Outsourcing Internal Audits – does this make sense?

Many organizations are choosing to “outsource” their Internal Auditing process.

On the surface, this seems to go against the intent of the ISO standards. However, the cost of maintaining a qualified pool of internal auditors can be expensive. Also, considering the turnover  in many organizations, the effectiveness of the audits may be poor and systemic non-conformances many go undetected.

The benefits of outsourcing your internal audits include:

  • Highly qualified auditor is more likely to detect systemic non-conformances resulting in fewer non-conformances during the registration audit.
  • Provides a coaching opportunity for on site management and good preparation for registration audit.
  • Keeping internal staff focused on their core area of responsibility.
  • Can be cost effective when compared to the cost of training auditors.

Outsourcing internal audits can also be effective when upgrading your management systems to meet new requirements. So companies upgrading to IATF 16949, ISO 14001:2015 or ISO 9001:2015 may wish to outsource their internal audits to gauge their readiness for recertification to the new requirements.

Please let US know how we can help support your internal audit process.

ISO 14001 2015 Services

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ISO 14001:2015 – 9.1.2 Evaluation of compliance – anything new??

I have been asked many times recently has this requirement changed? My answer is that they haven’t changed but the “process” needs to be more clearly and completely defined.

The organization shall establish, implement and maintain the process(es) needed to evaluate fulfilment of its compliance obligations.

Step 1 – define the process. The following items need to be defined:

  • determine the frequency that compliance will be evaluated;
    • This may vary for each type of requirement – regulatory,  customer, community, etc.
      • Regulatory Audits – every 1 to 3 years
      • Customer requirements – PPAP/quality internal audits – annually
      • Other
  • evaluate compliance and take action if needed;
    • How compliance will be evaluated
    • Resources – qualifications of persons doing compliance evaluation
    • How evaluation(s) shall be documented
    • How results will be reported and corrected
  • maintain knowledge and understanding of its compliance status.
    • Reference any inspections that you may do on regular basis – safety, emergency prep, 5S, etc.
    • Reference use of preventative maintenance system to track requirements – SPCC inspections, Air Permit Equipment, Storm Water Inspections, etc.
    • Reference internal audits of work instructions – universal waste, aerosol cans, haz waste, etc.
    • Process to keep current with regulatory changes (see 6.1.3) and how these are reported to management (this should be an input to management review).

The third item is not really new but does require the process be more clearly defined.  There may be some gaps in this area in organizations that don’t do many formal inspections.

Remember it is up to the “organization” (that’s you) to define the process NOT your registration company. So if you have defined the process and implemented it, you CONFORM to the requirements. Your registration company may offer “opportunities for improvement” but these should not be non-conformance’s.

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Elementary Neutralization: Treatment Without a Permit

Treating your hazardous waste without a permit?! Is that really possible? Yes! Yes, it is. While the EPA generally prohibits you from treating hazardous waste without a permit, there are exceptions. Under certain conditions you can neutralize your corrosive hazardous waste and pipe it out as sewage rather than containerize it and freight it to an expensive treatment facility. [See 40 CFR 270.1(c)(2)(v).]

How Do I Qualify?

Hazardous wastes eligible for this exclusion can be unused products, off-spec mixes, residue from spills, cleanup or storage, or any byproduct or cogenerated materials, as long as they meet two conditions:

  1. The waste is hazardous ONLY because of the corrosivity characteristic (D002).
  2. The waste is neutralized in a tank, tank system, container, transport vehicle, or vessel as defined in 40 CFR 260.10.

What Are The Advantages?

Treating hazardous waste in an elementary neutralization unit (ENU) does NOT require a RCRA treatment permit. [40 CFR 270.2(c)(2)(v)] This is the primary advantage. Although elementary neutralization systems are usually tanks or containers, ,these units are not subject to the waste storage management standards codified in 40 CFR Parts 264 and 265. [40 CFR 264.1(c)(10), 265.1(c)(10)]

If you manage to store the hazardous waste in the elementary neutralization unit IMMEDIATELY upon generation, you do not need to count it when counting hazardous waste towards your generator status, as it is “not subject to substantive regulation.” [40 CFR 261.5(c)(2), 262.10(b)] This reduction in your facility’s hazardous waste total may class down your generator status and provide flexibility for your other hazardous wastes. Keep in mind that this hazardous waste must still be recorded and included on your Biennial Report, should you be required to file one.

What Rules Do I Still Have to Follow?

Any wastes generated from the neutralization process (precipitated solids, etc.) must be managed appropriately. If these residues exhibit any characteristic, then they are hazardous waste and must be managed accordingly. Otherwise, comply with state/local regulations for industrial wastes. [40 CFR 261.3(d)(1), 261.3(g)(2)(ii)]

Since the waste was hazardous at the initial point of generation, the land disposal restrictions (LDRs) may still apply even after neutralization. The presence of underlying hazardous constituents (UHCs) in excess of the LDR threshold may require additional treatment, either on site or at an off-site facility. Either way, there are significant recordkeeping requirements. [40 CFR 268.7, 268.9]

What Do I Do With My ENU Waste?

Once you have neutralized the waste, extracted the residuals, and treated for UHCs, you still have a large quantity of wastewater and need to dispose of it somehow. In many areas, you may be able to negotiate with the waterworks and simply pour the neutralized wastewater into a sewer. In other areas, you may have to get a wastewater discharge permit or arrange for the wastewater to be trucked or piped away.

Characterizing hazardous waste

Elementary Neutralization: A RCRA Exclusion

The ENU exclusion is distinct from other relief provided for hazardous waste treatment, such as EPA’s longstanding interpretation that a hazardous waste generator may treat-while-accumulating hazardous waste in units managed in accordance with 40 CFR 262.34.

As always, state authorities may have more specific or limited allowances for elementary neutralization. So, it is important to see how your state views elementary neutralization prior to changing your current practices.

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EPA Turns Up the Heat on Refrigerant Regulation

Refrigeration and cooling systems face expanded and tighter regulation under a final rule recently signed by EPA Administrator Gina McCarthy.  The rule revises and expands EPA’s regulations for “Ozone-Depleting Substances” (ODS), which erode the stratospheric ozone layer that protects the Earth from harmful ultraviolet radiation.

Most ODS are used as refrigerants in industrial process refrigeration (e.g., in chemical, electronics, and food manufacturing), commercial refrigeration (e.g., supermarkets, refrigerated storage, and transport), or comfort-cooling/air conditioning systems. Since the 1990s, the ODS regulations (40 CFR Part 82) have mandated various practices to minimize or prevent the release of refrigerants during operation, maintenance, and disposal of refrigerant-containing equipment, and to maximize refrigerant recapture and recycling. The regulations also require certification of technicians working with ODS systems, and subject to certain exemptions, restrict ODS sales to certified technicians.

But here’s the tricky part: not only does the recently revised rule expand and tighten these requirements for ODS, it also extends them to non-ODS refrigerants used as substitutes for ODS. This extension is based not on the protection of the ozone layer, but on preventing global warming caused by such substitutes. The extension primarily targets hydrofluorocarbons (HFCs), a family of non-ODS refrigerants that have been widely used to replace ODS but have since been found to have significant global warming potential.1

In addition to extending the ODS regulations to non-ODS refrigerants, the recent revisions also include the following:

  • Lowered thresholds for leak repair requirements: Under the existing regulations, the owner or operator of a refrigeration and air conditioning system that contains at least 50 pounds of refrigerant must repair and test the system or retire it when it is found to have leaked beyond certain annualized rates. Here are the existing and revised leak rates thresholds:
Type of equipment Under existing regulations Under revised regulations
Industrial process refrigeration 35% 30%
Commercial refrigeration 35% 20%
Comfort cooling 15% 10%
  • New requirements for leak inspections or automatic detection monitors: Cooling systems that have exceeded the leak rates specified above must now be inspected either quarterly (for industrial process refrigeration and commercial refrigeration systems with a full charge of at least 500 pounds) or annually (for such systems with a full charge of at least 50 pounds but less than 500 pounds, and for comfort cooling systems). These inspection requirements can be avoided by continuously monitoring the system with an automatic leak detector that is audited or calibrated annually.
  • Release reporting for elevated release levels: If a system with a full charge of at least 50 pounds of refrigerant has leaked 125% or more of the full charge in a calendar year, the owner or operator must submit a report to EPA. The report must describe efforts to identify the leaks and repair the equipment.
  • Recordkeeping for refrigerant recovery: Technicians must now keep a record of refrigerant recovered during disposal of refrigerant and cooling systems with a full charge of 5-50 pounds. (This closes a gap in the existing regulations, which had not required such recordkeeping for this size category.)
  • Updated and expanded certification requirements for refrigeration technicians.

The revisions also make extensive organizational and wording changes intended to improve readability.

Compliance deadlines for the various new requirements range from January 1, 2017 to January 1, 2019. In the meantime, court challenges to the rule – and particularly EPA’s authority for expanding the rule to non-ODS – seem likely.

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Arc Flash Risk Management – a very real threat to your employees

An arc flash occurs amongst the live conductors or between a conductor and the ground. The current from any of the live conductor leaves its normal directional flow, travels through air and enters another conductor or to the ground. The radiant energy released by an electric arc is capable of permanently injuring or killing a human being at distances of even up to 20 feet. The workers can be thrown against a wall due to the extreme pressure of a blast. The hospitalization records indicate that the arc flash incidents are frequent in throughout the US. A simple reason can contribute to serious arc blast incidents. The US Bureau of Labor Statistics reports of the previous 10 years reflect 2,000 fatal and more than 24,000 non-fatal electrical injuries sustained from an arc flash.

