When, and How

September 20th, 2017

Preparation is the key to effective response to workplace fires. Fire drills help prepare employees to respond quickly, calmly, and safely.

Fire drills play a very important role in workplace fire safety. Although OSHA does not require fire drills, it strongly recommends them.

Fire Alarm

In its “Evacuation Plans and Procedures eTool,” OSHA says:

“It is a good idea to hold practice drills as often as necessary to keep employees prepared. Include outside resources such as fire and police departments when possible. After each drill, gather management and employees to evaluate the effectiveness of the drill. Identify the strengths and weaknesses of your plan and work to improve it.”

It’s important to note that even though OSHA doesn’t require drills, local fire codes and your insurance carrier may require you to hold periodic fire drills to ensure safe evacuation of employees. Read the rest of this entry »

Deciphering New Standards for Cut-Resistant Gloves

September 20th, 2017

In 2016, the American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) updated its voluntary standard for hand protection, ANSI/ISEA 105. The standard specifies standardized testing methods for U.S. manufacturers to use in classifying protective gloves, rating them on protective factors that include cut, abrasion, and puncture resistance; chemical permeation; and other factors like flame resistance and dexterity.

Europe also updated its voluntary standard, EN 388, in 2016. EN 388 certification is required for gloves that will be sold in Europe. The standard specifies test methods for mechanical hand protection, including abrasion, cut, puncture, and tear resistance. In addition, the updated standard includes test methods and ratings for impact resistance that are required for any gloves that are marketed as “impact resistant.” Read the rest of this entry »

Spotlight on Safety Enforcement

August 18th, 2017

OSHA isn’t publicizing its enforcement efforts as much as it did under the Obama administration, but that doesn’t mean employers aren’t being cited and fined. Today and tomorrow, we’re taking a look at 21 recent enforcement cases that all led to penalties of over $40,000.

Here are some cases in our roundup: 

Alabama—A motor vehicle parts manufacturer was cited with three repeat violations and three serious violations. The repeat violations were issued for lockout/tagout deficiencies and failing to provide injury and illness records to authorized government representatives within 4 business hours. Serious violations were issued for fall protection, machine guarding, and lockout/tagout.
Total penalty: $84,255  Read the rest of this entry »

OSHA Enforcement

August 18th, 2017

Ohio auto insulation manufacturer faces penalties following worker injury

A worker at a Toledo, Ohio, automotive parts supplier lost his hand and part of his arm in a shredding machine. OSHA’s investigation of Autoneum North America found that the company failed to equip the machine with safety guards and train workers on lockout/tagout procedures, and exposed workers to struck-by hazards from machine parts. The company was cited for three willful and two repeated violations and proposed fines of $569,463. For more information, read the news release. 

Michigan landscaping company obtains Cease Operations Order for exposing workers to hazards Read the rest of this entry »

EPA Seeks Elimination of $28 Million Monitoring Requirement

August 18th, 2017

A requirement to place wireless continuous monitors on containers at off-site waste and recovery operations (OSWROs) to detect leaks from pressure relief devices (PRDs) would be eliminated under an EPA proposal (August 7, 2017, FR).

The proposal responds to an industry petition for reconsideration of the requirement, which is included in the Agency’s 2015 residual Risk and Technology Review (RTR) of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for OSWROs. Jointly submitted by the American Chemistry Council and Eastman Chemical Company, the petition argued that the transitory nature of containers at OSWRO sites would make the installation of continuous monitoring devices technically impossible. Moreover, the petitioners said other federal regulations cover leak detection of OSWRO containers, and therefore, the RTR requirement is redundant. Read the rest of this entry »

Construction Safety – Tips for an Effective Program

August 18th, 2017

An effective construction safety program goes beyond compliance to address overall loss control, which includes employee protection, property damage, and liability claims. The National Association of Home Builders (NAHB) has created a model safety program for builders. It’s built on a solid foundation of safety principles that will resonate with safety professionals in the building industry and beyond.

Here’s what NAHB recommends: Read the rest of this entry »