Changes in Refrigerant Regulation – Are You Prepared

August 18th, 2017

The regulation of refrigeration and air-conditioning equipment is changing.  The universe of regulated refrigerants is expanding, commonly used refrigerants are being phased out, and revised refrigerant regulations are being phased in.  Is your facility prepared to cope with the changes in order to avoid penalties and enforcement actions?

The Changes

Refrigerant regulations originally addressed only ozone-depleting substances (ODSs) used as refrigerants.  However, revisions to the regulations, effective January 1, 2017, revised the definition of “refrigerant.”  The effect of this change was to extend the refrigerant regulations for ODS refrigerants to non-ozone-depleting substitute refrigerants. The change was primarily meant to address hydrofluorocarbons (HFCs), which have a very high global warming potential, but it does apply to any substitute refrigerant, other than the few that are specifically listed as exempt, and greatly expands the universe of regulated refrigerants. Read the rest of this entry »

11 Rules for Safe Handling of Hazardous Materials

August 18th, 2017

Do your employees know how to handle hazardous materials safely? Here are 11 basic rules all employees who handle hazardous materials should know and follow.

These 11 rules are presented in no particular order. They are all top priorities for chemical handlers. However, feel free to rearrange them in whatever order you think is best for your workplace, your workers, and your material hazards.

You’ll undoubtedly have other safety rules to add to the list. Better yet, present the list in a safety meeting and get employees involved in helping you add to the list. This will create a sense of ownership over your safe chemical handling rules.  Read the rest of this entry »

Updated ASTM AAI Standard Referenced by EPA

July 5th, 2017

In a direct final rule, the EPA is allowing the use of an updated nongovernmental consensus standard—American Society for Testing and Materials (ASTM) E2247-16, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property—to meet the All Appropriate Inquiries (AAI) requirement applicable to purchases of forestland and rural property. Read the rest of this entry »

Safety Leadership Tips for Frontline Supervisors

July 5th, 2017

At Safety 2017, the annual professional development conference of the American Society of Safety Engineers (ASSE), Judy L. Agnew, PhD, senior vice president of safety solutions with Aubrey Daniels International, spoke to a large room filled with safety professionals in a session titled “Setting Frontline Supervisors Up for Success in Safety.”

Referring to frontline supervisors as “the linchpins of safety,” Agnew emphasized that creating a safe workplace requires active participation at all levels of the organization. Frontline supervisors, she said, play a key role in holding together the many moving parts of a safety program, from training and hazard identification to equipment inspections and recordkeeping. Read the rest of this entry »

OSHA Wants to Scale Back Coverage of Beryllium Rules

July 5th, 2017

OSHA proposed on June 23 to exclude construction and shipbuilding from a final rule issued on January 9, 2017 reducing workers’ exposure to beryllium. The lightweight metal is used primarily in foundry and smelting, composites manufacturing, dental lab work, among other applications. Under the proposal only general industry workplaces would be subject to the January changes, which reduce exposure from 2.0 micrograms per cubic meter of air, to 0.2 micrograms over an eight-hour period. The rule was signed into law during the last days of the Obama administration. Read the rest of this entry »

Judge Rules Corps Must Revise the Dakota Pipeline EIS

July 5th, 2017

Operation of the Dakota Access Pipeline (DAPL) hit a potential roadblock when a federal district judge ruled that the Army Corps of Engineers (Corps) had approved the project without adequately considering the rights of the Sioux tribe living on the Standing Rock Reservation, which spans the North Dakota/South Dakota border near Lake Oahe. The pipeline runs under Lake Oahe but does not enter the Standing Rock Reservation. Nonetheless, in a ruling issued June 14, 2017, Judge James E. Boasberg of the U.S. District Court for the D.C. District said that the Environmental Impact Statement (EIS) the Corps issued for the project was incomplete.

“Although the Corps substantially complied with [the National Environmental Policy Act] in many areas, the Court agrees that it did not adequately consider the impacts of an oil spill on fishing rights, hunting rights, or environmental justice, or the degree to which the pipeline’s effects are likely to be highly controversial,” wrote Boasberg.” To remedy those violations, the Corps will have to reconsider those sections of its environmental analysis upon remand by the Court.” Read the rest of this entry »

HazMat Packages – When Is Secure Really Secure?

July 5th, 2017

The top hazardous materials (hazmat) transportation violation uncovered by Department of Transportation (DOT) roadside inspectors since 2013 is unsecured packages in vehicles, accounting for nearly 10% of hazmat violations. You may think your hazmat package is secure in the vehicle, but the important question is whether the DOT roadside inspector thinks so. We’ll take a look at a couple of scenarios where a roadside inspector may disagree or agree with the way you secured your hazmat.

Pallet Problems

Say you’re loading and securing a number of pallets for a hazmat shipment. You have four drums loaded on each pallet, and you have shrink-wrapped the drums to the pallet. In addition, you have placed heavy cardboard on top of each set of four drums banded to a pallet. Read the rest of this entry »

14 AGs File a Motion to Intervene in O&G Methane Case

July 5th, 2017

The case against EPA’s effort to freeze the Agency’s June 2016 New Source Performance Standards (NSPS) imposing air pollution controls the oil and natural gas (O&G) industry expanded when the attorneys general (AGs) of 14 states and the city of Chicago filed a motion to intervene on behalf of the plaintiffs, five environmental groups.

“State Intervenors have unique interests in the outcome of this case that may not be adequately represented by Petitioners, and State Intervenors are uniquely situated to explain the burdens and harms of staying the 2016 Rule on those State interests,” say the AGs in their motion. Read the rest of this entry »

What You Don’t Know About RCRA’s Waste Analysis Requirements

May 24th, 2017

“According to the EPA, a “cornerstone” of the RCRA hazardous waste program is the ability of regulated entities to properly identify which hazardous waste(s) they are generating. As a result, the EPA issued regulations that compel large quantity generators (LQGs) and small quantity generators (SQGs) of hazardous waste to develop and implement a waste analysis plan (WAP) to classify the hazardous waste and ensure that it is managed properly.”

In addition, owners and operators of RCRA-permitted transfer, storage, and disposal facilities (TSDFs) may also be required to develop and use WAPs if the generator does not provide the TSDF with a complete and up-to-date waste analysis. Read the rest of this entry »

Workplace Safety Signs and Tags Prevent Accidents – Select and Place Them With Care

May 24th, 2017

Your employees should be familiar with the hazards associated with their own work areas. But as they go about the facility, they may come into casual contact with risks they don’t know about.

Outsiders who come into your facility may also be unaware of the hazards they face. This is why safety signs and tags are so important. Another important reason is to remind workers daily of the hazards in their own work areas so that they don’t become complacent about hazards.

Yet another reason for safety signs and tags is to warn of hazards that are out of the ordinary, unexpected, or not readily apparent. Read the rest of this entry »