The extent of the injuries depend on

  • Distance of the worker from the hazard
  • Heat
  • Tripping time of the circuit.

The typical results of an Arc Flash are:

  • Heat from more than 35,000 degrees F temperature.
  • Flying molten metal objects can injure others present in the line of fire.
  • Burns (The ordinary clothing shall burn on to the skin of a worker).
  • Rapidly spreading fire into the building or an installation.
  • High pressures more than 2,000 lbs. per sq. inch that create a blast.
  • Higher level sound more than 140 dB, which is as loud as a gun.

Arc Flash Risk Management

People are required to carry out maintenance, diagnostics and testing works on or near energized electrical circuits. Therefore, it is important to calculate the arc flash distance for all locations where the voltages used are more than 50 volts. There are two methods used to determine the protection and Personal Protective Equipment requirements in each situation. i.e. engineering analysis and a table method.

Best Practices for Complying with NFPA 70E standards

  1. Preventive Maintenance
  2. Risk Assessment
  3. Labeling and Hazard Communication Plan
  4. Design and Method Reviews
  5. Accurate Single-Line Diagrams
  6. Short Circuit and Coordination Studies
  7. Electrical Safety Program Review/Development
  8. Arc Flash Training Program and PPE Plan Development
  9. Documentation
  10. Periodic Reviews

High level risk is associated when it comes to working on an electrical system. The electricity is an invisible energy. The incidents can be spontaneous and anyone in the vicinity could be at risk. The employers should prioritize, maintain their systems up to date and as far as possible fully de-energize the system to a zero potential during the maintenance. But if it is unavoidable and working on live system is essential, the employer is required to confirm it in advance so that the level of protection and safe system of work can be established in a proactive manner. The international organizations such as OSHA and NFPA have become increasingly proactive about providing and enforcing guidelines and standards for mitigating the risk and ensuring worker safety.

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Heat Stress – keeping your employees safe

As we transition to warmer temperatures, it’s important to revisit your workplace’s Heat Illness Prevention Program to ensure your employees are equipped to combat heat-related stress and illnesses. Heat is the number one cause of weather-related fatalities in the United States despite the fact that most heat-related deaths are preventable.

Average high temperatures have seen a steady increase across the country over the past couple of decades. The Environmental Protection Agency (EPA) anticipates that average temperatures will continue to increase, and heat waves will become more frequent and impactful. This prediction should encourage all businesses to look at how their employees are exposed to high temperatures, and what they can do to accommodate.

Businesses with employees who perform work in moderate to high temperatures or humid conditions, especially where increased heart rate and perspiration are concerned, must be given the necessary tools to recognize, understand, and prevent heat stress illnesses.

Essentially, heat stress prevention comes down to workplace design, employee training, and effective work procedures. Design and procedures will vary greatly depending on geographical location and the type of work being performed. Businesses should keep in mind that heat stress can occur regardless of the time of year, in both outdoor and indoor conditions. Required personal protective equipment (PPE) can also have a significant impact on the body’s ability to expel heat. Workers involved with hazardous waste operations or asbestos removal, for example, are often required to wear impermeable protective equipment which can trap heat close to the body. A thorough risk assessment will help businesses identify risk elements such as these.

A strong working knowledge of how the body regulates heat, and how personal factors can affect that regulation, is an extremely valuable tool in prevention. The human body needs to maintain a core temperature between 96.8 (36) and 100.4 (38) degrees Fahrenheit to function at peak performance. Weather conditions, manual labor, and personal factors can cause the core temperature to increase, which can lead to the development of a series of heat-related illnesses.

To regulate internal temperature, the body uses two basic mechanisms. The first is to increase the heart rate which assists in moving blood and heat away from vital organs to the skin. The second is perspiration, during which the body expels heat in moisture through the pores, which then evaporates and carries heat away in the process. Personal factors, such as acclimatization, caffeine and alcohol consumption, hydration replenishment, general health, age, and certain prescription medications can affect how well these mechanisms work and should be taken into consideration before performing work in high temperatures. Perspiration is the more effective of the two mechanisms, which means that proper hydration to replenish fluids lost as sweat is absolutely essential.

There are four common disorders which surface as a result of heat stress, ranging from mild discomfort to life-threatening conditions:

Heat rash is the most common ailment which occurs while working in the heat. It is also called “prickly heat.” Symptoms include red, blotchy, itchy skin, particularly in areas of the body with high perspiration, and a prickling sensation. Rashes which aren’t cleaned thoroughly and frequently may become infected. Moving to a cool environment, cleaning the affected area with cool water, and complete drying are often effective treatments.

Heat cramps occur as a result of salt being lost through perspiration. They are painful muscle spasms causing lumps in the affected muscles, usually the back, legs, and arms. The pain can be severe enough to greatly inhibit movement. Workers should cease activities to tend to cramps as soon as they feel them. Stretching and massaging the affected muscle as well as replacing salt by drinking electrolyte replacement fluids are useful techniques in tending to heat cramps.

Heat exhaustion is a dangerous result of heat stress which can lead to a heat stroke if not treated promptly with first aid. It happens when the body is so overexerted that it cannot supply blood simultaneously to vital organs and the skin for temperature regulations. Inflicted workers may experience weakness, headache, breathlessness, nausea, vomiting, faintness, or loss of consciousness. Call 911 and move workers exhibiting these symptoms to a cool place and give them water to drink. Remove any clothing that isn’t necessary and loosen other clothing. Shower or sponge them down with cool water. It will take at least 30 minutes for the body to cool down after experiencing heat exhaustion.

Heat stroke is a disorder which requires immediate medical attention, and can lead rapidly to fatality if not treated quickly. A person experiencing a heat stroke may experience confusion, hot, dry skin, high body temperatures, lack of sweating, irrational behavior, convulsions, and/or a loss of consciousness. Call 911 right away and take the victim to a cool area to immerse or shower them with cool water. Wrap them in wet sheets and fan them until you can transport them to a hospital or an ambulance arrives.

Knowledge can mean the difference between life and death during a critical victimization of heat stress. Workers should understand the nature and symptoms of heat-related illnesses both in a sense of recognizing them in themselves, and when a coworker is suffering. In many cases, a quick and efficient response can save a heat stress victim from numerous long-term effects that would have otherwise occurred had symptoms gone untreated. Proper training and a strong Heat Stress Prevention Program will help protect worker health year round.

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Webinar – Identifying Risks and Opportunities from a Life Cycle Perspective

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Aerosol Can Disposal – what is required?

During management system audits or compliance audits the management of aerosol cans is one issue that is seldom management consistently. The disposal of aerosol cans depends on the condition of the can and the hazardous waste generator status of the site.  The condition of the can can be:

  • Empty
  • Partially Empty

An empty aerosol can is one where the contends of the can have been emptied and the pressure inside the can is atmospheric.  These cans under the federal rules (check for state specific rules) can be place in the general trash or recycled.

For example, some states, such as Colorado, treat aerosol cans containing product as universal waste. In Wisconsin, there are special requirements for “empty” aerosol cans. So please check your stated specific rules.

Waste Management LampTracker(R)

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ISO 14001:2015 Tool Box

As you plan for  2017 and upgrading your EMS please see how EHS Management Strategies can help streamline your EMS………

ISO 14001:2015 Tool Box

2017 is the year to upgrade to ISO 14001:2015 – let us help!!

The International Organization for Standardization (ISO) has finalized a significant revision to the ISO 14001 standard (ISO 14001:2015) on September 14, 2015 and your existing ISO 14001:2004 certificate will expire on September 14, 2018. Don’t wait until the last minute.

Click to see more…..

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Are Universal Wastes DOT Regulated?

The answer is yes, no, and maybe.

Under the DOT regulations, hazardous wastes are regulated in all modes (ground, air, rail, vessel) of transportation.

EPA has classified specific hazardous waste as Universal Waste to streamline the process and encourage recycling of these materials (see 40 CFR 273). EPA has specifically addressed the DOT requirements for these waste at 40 CFR 273.52 as follows:

§ 273.52 – Waste management.
(a) A universal waste transporter must comply with all applicable U.S. Department of Transportation regulations in 49 CFR part 171 through 180 for transport of any universal waste that meets the definition of hazardous material in 49 CFR 171.8. For purposes of the Department of Transportation regulations, a material is considered a hazardous waste if it is subject to the Hazardous Waste Manifest Requirements of the U.S. Environmental Protection Agency specified in 40 CFR part 262. Because universal waste does not require a hazardous waste manifest, it is not considered hazardous waste under the Department of Transportation regulations.

(b) Some universal waste materials are regulated by the Department of Transportation as hazardous materials because they meet the criteria for one or more hazard classes specified in 49 CFR 173.2. As universal waste shipments do not require a manifest under 40 CFR 262, they may not be described by the DOT proper shipping name “hazardous waste, (l) or (s), n.o.s.”, nor may the hazardous material’s proper shipping name be modified by adding the word “waste”.

So it would appear that Universal Wastes would NOT be subject to DOT regulation unless the universal waste being shipped meets the definition of a DOT Hazardous Material. For example pesticides and most batteries are US DOT regulated.

For a discussion on proper shipping of various types of batteries see Battery University’s discussion and always refer back to the DOT regulations. See 49 CFR 173.159 for requirements for lead acid batteries. So it would appear that specific types of batteries do meet the definition of a DOT Hazardous Material.

