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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ISO 14001 Revision

As many of you already know, the ISO 14001 is being revised by the International Organization for Standardization.  The final draft of the revision has been published and is available for purchase from ISO (Order ISO/DIS 14001).  The original release date was June 2015 and this has been moved to the end of 2015. [Revised ISO 14001:2015 training]



Once finalized, companies will have 3 years to upgrade their certification to the new standard.  Most certification companies will suggest that you upgrade at your next recertification audit once finalized.

We are planning to develop a Level 1 manual and set of training video’s to help companies upgrade their existing EMS programs. Please contact us with any questions. We will keep you posted on the progress of ISO 14001:2015 and our ISO 14001:2015 Tool Box.



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U.S. Department of Transportation Issues New Standards to Improve Safety of Lithium Battery Transportation

WASHINGTON – The U.S. Department of Transportation (DOT) today issued new standards to strengthen safety conditions for the shipment of lithium cells and batteries. These changes, some of which focus specifically on shipments by air, will better ensure that lithium cells and batteries are able to withstand normal transportation conditions and are packaged to reduce the possibility of damage that could lead to an unsafe situation.

“Safety is our number one priority, and this rule provides an additional layer of protection to the shipment of lithium batteries, which we all depend on daily to power our phones and our laptops,”  said Transportation Secretary Anthony Foxx. “Today’s standards are part of our ongoing work to improve safety for all travelers, including those who travel with or ship lithium batteries.”

The Department’s Pipeline and Hazardous Materials Safety Administration (PHMSA) developed this rule in close coordination with the Federal Aviation Administration (FAA). Voluntary compliance is encouraged upon publication of the final rule; however mandatory compliance is effective six months after publication.

The rule will also provide a greater level of consistency with international standards, including the International Civil Aviation Organization’s (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by air.

“Our continuing efforts to harmonize U.S. Hazardous Materials Regulations with international standards improve consistency in procedures and terminology when shipping lithium batteries around the globe,” noted PHMSA Administrator Cynthia L. Quarterman.

The final rule will:

  • Enhance packaging and hazard communication requirements for lithium batteries transported by air;
  • Replace equivalent lithium content with Watt-hours for lithium ion cells and batteries;
  • Adopt separate shipping descriptions for lithium metal batteries and lithium ion batteries;
  • Revise provisions for the transport of small and medium lithium cells and batteries including cells and batteries packed with, or contained in, equipment;
  • Revise the requirements for the transport of lithium batteries for disposal or recycling;
  • Harmonize the provisions for the transport of low production and prototype lithium cells and batteries with the ICAO Technical Instructions and the International Maritime Dangerous Goods Code; and
  • Adopt new provisions for the transport of damaged, defective, and recalled lithium batteries.

Click here for a copy of the final.

Thursday, July 31, 2014

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Effective EHS Training: ANSI’s Z490.1 Provides Nice Approach

Many companies spend a lot of time, effort, and money trying to maintain high standards for the environment, health, and safety (EHS). And this often involves-and should involve-an EHS training component.

For example, OSHA and similar regulatory agencies require EHS training at the workplace in many different circumstances. The regulations make it clear enough when training is required.

Beyond that, OSHA tells you that EHS training should be effective. They tell that you need to ensure it’s effective (through some form of assessment). And they tell you to provide it in a language the employee understands.

But it’s not always so clear exactly how to create effective EHS training. That’s not spelled out in the regulations. But fortunately, we’ve got ANSI Z490.1 for that.

Z 490.1, titled “Criteria for Accepted Practices in Safety, Health and Environmental Training,” provides a national standard for creating, maintaining, and evaluating an EHS training program.

So let’s dig into ANSI Z 490.1 and see what’s it’s all about. First, let’s deal with some common questions.

Common Questions about ANSI and ANSI Standards

What is ANSI?

ANSI is the American National Standards Institute. Also, they are “a private, non-profit organization that administers and coordinates the U.S. voluntary standards and conformity assessment system.” (I snagged that quote from their web page.) Read more about ANSI at their FAQs page or check out this ANSI Overview they created.

Do ANSI standards have the power of law?

No, not by themselves. But in some cases, a regulatory agency may include an ANSI standard within its own standard, stating that people should follow the ANSI standard in given circumstances. OSHA calls this incorporation by reference. ANSI has created a portal for its standards that have been incorporated by reference.



Common Questions about ANSI Z490.1

So what’s ANSI Z490.1?

It’s a national standard created to provide guidelines for safety, health, and environmental training. Basically, its creators took accepted practices in the training industry and put them into an EHS context.

Who created ANSI Z490.1?