Florescent bulbs are not listed as a DOT material under 49 CFR 172.101.  However, they are known to contain mercury. DOT exceptions for shipment of light bulbs containing hazardous materials can be found at 49 CFR 173.11 and this specifies:

The following light bulbs (lamps) are not subject to any other requirements of this subchapter provided they do not contain Class 7 (radioactive) material:

(a) Light bulbs that are collected directly from individuals and households when transported to a collection or recycling facility.

(b) Light bulbs each containing not more than 1 g of hazardous materials and packaged so that there is not more than 30 g of hazardous materials per package. Each light bulb must be packed in inner packaging separated by dividers, or surrounded by cushioning material to protect the light bulbs and packed into strong outer packagings meeting the requirements of § 173.24(b) of this subpart and capable of passing a 1.2 m (4 feet) drop test;

(c) Used, damaged, defective light bulbs each containing not more than 1 g of hazardous materials and packaged so that there is not more than 30 g of hazardous materials per package when transported from a collection or recycling facility. The light bulbs must be packed in strong outer packagings meeting the requirements of § 173.24(b) of this subpart and capable of passing a 1.2 m (4 feet) drop test.

(d) Light bulbs containing only gases of Division 2.2 provided they are packaged so that the projectile effects of any rupture of the bulb will be contained within the package.

[80 FR 1153, Jan. 8, 2015]

So it would appear that Universal Waste bulbs would be exempt provided they do not contain more than 1g of a hazardous material (mercury). This information can be found on an SDS sheet for your florescent bulbs.

“A typical 2006-era 4 ft (122 cm) T-12 fluorescent lamp (i.e. F34T12) contains about 5 milligrams of mercury.[5] In early 2007, the National Electrical Manufacturers Association in the US announced that “Under the voluntary commitment, effective April 15, 2007, participating manufacturers will cap the total mercury content in CFLs under 25 watts at 5 milligrams (mg) per unit. CFLs that use 25 to 40 watts of electricity will have total mercury content capped at 6 mg per unit.” –  Source Wikipedia

So at 6 mg per bulb you are clearly below the 1 g limit and you would need to package >5,000 bulbs into a single package to get close the the 30 g limits.

So the answer is yes, no, and maybe.

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ISO 45001 (Occupational Health & Safety) – Could it Lead to more Stringent Provisions Around Legal Compliance?

It was announced this summer (in June 2016) that the publication of the much-anticipated ISO 45001 Management System Standard for Occupational Safety & Health is to be delayed by at least a year. Initially, the plan had been for the standard to be available from October 2016.

However, the participating members of the ISO committee did not approve the first Draft International Standard (DIS), and according to ISO, a publication date of December 2017 is now expected.

A second draft standard is currently being worked on. The delay was caused after the first Draft International Standard received more than 3,000 comments that had to be dealt with.

A lot has been written and spoken about the new standard. The main, broad aspects of the new standard are of course:

  • Its alignment with the common ISO Management System structure – to allow better integration with, for example, ISO 14001 and 9001 (Annex SL).
  • The fact that it will replace OHSAS 18001 as the primary international standard on H&S; and
  • How it will take into account the International Labor Organization’s ILO-OSH Guidelines, various national standards and the ILO’s international labor standards and conventions

However, one of the more specific points of interest revolves around how ISO 45001 will address the issue of compliance with “legal and other requirements” under the ISO general rules.

In its Briefing note on ISO 45001, ISO identifies the following benefits (specifically related to legal compliance) that using ISO 45001 will bring to organizations:

  • Enable the establishing of operational controls to manage its OH&S risks and legal and other requirements; and, more generally
  • Improve its ability to respond to regulatory compliance issues

The current section 4.3.2 of OHSAS 18001 is entitled simply “Legal and other requirements”, whereas the proposed new Section 6.1.3 would be called “Determination of applicable legal requirements and other requirements”.

There was concern in several comments submitted to ISO that the proposed new wording would have weakened these provisions and created unnecessary ambiguity. Various organizations, such as the International Trade Union Confederation, were keen to point this out:

“We believe that the public will expect that certification to this management system means the company is respecting all applicable laws”

Given the above, it will be relevant to all those companies implementing ISO 45001 that ISO may move to remove ambiguity and look to strengthen the wording around compliance with legal requirements. It is likely to mean that the need for companies to have a robust, on-going and up-to-date legal compliance management tool (not just a “legal register”) will become even more important.

If you are interested in developing an occupational safety and health program based on the ISO 45001 standard please give us a call.

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OSHA final rule requires electronic injury and illness reporting, creates public database

OSHA has released its final rule to modernize injury data collection to better inform workers, employers, the public, and OSHA about workplace hazards. The agency said that via the final regulation, it is applying the insights of behavioral economics to improve workplace safety and prevent injuries and illnesses. The final rule, which has been in the making since November 2013, was published in the Federal Register on May 12.

Data submission and public posting. The final rule makes changes to 29 C.F.R. Parts 1904 and 1902 and requires employers in certain industries to electronically submit injury and illness data to OSHA that employers are already required to keep under existing regulations. The frequency and content of these establishment-specific submissions is set forth in the final rule; it is dependent on the size and industry of the employer. OSHA intends to post data from these submissions on a publicly accessible website, but it will not post any information that could be used to identify individual employees.

Specifically, under the new rule, all establishments with 250 or more employees in industries covered by the recordkeeping regulation must electronically submit injury and illness information from OSHA Forms 300, 300A, and 301. Establishments with 20-249 employees in certain industries must electronically submit information from OSHA Form 300A only, OSHA said in a press release explaining the final rule’s requirements.

Retaliation. In addition, the final rule amends OSHA’s recordkeeping regulation to update requirements on how employers inform their employees about reporting work-related injuries and illnesses to the employer. The rule requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation; clarifies the existing implicit requirement that an employer’s procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting; and incorporates the existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses. The rule also amends OSHA’s existing recordkeeping regulation to clarify the rights of employees and their representatives to access the injury and illness records.

Initial proposal. On November 8, 2013, OSHA issued a proposed rule that would amend its recordkeeping regulations to add requirements for electronic submission of injury and illness information that employers are already required to keep. The preamble to the proposal explained that, in line with applicable federal law, such as FOIA and specific provisions of Part 1904, OSHA intended to post the recordkeeping data it collects on its public website. However, at a public meeting in January 2014, participants raised concerns that the proposed electronic submission requirement might motivate employers to under-report injuries and illnesses. Some participants said that employers already discourage employees from reporting injuries or illnesses by disciplining or taking other adverse action against employees who file injury and illness reports.

Follow-up on adverse action concerns. In light of comments raised at the January 2014 meeting, OSHA issued a supplemental notice to the proposed rule on August 14, 2014, soliciting comments on whether to amend the Part 1904 regulations to prohibit employers from taking adverse action against employees for reporting occupational injuries and illnesses. The agency received 311 comments on the electronic submission section of the proposed rule and 142 comments on the supplemental notice to the proposed rule. OSHA addressed those comments in its final rule notice.

Studying the data. OSHA said that using data collected under the new rule, it will create the largest publicly available data set on work injuries and illnesses, enabling researchers to better study injury causation, identify new workplace safety hazards before they become widespread, and evaluate the effectiveness of injury and illness prevention activities. The agency stressed that it will remove all personally identifiable information associated with the data before making it publicly accessible.

“Since high injury rates are a sign of poor management, no employer wants to be seen publicly as operating a dangerous workplace,” observed Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Our new reporting requirements will ‘nudge’ employers to prevent worker injuries and illnesses to demonstrate to investors, job seekers, customers and the public that they operate safe and well-managed facilities. Access to injury data will also help OSHA better target our compliance assistance and enforcement resources at establishments where workers are at greatest risk, and enable ‘big data’ researchers to apply their skills to making workplaces safer.”

ohsa-snipEffective date. The new requirements are effective August 10, 2016, with phased-in data submissions beginning in 2017. OSHA noted that these requirements do not add to or change an employer’s obligation to complete and retain injury and illness records under the Recording and Reporting Occupational Injuries and Illnesses regulation.

ISO 14001:2015 ToolBox

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DOT training for CESQG Hazardous Waste Generators

CESQG hazardous waste generators generate very low quantities of hazardous waste and ship them very infrequently. They typically hire qualified waste disposal companies to transport and dispose of these materials.

The requirements for the management and disposal of hazardous waste can be found at 40CFR 260-262. The transportation of the materials is regulated by DOT under 49 CFR 170-180. CESQG’s are not required to provide any training under the EPA regulations – 40CFR 260-262 (not true for small or large quantity generators).  However, personnel responsible for the transportation of these materials do require training under the DOT regulations found at 49CFR 172 subpart H.  This training is often overlooked and missed by many CESQG’s.  See the DOT interpretation letter that describes these requirements.

Please contact us with any questions on how these regulations may apply to your operations.

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ISO 14001:2015 – Risks and Opportunities vs. Environmental Aspects

ISO 14001 has always talked about the importance of identifying, understanding, and controlling your environmental aspects for better environmental performance, but the newly released standard, ISO 14001:2015, also includes requirements for understanding and addressing your risks and opportunities related to your Environmental Management System (EMS). So, the question is, what is the difference between these two concepts and how do you use them in your EMS?

What are EMS environmental aspects?

An environmental aspect is any potential interaction that your business processes have with the environment. When these interactions happen they will have an impact on the environment, either positive or negative. Part of the requirements of ISO 14001 is to identify your environmental aspects and impacts, and determine which impacts are significant, so that you can take actions to control these significant environmental aspects. It is by controlling these environmental aspects that you can eliminate the environmental impacts they can cause; this is how you control your environmental performance in the EMS.

For example, if you have a chemical process for cleaning your parts that uses a cleaning chemical in it, you will very likely have to control the use and disposal of this chemical bath when it is depleted. For this process, you will have several environmental aspects, such as a potential spill of the chemical and the handling of toxic waste. You would control this by employing a certified waste hauler who can safely handle this chemical and dispose of it properly. Thus, you would prevent the negative environmental impact for your environmental aspects.

What are EMS risks and opportunities?

While the environmental impacts that result from your environmental aspects could be an area of risk or opportunity for your business, they are not what is referred to in the ISO 14001:2015 standard when it discusses risks & opportunities. The reason that risks and opportunities are included in the planning section of ISO 14001:2015 (section 6.1.1) is as follows:

  • Ensure that the EMS can meet the intended outcomes
  • Prevent or reduce undesired effects or potential effects from the organization
  • Continual improvement

So, you need to identify the risks and opportunities that are present for your EMS, decide which need to be addressed, and keep documentation of the risks and opportunities you will address.

As an understanding of the difference, take the example above. With the chemical used you could identify a risk that the chemical was soon to be discontinued and you would need to use a more environmentally harmful chemical in its place in the future. You could also find an opportunity to replace the harmful chemical with one that has just come onto the market and is more environmentally safe to use. While these risks and opportunities are related to your environmental aspect, they are not the risk that was directly indicated by your environmental aspect when it was identified.

So, there is a relationship between environmental aspects and risks and opportunities in the EMS, but this is not the only place to find risks and opportunities. Environmental aspects are not the only risks and opportunities that you will be able to identify for your EMS, even though they are a good place to start looking. Risks and opportunities can also arise from your legal environmental requirements (especially when they change), information from your customers or market research, benchmarking your processes against other companies for improvement, suggestions from employees, or feedback from neighbors or other external interested parties.

How you identify risks and opportunities is up to you, but it is an important activity within your EMS. Risks and opportunities can present a great list of ideas that can be used for the continual improvement of your Environmental Management System.

What do you need to do about environmental risks and opportunities?

It is important to note that there is no requirement for you to have a documented system for identifying your risks and opportunities, nor do you need to formally track what they are or how you will address them. The only requirement for documentation with respect to risks and opportunities is to “maintain documented information about the risks and opportunities that need to be addressed.” You do not necessarily need to have a method to track and monitor your risks and opportunities.

After identifying the risks and opportunities that need to be addressed, you then also need to plan to take actions to address them (section 6.1.4). This can include using them in your decision of which environmental objectives to put in place (section 6.2.1), but you are not required to have an environmental objective for every risk or opportunity identified.

The last mention of risks and opportunities is that management review (section 9.3) needs to consider the changes in your risks and opportunities during the review of the EMS sustainability, adequacy, and effectiveness.

Use risks and opportunities for your business

It is not hard to see that identifying the risks and opportunities that are applicable to your business just makes sense when you have a management system and are trying to improve. It is only by managing your risks and taking action to gain the benefit of your opportunities that your business will be able to improve how it functions; improvement is impossible if you don’t start here.

So, don’t just look at environmental risks and opportunities because you have to in order to become certified to ISO 14001:2015; do it because it makes good business sense to understand and address the risks and opportunities of your business.

For a better understanding of the ISO 14001:2015 requirements and how to address them in your company, check out our ISO 14001:2015 tool box.

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ISO 14001:2015 – Putting the changes in perspective

We are all trying to digest the new ISO 14001:2015 standard and the changes needed to our environmental management systems (EMS). ISO is definitely “nudging” companies to take a more comprehensive look at their operations including supply chain management. Here is a brief overview of the main changes.

The Five Main Changes

The standard will look and feel quite different and there are numerous changes throughout the document. However, we have used our practical knowledge of the revised standard to condense the changes into five main areas which are presented in Figure 1 and explained below:

Strategic Leadership

Your cross functional senior managers will need to promote and be accountable for the EMS and ensure it achieves its intended outcomes. Your EMS should be integrated with your other business processes and compatible with your strategy so that decisions are made with consideration for the environment at all levels. Your environmental policy requires a commitment to environmental protection not just prevention of pollution. Specific commitments to sustainability principles are also encouraged.

Strategic Context

You will be expected to demonstrate a broader understanding of the context in which you operate and ensure your EMS responds in order to meet its intended outcome. This requires an understanding of your organizations direction, culture and resources and external influences. The new standard flips the question “what’s your impact on the environment?” to also consider the impact of the environment on you (your organization), for example climate change and resource scarcity.

Interested Party Analysis and Communication

Your EMS will need to become more outward looking by understanding the needs and expectations of your interested parties or stakeholders (customers, local communities, regulators, NGOs etc). This process will identify your stakeholders’ requirements and which of these will become compliance obligations. Compliance obligations are the new legal and other requirements and include stakeholder requirements with which you are either legally bound to comply or can choose to adopt, such as a customer requirement or industry agreement. In addition to a compliance obligation register, you will also need to plan communication relevant to your obligations. Robust monitoring and measurement and internal auditing processes are required to provide reliable communication.

Risks and Opportunities

There are three principle sources of risk and opportunity: environmental aspects, compliance obligations and other issues and requirements. You are required to assess these sources for risks and opportunities that need to be addressed to ensure the success of your EMS and benefit the organization as a whole.

Life Cycle

You should determine environmental aspects at each stage of the life cycle of your product or service (acquisition of raw materials, design, production, transportation/delivery, use, end of life treatment and final disposal) and not just those relating to onsite activities. Where appropriate,environmental requirements can be included at the design stage and during procurement and information about potential significant environmental impacts can be provided during the delivery, use and end- of -life treatment of the product or service.

If you need help understanding how these changes impact your EMS you may benefit from our Making the Transition to ISO 14001:2015 training program.

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ISO 14001:2004 Internal Audit AND ISO 14001:2015 Gap Assessment

All companies that are certified to the ISO 14001:2004 standard must update their environmental management system to the new ISO 14001:2015 requirements over the next 1 to 2 years.   Many companies are also choosing to outsource their internal auditing program instead of the expense of maintaining a trained pool of auditors and pulling people away from their full-time responsibilities.

EHS-MS has developed a program where we will conduct your internal audit to the ISO 14001:2004 standard, a gap assessment to the new ISO 14001:2015, and provide couching to management throughout the process. This program will provide feedback needed to update your program to the new standard and complete a value added EMS internal audit.  We will provide the following deliverables:

  • Internal Audit Report to ISO 14001:2004 with SWOT Summary
  • ISO 14001:2015 Matrix with Identified Gaps
  • ISO 14001:2015 Upgrade Plan – detailed action plan
  • Training Certificate for EMR Documenting 4 hours of ISO 14001:2015 Implementation Training

These audits will typically take 3 to 5 audit days to complete.  The result will detect non-conformances and opportunities to improve your existing EMS, provide feedback needed to upgrade your EMS to ISO 14001:2015, and document training for your EMR in the requirements of the new standard. Win-win-win.

Please contact EHS-MS to discuss how this program can be implemented for your organization at James.Charles@ISO14001-Training.com .

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ISO 14004:2016 – Help is on the way!!

Environmental management systems — General guidelines on implementation

ISO 14004:2016 provides guidance for an organization on the establishment, implementation, maintenance and improvement of a robust, credible and reliable environmental management system. The guidance provided is intended for an organization seeking to manage its environmental responsibilities in a systematic manner that contributes to the environmental pillar of sustainability.

This International Standard helps an organization achieve the intended outcomes of its environmental management system, which provides value for the environment, the organization itself and interested parties. Consistent with the organization’s environmental policy, the intended outcomes of an environmental management system include:

  • enhancement of environmental performance;
  • fulfillment of compliance obligations;
  • achievement of environmental objectives.

The guidance in this International Standard can help an organization to enhance its environmental performance, and enables the elements of the environmental management system to be integrated into its core business process.

ISO 14004:2016 is applicable to any organization, regardless of size, type and nature, and applies to the environmental aspects of its activities, products and services that the organization determines it can either control or influence, considering a life cycle perspective.

The guidance in this International Standard can be used in whole or in part to systematically improve environmental management. It serves to provide additional explanation of the concepts and requirements.

While the guidance in this International Standard is consistent with the ISO 14001 environmental management system model, it is not intended to provide interpretations of the requirements of ISO 14001.

Contact us with any questions at James.Charles@iso14001-training.com.

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How to Better Manage Supply Chain Climate Risks

Supply chains are responsible for up to four times the greenhouse gas emissions of a company’s direct operations and yet half of major companies’ key suppliers don’t provide requested climate data to their corporate customers, according to a study produced by CDP (formerly Climate Disclosure Project) and written in partnership with BSR(If you are not familiar with CDP or BSR organizations check out their websites)

The report also gives examples of ways companies can encourage supplier performance. It says L’Oréal works with CDP to create supplier climate scorecards that can be easily understood in the purchasing department.