An ANSI/ASSE task force. ASSE, in case you don’t know, is the American Society of Safety Engineers. Pretty credible folks on the topic of EHS.

Where can I find and read ANSI Z490.1?

Here’s Z490.1. Note that this isn’t free. It will set you back $77 or $92, depending on the packet you buy.

How many sections does ANSI Z490.1 include and what are they?

It has seven different sections and is fifty-two pages long. Those sections are:

  1. Scope, Purpose, and Application
  2. Definitions
  3. Training Program Administration and Management
  4. Training Development
  5. Training Delivery
  6. Training Evaluation
  7. Documentation and Record Keeping

There are also three annexes:

  1. References
  2. Training Course Development Guidelines
  3. EHS Trainer’s Checklist

What does ANSI Z490.1 say about training development?

The standard covers training development in section 4.



This section says that training development should be a systematic process including:

  • A needs assessment
  • Learning objectives
  • Course design
  • An evaluation strategy
  • Criteria for completion
  • A plan for continuous improvement

What does ANSI Z490.1 say about training delivery?

The standard covers training delivery in section 5.

This section covers the importance of:

  • Using teaching and instructional methods that are appropriate for your training audience
  • Creating (and using) training materials that are appropriate for your training audience
  • Using adult learning principles

What does ANSI Z490.1 say about training evaluation?

The standard covers training evaluation in section 6.

In this section, the ANSI standard stresses the importance of evaluating your EHS training courses and program, including the use of:

  • Test results (and results of other assessments of training)
  • Trainee feedback, including post-training survey/evaluations
  • Post-training behaviors and observations
  • Continuous evaluation and improvement efforts

ANSI Z490.1 is a great resource for anybody looking to develop or improve their EHS training programs.  You can also find a FREE EHS Training Best Practices manual prepared by the University of California at FREE EHS Training Manual.

Also, you can down load our FREE training matrix on the tab – FREE ISO Tools..

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OSHA’s New Recordkeeping Rules Summarized (29 CFR 1904)

On September 11, 2014, OSHA released the text of its Final Rule making changes to requirements for Injury and Illness Recordkeeping and Reporting under Part 1904, 29 C.F.R. §1904.0 et.seq.  The new requirements take effect in federal OSHA states on January 1, 2015.  State OSHA plans are encouraged to implement the changes by January 1, 2015, and are required to implement them no later than January 1, 2016.

The final rule includes only minor changes from the rule that OSHA proposed in June 2011.  Like the proposed rule, the final rule has two parts:  (1) it changes and updates the list of industries that are exempt from keeping records of injuries and illnesses, and (2) it changes and expands the requirements regarding reporting of “serious” work-related incidents to OSHA.



Changes regarding exemption from recordkeeping

With regard to the first part, the current regulation (in Appendix A to Subpart B of Part 1904) includes a list of 56 industries, identified by 2 or 3 digit SIC number, that are exempt from the recordkeeping requirements.  OSHA refers to these as “partially exempt” because, despite being listed Appendix A, they may be required to keep records if so notified by BLS, for its annual survey, or by OSHA, as part of the OSHA Data Initiative.  For ease of reference, this memo refers to the listed industries as exempt.

The current list was created in the 2001 changes to Part 1904 and was derived from injury and illness data from 1996 to 1998.  In general, the industries listed are those with Lost Workday Injury and Illness rates that were 75% or less of the average LWDII rate for all of private industry during those years.

The new rule retains the “75% of private industry average” methodology but uses NAICS industry classifications, identifies industries according to 4-digit classification, and uses the DART (days away, restricted work, job transfers) rate that is commonly used since the 2001 recordkeeping changes. The new list of exempt industries is based on 2007 to 2009 data.

Because overall injury and illness rates in the U.S. have declined, the threshold DART rate to be exempt under the new rule is 1.5, down from 2.325 that was used for the current list.  OSHA estimates that 199,000 establishments currently exempt will be covered by the new rule, and 119,000 establishments that were previously covered will now be exempt.  Thus 80,000 fewer establishments will be exempt from recordkeeping under the new rule.

It should also be noted that the separate exemption in 29 C.F.R. § 1904.1 for employers which employ fewer than 10 employees throughout the year is not changed by the new rule.

Changes regarding reporting incidents to OSHA  

OSHA’s current rule, section 1904.39, requires employers to report work-related fatalities and work-related incidents involving the hospitalization of 3 or more employees. All such incidents must be reported within 8 hours of their occurrence.  The employer must report such incidents by either contacting the OSHA area office or calling the toll-free 800 number OSHA maintains for this purpose, 1-800-321-6742.