Additionally, Coca-Cola and Lego Group are both experimenting with incentives and training for suppliers that aim to improve climate performance. Coca-Cola, for example, encourages suppliers to implement sustainable agricultural practices, reduce material used in packaging, and reduce the carbon footprint of vending machines. Lego Group LEGO Group is hosting “innovation camps” that the report says not only identify projects to reduce CO2 emissions, they also strengthen partnerships with suppliers.

“Companies face a variety business risks as a result of climate change,” lead author and BSR associate director Marshall Chase told Environmental Leader. “Some of the most significant — such as regulatory impacts on the cost or availability of materials and energy, or business continuity of suppliers during extreme weather events — are supply chain risks. This report demonstrates that companies can work with their suppliers to understand and manage these risks.”

BSR and CDP say the study is the largest ever study of climate data from suppliers and their corporate customers. It follows COP21, at which major companies including Dell, Unilever and Walmart committed to reducing their own emissions and 195 countries reached a historic climate deal to reduce GHGs to net zero well before the end of the century.

Other findings include:

  • 72 percent say climate change presents risks that could significantly impact their business operations, revenue or expenditure.
  • 64 percent of suppliers specifically identify climate regulation as a risk, with the most commonly cited consequences being fuel, energy and carbon taxes.
  • Despite the high perception of climate related risk, less than half (45 percent) of the participating suppliers have set a target to reduce their emissions and only 34 percent have lowered their GHGs in the past reporting year.

Benefits of Disclosure

Some 75 multinationals work with CDP to seek data from 7,879 key suppliers on their carbon emissions and climate risk strategies. According to the new report, companies received information from 4,005 suppliers — meaning 49 percent failed to fulfill their customers’ requests.

“It makes perfect sense for suppliers and their customers to work together to overcome the shared challenges of climate change,” report author Dexter Galvin, head of CDP’s supply chain program, told Environmental Leader. “Building climate resilience elicits co-benefits.

“In the space of just one year, 3.5 million tons of carbon savings have been achieved expressly by the purchasers that use CDP to create sustainable supply chains engaging with their suppliers. Now we are seeing a greater appetite for collaboration both up and down stream.”

Companies that work with CDP are better able to manage risk — and see financial benefits from climate performance disclosure. Around three quarters of the 1,850 repeat participants in CDP’s supply chain program have climate risk management procedures in place and are actively reducing emissions, compared to fewer than half the 1,258 first time disclosers.

“Suppliers that took part in our program for the first time last year averaged $900,000 of savings as a result of each initiative to reduce emissions,” Galvin says. “That number jumps to $1.5 million when suppliers have been disclosing through CDP for three years plus. The sheer volume of identified opportunities and the scale of potential efficiencies is an attractive proposition for the bottom line of both suppliers and customers, with the double win of lowering greenhouse gas emissions.”

How to Improve Suppliers’ Performance

The report identifies ways purchasing organizations can improve the climate performance and risk management of suppliers. It says collecting, tracking, and sharing climate performance data should play a major part in supplier plans. But the organizations’ research found that firms’ perceived climate-change risk doesn’t always match up with the reality, so companies should look at how they evaluate climate risks. Finally climate management initiatives — such as buyer incentives and targets for climate change management and GHG reduction targets — should be an integral part of a broader operational strategy.

Based on its supply chain work with global companies, BSR has developed a three-step framework (see image) to build climate-resilient supply chains.

  • Step 1: Identify supply chain priorities. This includes areas of a supply chain with high GHG emissions and high climate vulnerability. It says purchasers should pay special attention to non-reporters and first-time reporters, as well as suppliers with little or no management in place.
  • Step 2: Take action and develop targets. BSR says procurement actions may include requests for information and buyer financial incentives, among others.
  • Step 3: Is to evaluate impact, which helps companies understand how different actions help (or don’t help) them achieve GHG or other climate-related targets.

Any steps a company starts to take along these paths is the begining of a sustainability program.  Please contact EHS Management Strategies if you would like help getting started..

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Testing Emergency Response Procedures – what is required?

Many clients struggle with knowing when and how to “test” emergency response procedures. ISO 14001:2015 element 8.2(d) (previously 4.4.7) requires organizations to “periodically test the planned response actions, where practicable…..”.  The word periodically should not be interpreted as “whenever we feel like it” but means to be completed over a specified period of time.

Emergency preparedness can be broken down into three (3) distinct phases – planning phase, training phase and testing phase.  The planning phase is where we identify potential emergencies that can impact the environment and develop “planned response actions” or procedures.  Procedures identify responsibilities, available resources, and planned activities.  Typical emergencies may include chemical spills, fire, equipment malfunction, or power outages.

The training phase is where we communicate to personnel their responsibilities should the event occur and an orientation to the available resources – spill kits, alarms, etc. This training should also be completed on a routine basis and records of training maintained.

The “testing” phase is where things become a bit ambiguous. The goal of testing emergency procedures is to determine the EFFECTIVENESS of the planning and training phases and to determine if personnel with respond appropriately. To the extent possible, the testing should be independent of planning and training. Each type of procedure should be tested.  So simply doing an evacuation drill does not satisfy this requirement.

Methods of testing spill response procedures can vary greatly and the method selected should be in proportion to the spill risk at the facility. A facility whose largest likely spill is 55 gallons of oil may test their procedures differently than a site with 10,000-gallon isocyanate tanks or 50,000 pounds of ammonia.

Low risk sites may do something as simple as random interviews with employees and spill responders to determine their awareness of procedures and responsibilities.  Or impromptu deployment of spill responders to a likely spill location and reviewing a spill scenario with the team. Each year a different scenario could be reviewed. If you are relying on an outside response contractor you should contact them on a regular basis to verify that they would indeed respond to an emergency at your facility.

At higher risk sites with trained HAZWOPER trained spill teams more complex full deployment drills mat be warranted.  These types of drills may be done as part of your annual 8-hour refresher training and may include dawning PPE, spill cleanup, and decontamination.

These tests need to be documented.  The documentation should describe the spill scenario reviewed, team members present, the teams approach and performance cleaning up the spill, and any changes needed to emergency response procedures or equipment. Common findings are the evacuation alarms cannot be heard in all areas of the plant or the spill response materials are not maintained.

In addition to testing regular inspections of response equipment is needed to insure readiness.  This can include spill kits, personal protective equipment, shut off valve, drain covers, and alarms.

The overall goal is that in the event of an emergency the safety of personnel is protected and environmental impact are minimized.  Well-developed emergency preparedness can insure that both of these goals are achieved.

written by:
James Charles, PE
Senior ISO Consultant
James.Charles@ISO 14001-Training.com
(616) 666-5490

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Top Five OSHA Changes to Watch for in 2016

The last year of President Obama’s administration is fast approaching and 2016 looks to be a busy time for the Occupational Safety and Health Administration (OSHA), as it attempts to finalize significant rulemakings and guidance documents.

Here are the top five OSHA changes to look out for in 2016.

OSHA Penalties Are Going Up

After years of lobbying from OSHA to increase the penalty amounts, Congress passed the Bipartisan Budget Act of 2015, which President Obama signed into law on Nov. 2, 2015. Section 701, “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” requires OSHA to increase its civil penalties for the first time since 1990. Under the act, a one-time “Catch Up Adjustment” will occur in 2016 and yearly increases based on the Consumer Price Index will occur each year after that. To effectuate these changes, OSHA will adjust the civil monetary penalties through an interim final rule next year. The increased penalty adjustment must come into effect by Aug. 1, 2016.

It is expected that after the interim final rule is put into place that the ceiling for a serious or other-than-serious citation will jump from $7,000 to around $12,000. A willful or repeat citation could rise as high as approximately $127,000 from the current $70,000. With increased penalty amounts comes increased financial risk and liability for each OSHA violation found. Now is a good time to review safety policies and focus on retraining employees on the rules and requirements in place for working safely.

Silica Rule Is Expected February 2016

In its fall regulatory agenda, OSHA indicated that the Final Rule for the Occupational Exposure to Crystalline Silica is expected to be published in February 2016. It is not clear what the final rule will look like but it is expected to follow closely the proposal in these key areas:

  • Exposure Monitoring and Assessment. Provide exposure monitoring of employees who are or may reasonably be expected to be exposed to respirable crystalline silica at or above the Action Level of 25µg/m³ every six months if the initial monitoring indicates that employee exposures are at or above the Action Level and every three months if the initial monitoring indicates that employee exposures are above the PEL.
  • Regulated Areas or Access Control Plan. Establish and implement either a regulated area or an access control plan whenever an employee’s exposure to respirable crystalline silica is, or can reasonably be expected to be, in excess of the PEL.
  • Engineering and Administrative Controls. Establish and implement engineering and administrative controls, such as local exhaust ventilation and wet cutting whenever feasible, for reducing exposures to crystalline silica before implementing respiratory protection.
  • Protective Work Clothing and Respiratory Protection. Provide appropriate protective clothing such as coveralls or similar full-bodied clothing or a means to remove excessive silica dust from contaminated clothing if there is a potential for employees’ work clothing to become grossly contaminated with crystalline silica. Provide respiratory protection when employees may be exposed to silica about the PEL or during periods when the employee is in a regulated area.
  • Medical Surveillance. Provide medical surveillance at no cost for each employee who will be occupationally exposed to respirable crystalline silica above the PEL for 30 or more days per year. Medical surveillance includes a medical examination within 30 days after initial assignment and periodic medical examinations at least every three years or more.
  • Hazard Communication and Training. Communicate and train employees on the hazards associated with crystalline silica under the Hazard Communication Standard, 29 C.F.R. § 1910.1200, and ensure that each employee has access to labels on containers of crystalline silica and safety data sheets.