The new rule is a substantial expansion of OSHA reporting requirements. Reporting of work-related fatalities is not changed; they must be reported within 8 hours. However, under the new rule, all work-related incidents resulting in hospitalization of a worker must be reported within 24 hours of the event.  Hospitalization is defined in the rule as “a formal admission to the in-patient service of a hospital or clinic for care or treatment.”  Thus emergency room visits are not covered, nor are admissions that are purely for observation or diagnostic testing.

In addition to hospitalizations, the new rule requires reporting within 24 hours of any “amputation” or enucleation (loss of eye).  “Amputation” is defined in the rule as “a traumatic loss of a limb or other external body part.  Amputations include a part, such as a limb or appendage with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached.”  OSHA states that this definition is taken from the 2010 BLS OIICS Manual.

The new rule provides that fatalities must be reported to OSHA if they occur within 30 days of the work-related incident.  Hospitalizations, amputations, or loss of an eye must be reported if it occurs within 24 hours of the incident.  However, the fatality, hospitalization, amputation, or loss an eye must be recorded if work-related, even if it does not have to be reported outside of these time frames.

One of the concerns expressed with the proposed rule was whether OSHA would be able to handle or make use of the vastly increased number of injury reports that will be receiving as of January 1. OSHA estimates that it will receive “30 times” as many reports under the new rule as it has received under the current reporting requirements.

In response to that concern, OSHA says that it expects that it will be able to respond in some manner to all reports, though not always with an inspection.  Instead OSHA indicates that it will determine on a case by case basis whether to launch an inspection, contact the employer by phone or fax, or “provide compliance assistance materials” to the employer. In addition, OSHA has stated that it will post reports of injuries or fatalities on its website.  Doing so would appear to require a considerable dedication of agency resources to scrub the information for any privacy concerns.



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Hazardous Waste Inspections – LQG and SQG – what is required?

You may conduct a variety of inspections at your facility:  quality control and regulatory standard, recommended and required, documented and undocumented.  If you generate a hazardous waste, conducting periodic inspections of certain critical risk areas is a good idea.  If you are a Large Quantity Generator or a Small Quantity Generator of hazardous waste, you are required to conduct weekly inspections of your hazardous waste accumulation containers. I will use this article to address the weekly inspection requirements required by US EPA regulation for accumulation containers of hazardous waste at LQG’s & SQG’s, it will not address…

  • The inspection requirements for tanks.  For more information on these management units an LQG should refer to 40 CFR 265.195 and an SQG should refer to 40 CFR 265.201.
  • The inspection requirements for the two remaining hazardous waste management units after tanks and containers:  Drip Pads [40 CFR 262.34(a)(iii)] and Containment Buildings [40 CFR 262.34(a)(iv)].
  • The inspection requirements of individual states, I will explain the regulations of the US EPA only.  Check with your State for clarification of these regulations unless you reside in Iowa, Alaska, or Puerto Rico since they lack approved programs to enforce RCRA.

To fully understand the inspection requirements it helps to appreciate the path that leads you to it.  You begin at 40 CFR 262.34(b) for an LQG and 40 CFR 262.34(d)(2) if an SQG; these are the accumulation time limit regulations for hazardous waste generators and are the starting point for most regulations applicable to generators of hazardous waste.  In this case both regulations point to 40 CFR 265.174—Inspections which is part of Subpart I—Use and Management of Containers.  40 CFR 265 is designed for Treatment Storage and Disposal Facilities (TSDF’s) that do not yet have a permit – thus “interim” – however, many times LQG’s and SQG’s are subject to these requirements as well.



At 40 CFR 265.174 you find this:  At least weekly, the owner or operator must inspect areas where containers are stored, except for Performance Track member facilities, that must conduct inspections at least once each month, upon approval by the Director. To apply for reduced inspection frequency, the Performance Track member facility must follow the procedures described in §265.15(b)(5) of this part. The owner or operator must look for leaking containers and for deterioration of containers caused by corrosion or other factors. Let’s take a look at this succinct and critical regulation one piece at a time.

“At least weekly…” – The US EPA does not define what weekly means; it has left the clarification of its meaning to the individual states.  However, based on my experience, it is safe to assume that this does not mean once per calendar week, but rather:  every seven days.  In other words, if you complete an inspection on Wednesday December 21st and the next week on Thursday December 29th, eight days separate the inspections and you have committed a violation.  Also, the regulations do not say anything about suspending the requirement during facility shut-downs (either planned or unplanned).  Therefore, the weekly – every 7 days – inspections must be completed even when you are shut-down for the holidays or maintenance if you have hazardous waste on-site.