The silica rule will likely be enforceable within 90 to 180 days after it becomes final. Employers are encouraged to start planning now for the possible changes that could occur–especially for the exposure monitoring, engineering and administrative controls, and medical surveillance components–which will likely require working with third parties and spending significant resources to fully effectuate.

Recordkeeping and Disincentive Policies Final Rule Expected March 2016

The Agency’s “Improve Tracking of Workplace Injuries and Illnesses” rule is expected to be final in March 2016. These regulations are anticipated to add new electronic reporting obligations to most employers that are required to keep OSHA 300 Logs and, as with the silica rule, it is expected that the final rule will track the proposed rule closely. In particular, OSHA will require employers with more than 250 employees (per establishment) to submit their OSHA 300 Logs to the agency on a quarterly basis. In addition, employers with 20 employees or more at any time in the previous calendar year (per establishment) will be required to electronically submit to OSHA on a yearly basis the information provided on OSHA Form 300A. OSHA would, in turn, post the OSHA 300 Logs and 300A Forms on its website and make the information publicly available to anyone who would like to review them.

OSHA believes that publicly posting such information will essentially shame employers into implementing safer work practices and give the public and employees information on the safety of a business.

In addition to electronic recordkeeping, the agency also may make certain safety incentive programs illegal and subject to OSHA citations irrespective of any recordkeeping or safety violations, if those programs are deemed to “discourage” employee reporting of injuries and illnesses. While it is unclear exactly what the regulatory language will look like, OSHA asked several questions about certain practices that could discourage employees from reporting injuries and illnesses in the proposed rule. These examples may give employers a clue as to the types of safety incentive programs that OSHA may ban:

  • making employees who report an injury or illness wear fluorescent vests;
  • disqualifying employees who report two injuries or illnesses from their current job;
  • requiring an employee who reports an injury to undergo drug testing where there was no reason to suspect drug use;
  • automatically disciplining employees who seek medical attention; and
  • enrolling employees who report an injury in an “Accident Repeater Program” that includes mandatory counseling on workplace safety and progressively more serious sanctions for additional reports.

Employers are encouraged to review their safety incentive programs to assess whether they could possibly discourage employee reporting of injuries and illnesses and consider making changes if any of the examples mentioned by OSHA are a part of their program. In lieu of these items, consider implementing OSHA-approved incentive programs that promote worker participation in safety-related activities, such as identifying hazards or participating in investigations of injuries, incidents or near misses; providing t-shirts to workers serving on safety and health committees; offering modest rewards for suggesting ways to strengthen safety and health; or throwing a recognition party at the successful completion of company-wide safety and health training.

Updated Safety and Health Program Management Guidelines Will Be Issued

OSHA is seeking public comment on its updated voluntary Safety and Health Program Management Guidelines (OSHA-2015-0018). The guidelines have been updated to reflect modern technology and practices, as well as incorporate approaches taken in two OSHA programs: the Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP). Comments must be received by Feb. 15, 2016.

OSHA considers the guidelines to be a proactive approach to safety, with a focus on finding and fixing hazards before they can cause injury or illness. The guidelines are divided into seven, color-code “core elements” that, in OSHA’s view, every good safety program should incorporate. Each core element contains action items and ways to accomplish the following.

  • Management Leadership. Top management demonstrates its commitment to continuous improvement in safety and health, and communicates that commitment to workers and sets program expectations and responsibilities.
  • Worker Participation. Workers are involved in all aspects of the safety and health program, including identifying and reporting hazards, participating in investigation incidents and tracking progress on program implementation.
  • Hazard Identification and Assessment. Procedures are put in place to continually identify workplace hazards and evaluate risks through initial and periodic assessments and inspections.
  • Hazard Prevention and Control. Processes are developed that ensures controls are implemented, the effectiveness of those controls is verified and progress on controlling hazards is tracked.
  • Education and Training. All workers, including temporary workers, are trained on how to carry out the responsibilities assigned to them under the program, recognize hazards and implement control measures.
  • Program Evaluation and Improvement. Processes are established to monitor program performance and identify deficiencies and opportunities for improvement, and take actions necessary to improve the program.
  • Coordination and Communication on Multi-Employer Worksites. Host employer and all contract workers coordinate on work planning and scheduling and are informed about hazards that are present at the worksite or created by the work.

In addition to a discussion of the program elements, the voluntary guidelines provide two appendices that employers might find helpful. Appendix A offers Implementation Tools and Resources which, when viewed online, contain links to various training tools and related OSHA materials and Appendix B, entitled “Relationship of Guidelines to Existing OSHA Standards,” contains color-coded tables detailing the existing standards with their connection to the seven core elements.

While these are voluntary guidelines, OSHA frequently requires that employers implement these guidelines as part of settlement of citations. Thus, employers should become familiar with them and consider whether there are elements that can be implemented to improve safety and health and provide comment.

On the Horizon

On Nov. 20, 2015, the fall semi-annual regulatory agenda for all federal agencies was published in the Federal Register. The regulatory agenda for OSHA includes 31 regulatory actions at various stages of the rulemaking process. These regulatory agenda items could impact the construction industry:

  • Preventing Back-Over Injuries and Fatalities. Anticipated that OSHA will propose a rule on preventing back-over injuries and the hazards and risks of reinforcing concrete operations in construction.
  • Chemical Management and Permissible Exposure Limits (PELs). Anticipated that OSHA will propose a rule on approaches it may take to reduce the PELs or implement new PELs for chemicals developed since the last updates that help it keep up with modern technology and scientific advancements in chemical production.
  • Updating OSHA Standards Based on National Consensus Standards Eye and Face Protection. Anticipated that OSHA will propose a rule that incorporates the 2010 edition of the American National Standard, Z87.1 Eye and Face Protection, for construction.
  • Quantitative Fit Testing Protocol: Amendment to the Final Rule on Respiratory Protection. Anticipated that OSHA will propose a rule that will consider three new quantitative fit test protocols for selecting appropriate respirators.
  • Amendments to the Cranes and Derricks in Construction Standard. Anticipated that OSHA will propose a rule that makes corrections and amendments to the final standard for cranes and derricks published in August 2010.

Keep an eye out for these and other regulatory changes, as well as new guidance documents as OSHA officials attempt to make the most out of the Obama administration’s final year in office. The next year could set the stage for many years to come..

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SWPPP Annual Report Submittal – Michigan

Michigan – All facilities with industrial storm water permit coverage except for those covered by general permit MIS110000 must submit their SWPPP Annual Report by January 10, 2016.  This must be submitted through the new MiWaters website..

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Management Responsibilities – ISO 14001:2015

So the new ISO 14001:2015 standard has been published has anything changed? The short answer is yes!!

One of the most significant changes is in the expectations of the overall management team of any organization. Their is no longer a requirement to designate a Management Representative to lead and implement the EMS but there are specific expectations for the the management team as a whole.

Element 5.0 Leadership defines the requirements for management to provide Leadership and commitment (Section 5.1), support the Environmental Policy Management (5.2), and to define the Organizational roles, responsibilities and authorities (5.3). While the requirements of these sections were inferred in the ISO 14001:2004 standard they are requirements under ISO 14001:2015.

Element 5.1 Leadership and commitment requires that Top Management shall demonstrate leadership and commitment with respect to the environmental
management system by:

a) taking accountability for the effectiveness of the environmental management system;
b) ensuring that the environmental policy and environmental objectives are established and are compatible with the strategic direction and the context of the organization;
c) ensuring the integration of the environmental management system requirements into the organization’s business processes;
d) ensuring that the resources needed for the environmental management system are available;
e) communicating the importance of effective environmental management and of conforming to the environmental management system requirements;
f ) ensuring that the environmental management system achieves its intended outcomes;
g) directing and supporting persons to contribute to the effectiveness of the environmental management system;
h) promoting continual improvement;
i) supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.

As your site upgrades your certification to ISO 14001:2015 your registration company will look for evidence of how you meet the above requirements.

So the Purchasing Manager, Quality Manager, Production Manager, Maintenance Manager,Engineering Manager will need a clear understanding of how their activities and responsibilities support the environmental policy, how they can impact the environmental objectives (intended outcomes), and a detailed understanding of the EMS program.

For many organizations this will require an enhanced level of awareness of the EMS program by top management and a better understanding of how their departments activities impact the EMS.

To help management teams understand these requirements, EHS Management Strategies has developed a 2-hour management overview training program. Please contact us to see how we can help you through the process to upgrade your EMS to the new requirements.  Contact Us.

 

 

 

 

 


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Spill Response – Training and Drills

We all think that giving someone a spill kit and expecting them to clean-up a low hazards oil spill is no big deal.  Many will use a simple PowerPoint presentation to demonstrate these techniques.

Attached is a video demonstration on the proper use of absorbent mats and socks. The video is a nice overview you can share with your spill responders.

Your ISO 14001 programs require “periodic” testing of spill response procedures.  Please contact us with questions on how to setup Moc or desk top spill drills.

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Context of the Organization – ISO 9001 / ISO 14001

Definition

The definition of Context of the Organization is “business environment“, “combination of internal and external factors and conditions that can have an effect on an organization’s  approach to its products, services  and investments and interested Parties“. The note states that this concept of Context of Organization is equally applicable to Not for profit organization, public service organization and governmental organization.Also in normal language this concept is also know as business environment, organizational environment or ecosystem of an organization.