“…inspect areas where containers are stored,” – This applies to anywhere within your facility that hazardous waste is generated, treated, accumulated, or stored; with one exception.  It does not apply to containers in satellite accumulation areas since 40 CFR 262.34(c) does not make compliance with 40 CFR 265.174 a requirement for hazardous waste containers managed in an SAA.  A container is defined at 40 CFR 260.10 as:  any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Thus it could include anything from a test tube to a 500-gallon portable tank to a 5,000-gallon tank mounted on a transport vehicle.

“…except for Performance Track member facilities…” – Forget it.  The National Environmental Performance Track is kaput.  Read its obituary here.

“…must look for leaking containers and for deterioration of containers caused by corrosion or other factors…” – The sole reason for the inspection is to determine the condition of the containers.  However, I recommend you take advantage of this opportunity to confirm your compliance with the following requirements as well:  labeling, date of accumulation, closed containers, condition of containment system (if required by your state), emergency communication and response equipment (as applicable), warning signs, and adequate aisle space.  Be sure to correct any errors you may find immediately and document the response action you take.  If damaged containers are found you must immediately transfer or manage the waste per 40 CFR 265.171.

Interesting that there is no requirement for generators of hazardous waste to document inspections or keep a log.  However, your state may require some form of documentation to prove you have been completing inspections as required.  I recommend you document your inspections and maintain records for at least three years.

Besides fulfilling the regulatory requirement, completion of a weekly inspection of your hazardous waste containers (I recommend you include SAA’s) is a good way to maintain regulatory compliance and provide a safe work environment.  Employees who complete these inspections should receive training on the applicable regulations and what it is they should be looking for



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OSHA Top Ten Violations for 2014

OSHA just released its list of the top ten most frequently cited workplace safety violations for fiscal year 2014. The 2014 list includes all the same all the same standards as last year’s list, and the four standards at the top of the list appear in the same order that they did last year, too.

The biggest “riser” was lockout/tagout (1910.147), which checked in at #8 last year but jumped up to #5 this year.

We’ve got the full list for you below. For each common violation, we’ve given a link to the regulation.

OSHA’s Top Ten Violations for 2014

Here’s the list, from most violated to tenth-most-violated.

Fall Protection (1926.501) – 6,143 violations

The Standard: Fall Protection

Our Course(s): Fall Prevention and Protection

Hazard Communication (1910.1200) – 5,161 violations

The Standard: Hazard Communication

Our Course(s): Hazard Communication 2012 (GHS), Hazard Communication 1994

Scaffolding (1926.451) – 4,029 violations

The Standard: Scaffolding

Our Course(s): Supported Scaffolding Safety

Respiratory Protection (1910.134) – 3,223 violations

The Standard: Respiratory Protection

Our Course(s): Respirators

Lockout/Tagout (1910.147) – 2,704 violations

The Standard: The Control of Hazardous Energy (Lockout/Tagout)

Our Course(s): Lockout/Tagout

Powered Industrial Trucks (1910.178) – 2,662 violations

The Standard: Powered Industrial Trucks

Our Course: Forklift Safety

Electrical, Wiring Methods (1910.305) – 2,490 violations

The Standard: Electrical, Wiring Methods

Our Course(s): Electric Shock, Electrical Safety General Awareness, Arc Flash Safety

Ladders (1926.1053) – 2,448 violations

The Standard: Stairways and Ladders

Our Course(s): Ladder Safety

Machine Guarding (1910.212) – 2,200 violations

The Standard: Machinery and Machine Guarding

Our Course: Machine Guarding

Electrical, General Requirements (1910.303) – 2,056 violations

The Standard: Electrical, General Requirements

Our Course(s): Electric Shock, Electrical Safety General Awareness, Arc Flash Safety.

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EMS Communications – What is required? [ISO 14001 4.4.3]

Internal EMS communication and awareness is typically one of the weaker parts of most management systems we audit.  Management teams often times do not clearly understand what information to share with employees and how to share it.  The ISO 14001:2004 internal communication requirements are overly general and provide little help. The ISO standard specifies:

4.4.3 Communication

With regard to its environmental aspects and environmental management system, the organization shall establish, implement and maintain a procedure(s) for…..

Internal communication among the various levels and functions of the organization,……..

So the requirement is to communicate information about your Environmental Aspects and Environmental Management System to employees at Various Levels and Functions. To keep matters simple we will talk about three basic levels of employees:

1)      Management

2)      Supervisors

3)      Production Employees

As an auditor, I have different expectations for each population of employee.

Personnel at all levels (including temporary) should get an awareness level overview of your EMS during their new hire orientation. This is the beginning of the communication process and where the problems typically start.  Some sites merely have the new employee read and sign their EMS policy while others create programs that are too complex.  The following topics should be covered in any orientation process:

1)      EMS Policy

2)      Summary of Significant Aspects

3)      Current Objectives/Targets

4)      Overview of Work Instructions

5)      Emergency Response Procedures

Once you have a well-focused and clear orientation process you need to sustain this awareness through your communication process.

Production employees and all other people working on behalf of the organization need to be aware of the general information included in their new hire orientation (see ISO 14001:2004 element 4.4.2 (a-h)).  Now it is up to the communication process to maintain and support the employee’s awareness of the EMS. Communication to all employees starts with posting the environmental policy at key locations in the plant – lobby, break room, time clock, etc..  The facility should also maintain an EMS communication board(s) that includes the environmental policy, list of significant aspects, EMS measurables, and EMS objectives.  Action: Verify that your policy is posted in key areas and update communication boards.

The facility also needs a ‘proactive verbal’ communication process. Most sites will have regular meetings with employees on a weekly, monthly, or quarterly basis to discuss production, quality or safety information.  It is these meeting that you need to add “EMS update” to the agenda and a ‘brief” 1 to 3 minute EMS update given. It is important that supervisors and department managers deliver these EMS updates because it requires them to keep up to date on the EMS topics.  For each meeting the environmental management representative (EMR) should provide a brief EMS update to the person leading the meeting.  To this process proactive simply put together an annual EMS communications plan that includes all methods of communication (download FREE EMS Communications plan).  Action: Review regular plant communication process and integrate EMS information.

The key is to explain the EMS in very clear terms.  You can explain that our EMS policy is that you are “Committed to the Prevention of Pollution” and that they prevent pollution by making good parts, recycling, containing oil/spills, turning off machines, etc.. They should also understand their responsibilities to control significant aspects and impact on the facility objectives/targets.

Supervisory employees should be aware of the sites EMS policy, identified significant aspects, work instructions, and emergency response procedures.  Typically supervisors will have very specific responsibilities during both fire and spill response.  They should clearly understand their role in controlling the identified significant aspects.

Management level employees should have a full working understanding the EMS as it applies to their position.  As an example, a Purchasing Manager should be aware that buying new chemicals or significantly increasing quantities of chemicals purchased could impact the aspects evaluation and should be reported the EMR.  New managers should get a detailed overview of the EMS procedures and information including a review of your aspects list, objectives/targets, training, document control, corrective action, and management review. This could be something as simple as an hour meeting with the EMR to review the documentation on the network. Surprisingly, less than 20% of the sites I audit provide this very basic level of training to new managers.                                    Action: Develop management level EMS orientation process.

The EMR should communicate EMS updates to management on a regular basis. Most management teams will get together monthly to review quality, financial, and production measurable and activities.  It is during these meetings that management should get updates on EMS measurables, objectives & targets, and EMS activities that month. This update can be brief and may only require 5 to 10 minutes to each meeting.  Then on an annual basis management should conduct a comprehensive review of the EMS and environmental performance as required by element 4.6 of ISO 14001.                         Action: Integrate EMS information into regular monthly management reviews.

You will be AMAZED at how this will dramatically improve employee engagement and overall awareness of your EMS program.   Simply planning out how these communications will occur on an annual basis will improve the effectiveness of your program.           Result: EMS Success!!!

FREE General Awareness PowerPoint
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Get ISO 14001 certified in 90 days!!

Need to get ISO 14001 certified by the end of 2014? This may seem like an impossible goal to achieve. If you are already ISO 9001 or TS 16949 certified this may be easier than you think. We have several clients who have just started developing their environmental management system and will be certified by the end of 2014.  We have developed a focused program that will result in a highly effective EMS program.  This includes the following:

  • ISO QuickStart™ – Aspects Matrix, EMS Manual, CFT Training, Implementation Plan
  • Legal & Other Matrix and Assessment
  • EMS Training Matrix and Awareness PowerPoint
  • EMS Internal Audit, Checklist and Procedure

With the right support and cross functional team (CFT). We can your site certified to ISO 14001 very quickly!!.

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OSHA extends comment period on proposed rule to improve tracking of workplace injury and illnesses

The Occupational Safety and Health Administration today announced it will extend the comment period on the proposed rule to improve tracking of workplace injuries and illnesses to Oct. 14, 2014. The proposal, published on Nov. 8, 2013, would amend the agency’s recordkeeping regulation to add requirements for the electronic submission of injury and illness information that employers are already required to keep.