Introduction:

The implementation of QMS  should be the strategic decision of the organization and is influenced by the context of the organization and the changes in that context. The changes in the context can be with respect to its specific objectives, the risks associated with its context and objectives, the needs and expectations of its customers and other relevant interested parties, the products and services it provides, the complexity of processes it employs and their interactions, the competence of persons within or working on behalf of the organization and  its size and organizational structure. The context of an organization will  include  internal factors such as organizational culture, and external factors such as the socio-economic conditions under which it operates. The scope of ISO DIS 9001:2015 states that organization needs to demonstrate its ability to consistently provide products and services that meet customer and applicable statutory and regulatory requirements and aims to enhance customer satisfaction.

Any interested party which is not relevant to the quality management system need not be considered and similarly any requirement of the interested party need not be considered. Determining what is relevant or not relevant is dependent on whether or not it has an impact on the organization’s ability to consistently provide products and services that meet customer and applicable statutory and regulatory requirements or the organization’s aim to enhance customer satisfaction. The organization can decide to determine additional needs and expectations that will meet its quality objectives. However, it is at the organization’s discretion whether or not to accept additional requirements to satisfy interested parties beyond what is required by this  Standard.

Clause 4 Context of the organization 

This clauses require the organization to determine the issues and requirements that can impact on the planning of the quality management system.Interested parties cannot go beyond the scope of ISO 9001.There is no requirement to go beyond interested parties that are relevant to the quality management system.Consider impact on the organization’s ability to consistently provide products and services that meet customer and applicable statutory and regulatory requirements or the organization’s aim to enhance customer satisfaction.Organizations can go beyond the minimum requirements to determine additional needs and expectations for interested parties that would not be “relevant” at the discretion of organization and should be clear in quality management system.

Clause 4.1 Understanding the Organization and its context

The organization should determine external and internal issues for the organization relevant to its purpose, strategic planning and which affect the organization’s ability to achieve its objectives . The Organization should monitor and review the information about external and internal issues. Management Review required the monitoring of external and internal issues. The organization must consider issues related to values,
culture knowledge and performance of the organization for understanding of internal issues. The organization must consider issues related to arising from legal, technological, competitive, market, cultural, social, and economic environments, whether international, national, regional or local for understanding of external context.

Clause 4.2 Understanding the needs and expectations of interested parties

The organization shall determine relevant interested parties and requirements of relevant interested parties. Interested parties include  Customers, Partners,Persons in the organization, External providers. Relevant interested parties to be considered are those that potentially could impact the organization’s ability to provide products and services that meet requirements. Monitor and review information related to interested parties and relevant requirements.Management Review requires the monitoring of relevant interested parties.

Clause 4.3 Determining the scope of the quality management system

The organization must establish scope of the quality management system by determining the the boundaries and applicability of the quality management system. While determining the scope the organization must consider the internal and external issues determined in 4.1.,the requirements of relevant interested parties in 4.2. and the products and services of the organization. Requirements that can be applied by the organization shall be applied. Requirements that cannot be applied cannot affect the organization’s ability to provide product and services that meet requirements. The organization must maintain scope as documented information. stating the Products and services covered by the QMS and any Justification where a requirement cannot be applied.

Clause 4.4 Quality management system and its processes

The organization must establish,implement, maintain and continually improve  its quality management system as per the requirement of  this standards by determining the process needed and its application through out the organization . While determining the processes, the organization must determine the inputs required and the outputs expected from these processes, the sequence and interaction of these processes,The organization must control these processes to ensure its effective operation. The organization must establish the criteria and methods which may include measurements and other  related performance indicators to control these processes. The organization must ensure the availability of the resources needed for effective operation of these processes.The personnel having authorities and responsibilities for these processes must be identified. The organization must analysis these organization for risk and analysis and must take appropriate action to address them. There must be methods for monitoring, measuring, as appropriate, and evaluation of these processes. The organization must make changes in its process if it fails to achieve result. The organization must look opportunities for improve for these process and for Quality management system as a whole. The organization shall maintain documented information to the extent necessary to support the operation of processes and retain documented information to the extent necessary to have confidence that the processes are being carried out as planned.

Understanding context

An organization’s context involves its “operating environment.” The context must be determined both within the organization and external to the organization. It is important to understand the unique context of an organization before starting the strategic planning.To establish the context means to define the external and internal factors that the organizations must consider when they manage risks. An organization’s external context includes its outside stakeholders, its local operating environment, as well as any external factors that influence the selection of its objectives (goals and targets) or its ability to meet its goals. An organization’s internal context includes its interested parties, its approach to governance, its contractual relationships with its customers, and its capabilities and culture.An organization’s internal context is the internal environment within which the organization seeks to achieve its sustainability goals. The internal context may include,

  • Product and service offerings
  • Governance, organizational structure, roles, and accountability
  • Regulatory requirements
  • Policies and goals, and the strategies that are in place to achieve them,
  • Assets (e.g., facilities, property, equipment and technology)
  • Capabilities, understood in terms of resources and knowledge (e.g., capital, time, people, processes, systems, and technologies)
  • Information systems, information flows, and decision-making processes (both formal and informal)
  • Relationships of the staff/volunteers/members and the perceptions and values of their internal stakeholders including suppliers and partners
  • Organization’s culture
  • Standards, guidelines, and models adopted by the organization and
  • Form and extent of the organization’s contractual relationships.

Internal context can also be defined as anything within the organization that may influence the way in  which the organization manages its internal risks.Once the  internal context is understood, one can conduct the macro-environmental external analysis using “PEST” (political, economic, social and technological) analysis.This  analysis determines which factors are can influence how the organization operates. The organization cannot control these factors, but they must seek to adapt to them. The PEST factors can be classified as opportunities and threats in a SWOT (strengths, weaknesses, opportunities and threats) analysis. Alternatively, some organizations might use Porter’s “Five Forces Model.” These methods are used to review a strategy or position or direction of an organization. Completing a pest analysis is simple and helps the individuals involved in the organization to understand and find ways to deal with the context.

 Political Factors  Economic Factors
 Ecological/Environmental Issues  National economies and trends
 Current legislation  General taxation issues
 Anticipated future legislation Taxation to activities, products, services
 International legislation (global influences)  Seasonality or other weather issues
 Regulatory bodies and processes  Market and trade cycles
Government policies, terms and change  Specific sector factors
 Funding, grants, and initiatives  Customer/end-user drivers
 Market lobbying groups  Interest and exchange rates
 Wars and conflicts  International trade and monetary issues
 Social Factors  Technology Factors
 Lifestyle trends  Competing technology development
 Demographics Associated/Dependent technologies
 Consumer attitudes and opinions  Replacement technology/Solutions
 Media views  Maturity of Technology
 Law changes affecting social behaviors  Information and communications
 Image of the organization  Consumer buying mechanisms
 Consumer buying patterns  Technology legislation
 Fashion and role models  Innovation potential
 Major events and influences  Technology access, licensing, patents
 Buying access and trends  Intellectual property issues
 Ethnic/Religious factors  Global communication
 Advertising and publicity  Social media use
 Ethical issues Maturity of  organization’s products/services

Although organizations cannot control macro-environment factors they need to manage them to their advantage. They also need to protect themselves from PEST factors which may increase operational costs or affect their reputation. The external context’s micro-environment consists of the organization’s immediate operations and how they affect its performance and decision-making. These factors have a direct impact on the success of the organization. It is important to conduct a full analysis of the micro-environment before moving to strategy development. Here are some of the micro-environmental context factors.

  • Customers:
    Organizations must attract and retain customers by offering products services that meet their needs along with providing excellent customer service
  • Employees:
    There must be availability of people with the motivation to remain as contributing members of the organization and develop the skills necessary to provide a competitive edge
  • Suppliers:
    Suppliers provide organizations with the resources they need to carry out their activities. If a supplier provides bad service, this affects the way the organization operates. Close supplier relationships are an effective way to remain competitive and secure the resources needed
  • Investors:
    All organizations require investment to grow. They may borrow the money from a bank or have people invest in their work. Relationships with investors need to be managed carefully as problems can detrimentally affect the long term success of the organization
  • Media:
    Positive media attention can bring success to the organization by maintaining its reputational strength. Managing the media (including the presence in social media) is a challenge.
  • Competitors:Members of the organization need to have a sense of belonging. Can the organization offer benefits that are better than those offered by the competitors? Is there a strong value proposition? Competitor analysis and monitoring is crucial if an organization is to maintain or improve its position in the competitive landscape of the community. The organization must always be aware of its competitor’s activities. The landscape can change quickly.

As in the case of the macro-environmental context, the organization cannot always control its micro-environment factors. But they must be carefully managed together and with the internal context understanding..

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ISO 14001:2015 – New ISO Standard is here!!!

It’s here – the new ISO 14001:2015.

You can purchase the new standard at the following sites:

ISO is giving sites up to 3 years to upgrade to the new standard.  You individual registration company will develop their own procedure to upgrade your certification.

EHS Management Strategies is already helping clients to upgrade their EMS documentation to meet these new requirements.  We are also offering a one-day implementation course that comes complete with electronic templates (see Making the Transition to ISO 14001:2015).

Please CONTACT us if we can help your facility get ready to upgrade to ISO 14001:2015..