During the public meeting held on the proposal, many participants expressed concern that the proposal may create motivation for employers to under-record injuries and illnesses, since each covered establishment’s injury and illness data would become publicly available on OSHA’s website. Participants also expressed concern that the proposal would lead to an increase in the number of employers who adopt practices that discourage employees from reporting recordable injuries and illnesses. OSHA is concerned that the accuracy of the data collected under the new proposal could be compromised if employers adopt these practices.

“OSHA wants to make sure that employers, employees and the public have access to the most accurate data about injuries and illnesses in their workplaces so that they can take the most appropriate steps to protect worker safety and health,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels.

Therefore, OSHA is soliciting comments on whether to amend the proposed rule to: 1) require that employers inform their employees of their right to report injuries and illnesses; 2) more clearly communicate the requirement that any injury and illness reporting requirements established by the employer be reasonable and not unduly burdensome; and 3) provide OSHA an additional remedy to prohibit employers from taking adverse action against employees for reporting injuries and illnesses.

Individuals interested in submitting comments may do so electronically at http://www.regulations.gov, the federal e-Rulemaking Portal. Comments may also be submitted via mail or facsimile. See the Federal Register notice for details..

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ISO 14001 – 2nd Draft Revison

Every five years, the International Organization for Standardization (ISO) reviews its standards. ISO is revising the ISO 14001 Environmental Management Systems standard and plans to release the new version in 2015.

ISO 14001:2015 is available for comment in the Draft Informational Stage. According to ISO, revisions will reflect the latest trends and ensure compatibility with other management system standards like ISO 9001.

Revisions of note include

  • understanding the organization’s context to better manage risk,
  • added emphasis on leaders to promote environmental management, and
  • a shift towards improving environmental performance vs.  improving the management system.

Expect the final revision to be published mid -2015.

Click here to view the official Web page on ISO 14001 revisions.

Also, see Revised-ISO14001.com for more information.

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SPCC Plan do I need one? 40 CFR 112

As I perform both environmental management system (EMS) and environmental compliance audits, I see much confusion about whether a site is required to develop and maintain a Spill Prevention Containment and Countermeasures (SPCC) plan. The SPCC regulations are specific to developing a spill response plan for oil intended to protect navigable water ways.

EPA promulgated the Oil Pollution Act (OPA) in 1990 and the original SPCC rules in 1991.  The requirements for SPCC plans can be found at 40 CFR 112.7.  The criteria for determining whether an SPCC plan is required are found at 40 CFR 112.1 and include:

  • Criteria #1 – Only applies to non-transportation related facilities.
  • Criteria #2 – Facilities that have oil containers exceeding 1,320 gallons only counting containers 55 gallons and larger [40 CFR 112.1(d)(2)(ii) and (d)(5)].
  • Criteria #3 – Could reasonably be expected to discharge oil in quantities that may be harmful, into or upon the navigable waters of the United States or adjoining shorelines….[40 CFR 112.1 (b)]

All three (3) criteria must be met before an SPCC plan is required. All manufacturing facilities would be considered non-transportation related facilities and meet criteria #1.  It is the interpretation of criteria #2 and #3 that can become less than clear.

Criteria #2 – Facilities that have oil containers exceeding 1,320 gallons

While this may seem like an easy calculation knowing what to count and what not to count can be tricky.  First, we only need to could containers are 55 gallons or greater, this can include:

  • 55  gallon drums of new or used oil;
  • Above-ground storage tanks (that exceed 55 gallons)
  • Oil reservoirs in machinery (that exceed 55 gallons)
  • Oil/Water separators (that exceed 55 gallons)

Equipment or containers that are “permanently closed” are not included. EPA defines Permanently Closedmeans any container or facility for which: (1) All liquid and sludge has been removed from each container and connecting line; and (2) All connecting lines and piping have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure.”

Now we must take an inventory of the containers at our site that meet the above criteria and see if we exceed 1,320 gallons. It is the container size that we measure not the quantity of oil in the container. Also, EPA does define oily water as oil so we need to include our oily waste water and process water that contains oil in the inventory.

Criteria #3 – Could reasonably be expected to discharge oil in quantities that may be harmful, into or upon the navigable waters

EPA defines navigable water way at 40 CFR 112.2 and this includes:

Navigable waters of the United States means “navigable waters” as defined in section 502(7) of the FWPCA, and includes:

  • All navigable waters of the United States, as defined in judicial decisions prior to passage of the 1972 Amendments to the FWPCA (Pub. L. 92-500), and tributaries of such waters;
  • Interstate waters;
  • Intrastate lakes, rivers, and streams which are utilized by interstate travelers for recreational or other purposes;
  • and Intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in interstate commerce.

So the questions we might ask is “would our worst case scenario spill and the ability to be harmful to a navigable water way?”.  This leads to another question, how does EPA define harmful impact?

EPA defines quantities that may be harmful as discharges of oil that violate applicable water quality standards; or cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shoreline. So basically any quantity of oil would meet this criteria.

So could my oil reach a Navigable Water way? To answer this question you should consider your worst case spill and potential pathways this spill could travel. Many facilities have storm water drainage systems that ultimately discharge to either a tributary or major water way we believe could meet the definition of a Navigable Waterway and would be subject to SPCC.

Now there are many sites where the pathway may be much harder to define.  Say you have drainage ditches that discharge to a county drain and most days these are dry.  In this scenario on a dry day a fairly large spill could occur and be cleaned up before it migrated very far. However, lets says the spill occurs during a heavy rain, it is likely the impact could reach a Navigable Waterway.

It is up to each facility to assess the potential of an oil discharge to reach a navigable water way. If your facility meets criteria #1 and #2 but you do not believe a release could impact a Navigable Waterway then it is recommended that you document this evaluation and maintain it for your records.

Many facilities will take a conservative approach and prepare an SPCC plan in either of the above scenarios.  The thought process is that have a spill prevention and response plan is a good business practice and does help reduce risk.

If you have any questions on how this regulation applies to your operations please contact us at James.Charles@iso14001-training.com or www.ISO14001-Training.com. Let us know how we can help answer your questions.



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ISO 14001 Revision

In our previous blog, we shared an outline of the new ISO 14001 standard.  The changes not only reorganize the standard but will add some new requirements. These changes are based on the recognition that the organization is affected by its social and political surroundings, is part of a larger value chain and needs to align or reconcile its EMS and business strategies in order to achieve its intended outcomes.

New PDCA Model

Below is the revised EMS PCDA model proposed by ISO:

ISO 14001 Training Michigan

New terms have been introduced for interested parties, risk, indicators, value chain and lifecycle.

The new requirements that will likely have the biggest impact on certified organizations are tied to these new terms:

  • Determination of relevant external and internal issues that could affect achievement of the intended outcomes of the EMS
  • Determination of the relevant interested parties and their requirements
  • Integration of the EMS and objectives into business processes
  • Compatibility of the environmental policy and objectives with its strategic direction
  • Consideration of environmental performance in strategic planning
  • A policy that is appropriate to the organization’s risks and opportunities
  • Consideration of life-cycle perspectives
  • Identification and access to the relevant requirements of interested parties
  • Identification of organizational risks and opportunities
  • Competency of those that affect its environmental performance
  • Control or influence of processes associated with the value chain, significant environmental aspects and organizational risks and opportunities, taking into account a lifecycle perspective.
  • Monitoring of risks and opportunities and value chain controls
  • Use of performance indicator criteria
  • A management review that incorporates the above requirements

While many of the above changes can be addressed with small changes to your organizational and strategic planning processes they will also expand the scope of your external and internal auditing programs.

We will be coming out with an online training solution that will get your team up to speed on the new requirments and up date your internal auditors.  We will keep you posted.

www.ISO14001-Training.com

 

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Used Oil vs. Waste Oil – What’s the difference?

I had thought most of us had a clear understanding of the difference between these two types of oil waste streams but during a recent ISO audit I encountered a site who labeled all of their used oil as “waste oil”. While these terms sound interchangeable there can be differences in how they are managed.

First off, whether used oil or waste oil, it’s regulated by the Federal USEPA and State governments under the Resource Conservation and Recovery Act.

Now here’s the difference.

Used oil is oil that has been used, and as a result of such use, is now contaminated by physical or chemical impurities. The classic example is used oil drained from the engine of a truck or vehicle, and then stored for reuse or recycling.

Waste oil is oil that has not been used, but is found to be unsuitable for its originally intended purpose. For example, suppose a 55-gallon drum of oil was opened only to find that the cap on the drum had leaked, and now the oil was mixed with water, rendering it unsuitable for it’s original purpose. A big difference between the two is that waste oil maybe a hazardous waste. Oils that are off-specification (“waste oil”) typically contain: Arsenic 5 ppm, Cadmium 2 ppm, Chromium 10 ppm, Lead 100 ppm, and Total Halogens >4,000 ppm and could be characterized as hazardous waste.

So there is a difference in used oil vs waste oil. And, there is a difference in how they are regulated too. Used oil is considered a regulated waste, while waste oil maybe a hazardous waste. Nearly all plants have used oil, while very few ever have waste oil. There are additional regulations, such as the level of contamination of the used oil, regards to its eventual reuse, recycling, or disposal. It’s much better to have used oil vs waste oil.