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Tesla Powerwall Will Change Electricity Business

This is what vision looks like. Watch Elon Musk announce Tesla Powerwall, the next phase in his plan to change the electricity business, from one were we mostly harvest old sunlight in the form of dead plants and animals by lighting them on fire, to one where we harvest sunlight as it comes. As he explains, this is a possible future, a preferred future, and in fact a probable future.
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Can Our Supply Chain Affect Our Environmental Impact – Conflict Minerals

Of course they do!! Recent regulatory changes in the U.S. regarding supply chain management, namely Conflict Mineral reporting, have highlighted how your suppliers are one of the most important elements of your sustainability program. Sustainability officers are paying particular attention to how proper data collection practices throughout the supply chain can be used not only for assessing minerals, but for so much more, which we’ll get to in a bit…

Conflict Minerals are defined by the Securities and Exchange Commission (SEC) as all cassiterite, columbite-tantalite (also known as coltan), gold, wolframite, their derivatives, or any other mineral and/or derivative determined by the Secretary of State to be financing conflict in Covered Countries.

Essentially, the use of these minerals, when sourced from “Covered Countries” – famously, the Democratic Republic of Congo (DRC) and other unstable African countries – is a peak concern because their use could directly or indirectly support human right violations and finance violent military actions. Having this type of supplier in your supply chain, no matter how many tiers separate you, is the antithesis of being a sustainable manufacturer.

However, not all gold, wolframite, cassiterite, or columbite-tantalite can be classified as a Conflict Mineral. In fact, many companies ethically source these minerals and avoid the complications of Conflict Minerals by doing due diligence on their supply chains and finding vendors that do not extract these minerals from the DRC. The SEC also classifies any of these minerals that are collected from scrap or recycled sources to be non-conflict, since at that point in the supply chain their sale or use is unlikely to financially contribute to an armed conflict.

In addition, the SEC considers any instance of these minerals, that has been smelted or refined and kept outside any Covered Country, to be “outside the supply chain.” In this state they are unlikely to have financially contributed to any human right violations.

Recently we wrote about how supply chain assessments and proactive management of your suppliers is the most effective way of managing your overall sustainability. What this requires is working closely with your vendors, and actively choosing to work with those that also do their own due diligence with their own suppliers. In regards to Conflict Minerals, you should seek out suppliers that are able to confidently inform you if they use conflict-free minerals.

However, Conflict Minerals are just the tip of the iceberg when it comes to your sustainability tracking throughout your supply chain. (see new ISO 14001:2015 requirements)  In the same way you expect vendors to know where they got their minerals, you should also expect them to be able to account for any toxicity in their goods and to be on top of any health risks associated with their product’s use.

In short, a sustainable business is built on a supply chain that shares information across its entire length. This is exceptionally important for larger OEMs, as drilling down to the primary source of your components can be nigh-impossible when there are several degrees of separation. Despite this difficulty, as the chain link with the most authority, the ability to elicit change and improvement falls squarely onto you.

Current Regulations Regarding Conflict Minerals

The SEC is responsible for overseeing the due diligence about & reporting for Conflict Minerals. Currently, the SEC requires all companies that file reports under Section 13(a) or Section 15(d) of the Exchange Act, including domestic companies, foreign private issuers, and smaller reporting companies, to report if they use Conflict Minerals.

The final SEC ruling [pdf] came into effect January 1, 2013, and the first reporting deadline is May 31, 2014. That gives businesses all year to determine if they presently use Conflict Minerals, and 150 days after year end to complete and submit the report.

The report is filed on the new SEC Form SD, and covers the duration of the entire previous calendar year, regardless of the reporter’s fiscal year end. This report is an annual report, meaning that in May 2015, businesses will report their 2014 mineral use, and so forth.

If you need to report, your responsibility is to perform a due diligence investigation on your supply chain and minerals to determine unequivocally if your minerals are Conflict or conflict-free. This due diligence process is not heavily regulated, however there are some stipulations.

Whichever process you use in your supply chain assessments, it must comply with either nationally or internationally recognized standards. You cannot simply invent a personal due diligence protocol and use it for SEC reporting. As part of compliance with this ruling, your due diligence will need to be audited by a private sector auditor who can sign off that you have undertaken every reasonable action needed in your supply chain management for assessing mineral status.

One of the due diligence frameworks gaining the most popularity among manufacturers is the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas framework. It is quickly becoming the standard, as it offers a sound methodology for mineral sustainability tracking throughout any type of supply chain. Some of the protocols contained within the OECD guidelines include important takeaways such as:

  • Adopt a company policy for the supply chain of minerals and clearly communicate it to suppliers and the public.
  • Structure internal management to support supply chain due diligence.
  • Establish a system of controls and transparency over the mineral supply chain. This includes a chain of custody or a traceability system or the identification of upstream actors in the supply chain.
  • Strengthen company involvement with suppliers. A supply-chain policy should be incorporated into contracts and/or agreements.

While these OECD strategies are vital for assessing the status of your minerals, they are also proven building blocks for any sustainability program, in any industry. For example, ERA helps its OEM partners in the automotive industry track the potential toxicity of components that wind up in their final products throughout the supply chain as part of their sustainability planning. This type of sustainability tracking allows for far greater control of your reportable emissions and helps businesses to make smarter purchasing decisions.

Complying with Conflict Mineral Reporting

It should be noted that although the OECD guidance on due diligence and best practices is useful for managing your mineral supply chain, its suggested reporting procedures and strategies do not stand in for compliance with SEC regulations. While implementing OECD reporting practices for your own business will likely yield positive results overall, you will need to complete the SEC’s own reporting protocols regardless.

The SEC has attempted to make this initial transition period as easy as possible for reporters by creating a temporary reportable category for minerals: “DRC conflict undeterminable”. This label can be reported for all minerals that complete due diligence on their supply chains and mineral use and are unable to determine if they are Conflict or conflict-free. As a temporary solution, all large reporters will have a two year grace period to use this category, and all smaller reporters will have four years in total. In essence, it provides time for businesses to make the changes necessary in their supply chains so that they can definitely state their status, while still requiring you to perform due diligence.

n addition, any Conflict Minerals “outside the supply chain” prior to January 31, 2013 are excluded from Form SD reporting. This will reduce the implementation cost of the regulation and will protect American suppliers with existing stockpiles of potentially Conflict-sourced minerals from being forced to dispose of their goods. This is a sign that the SEC clearly does not want to punish those who may not have been aware of the potential ethical or regulatory complications prior to the final ruling.

Any regulated minerals sourced from recycled or scrap sources will not require a private sector audit if the business can state with certainty these materials did not come from any other source. You will still need to conduct your due diligence prior to reporting, but this is a much simpler and less expensive task if all your minerals are from recycled sources. However, if you are at all unsure, or only a certain proportion of your minerals are from scrap/recycled sources, you will need to undergo an audit as well.

Key Takeaways

Conflict Mineral reporting illustrates that supply chain management can be used for more than logistics and purchasing. By tapping into the flow of information across your supply chain, you have the potential to account for your entire Triple Bottom Line, including embedded energy use and carbon footprint, and tracking the human rights background of any material coming into your facility.

These new regulations also underscore the challenges associated with supply chain management. In particular, it highlights how collecting data from each tier of your supply chain gets more complex the further along the supply chain you look. This information loss and opacity put your facility at risk, not only for using Conflict Minerals or other banned substances, but also because it holds you accountable for your suppliers’ actions that you had no information about. It takes every supply chain link working together towards transparency to be confident about your own product. And as the Conflict Minerals reporting protocol demonstrates, it will likely take pressure from the top to achieve this level of transparency.

Just as the SEC put pressure on American supply chains to report their Conflict Mineral use, it’s time for you to push your supply chain to prioritize and share the sustainability data that affects your business.  .

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Always Wear Your Seat Belt While Operating a Fork Lift – why?

This photo shows the scene of a fatality that occurred when a forklift tipped over and the operator thought he could “jump clear.” He didn’t quite make it. He was crushed between the forklift rollover bar and the concrete floor. He wasn’t wearing his seat belt.

Other factors contributing to this death:

  • The presence of tipover hazards including “homemade” curbing at the edge of the loading ramp.
  • Inadequate lighting. It was too dark to safely see the operating area.
  • The lights on the forklift were burnt out.

IF you’re involved in a forklift tip over (Remind Your Operators):

  • Don’t jump.
  • Hold on tight.
  • Brace your feet.
  • Lean away from the direction of the tip over.

A best practice is to retrofit forklifts with seatbelts equipped with kill switches. These work similar to the ones in our personal vehicles and can be wired to the transmission so the machine will idle but not move. Operators found sitting on buckled seat belts are terminated immediately.

Enforce Your Safety Rules!!!

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It is coming!! ISO 14001:2015 Upgrade Training

EHS-MS is pleased to let you know we have developed the following program to help you upgrade your EMS to the requirements of the new ISO 14001:2015.

ISO 14001:2015 Upgrade Training

The new ISO 14001 standard is published and you are trying to figure how to upgrade your environmental management system (EMS) to meet the requirements of the ISO 14001:2015 standard.  This training session will outline in detail the requirements of the new ISO 14001 standard and the easiest way to update your EMS and what to expect from your registration company.

We will start offering public courses in October 2015.  The cost will be $895 per student.  The ISO 14001:2015 Tool Box will include electronic templates needed to upgrade your EMS documentation.

We can also offer this training at your location for up to 6 people for $3,200..

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Refrigerant Types

This is a nice overview of refrigerant types and their environmental impact. Refrigerant Types

 

 

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