Used oil tanks or containers (drums, totes, etc.) must, by regulation, be labelled as Used Oil – not unmarked, unlabelled, or as waste oil. Used Oil – that’s it.

                                       

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ISO 45001: The New Health & Safety Standard

ISO recently announced that ISO Committee ISO/PC 283 – Occupational Health & Safety Management Systems, has been formed with an objective to develop and publish an international standard for Occupational Health and Safety (OH&S) based on OHSAS 18001. The new standard will be known as ISO 45001. The standard’s publication is still some time off, but the result will hopefully be an up-to-date health and safety management system which will allow practicable and efficient integration with standards such as ISO 14001 and ISO 9001.

This standard, designated as ISO 45001, will establish globally-accepted requirements for third-party certification of an OH&S management system. It is intended to replace the OHSAS 18001 standard.

At the first meeting of the committee ISO/PC 283 in October 2013, an outline project plan for the development and publication of ISO 45001 was created:

• ISO/CD 45001 (first committee draft) to be published by May 2014
• ISO/DIS 45001 (first draft international standard) to be published by February 2015
• ISO/FDIS 45001 (final draft international standard) to be published by March 2016
• Final ISO 45001 to be published in October 2016

The new standard will follow the “High-Level Structure” format defined in Annex SL, meaning that it will be aligned with the revised versions of ISO 14001 and ISO 9001 scheduled for publication in 2015.

ISO/PC 283 – the committee responsible for ISO 45001 – held their inaugural meeting in October. It was agreed that, ISO 45001 will fall in line with the Annex SL high-level structure,. This means that all the management system standards will eventually be aligned. This decision was taken by the ISO Joint Technical Coordination Group (JTCG) in an effort to make life easier for organisations who wish to have a single management system.

This will mean the structure of the standard will be:

1. Scope
2. Normative references
3. Terms and definitions
4. Context of the organization
5. Leadership
6. Planning
7. Support
8. Operation
9. Performance evaluation
10. Improvement

Moving forward, the committee established a plan for the development and publication of the standard:

• ISO/CD 45001 (first committee draft) to be published by May 2014
• ISO/DIS 45001 (first draft international standard) to be published by February 2015
• ISO/FDIS 45001 (final draft international standard) to be published by March 2016
• ISO 45001 to be published in October 2016

The next meeting for the ISO/PC 283 committee will be held in March 2014 in Morocco in order to get the working draft of ISO 45001. It will then be open for comment, in order to ensure the standard reflects the needs of users around the world.

With poor health and safety management costing around 4% of global GDP, the new international standard’s impact has the potential to save lives, reduce accidents and improve employee morale. Its impact on industry will be closely watched by business leaders and safety professionals around the world. If done correctly it has the potential to improve safety standards, performance and ultimately reduce accident rates. However if not managed properly it could end up being just a paper exercise and a new certificate on the wall.


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Hazardous Waste (Biennial) Reporting – Michigan

Large quantity generators (LQG) and Treatment, Storage, and Disposal Facilities (TSDF) are required to file Biennial Hazardous Waste Reports.  These reports are required to be filed on the even numbered years (ie. 2014) for the previous year’s (ie. 2013) activities. This years reports are due March 1. 2014.

The DEQ will not be sending biennial packets this cycle.  Instead LQGs and TSDs will report using the federal forms and instructions.  The DEQ is encouraging the use of the State of Florida’s biennial reporting software (BRSW4). You may use the federal forms or approved software systems.

Please note that Michigan has not adopted the Hazardous Secondary Material rules yet – Please do not complete Section 12 or the Addendum page of the Site Identification form.

Paper submissions of the Biennial Hazardous Waste Report must include a signed copy of the Michigan Site ID Form (EQP 5150) along with the Biennial Report forms GM and WR (as required).

Please feel free to contact us with any questions on how this requirement applies to your facility.

James.Charles@iso14001-training.com

 


 

 

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Free ISO Tools


It was recently brought to my attention that most of the links on our Free ISO Tools page were broken.  I wanted to let you know that these have all been fixed and are now working.  Also, if you have additional tools or templates you would like to see posted please forward these to me – james.charles@iso14001-training.com

Please let us know if these tools provide any help – FREE ISO TOOLS.

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New ISO 14001 – It’s coming!!

The Internal Organization for Standardization (ISO) has begun their next revision of the ISO 14001 standard. A draft of the proposed changes was issued on October 23, 2013 by the ISO/TC 207 committee and comments are due back January 23, 2014. Below is the proposed table of contents for the proposed revised standard.  The new version of the ISO 14001 standard is expected in 2015. The proposed standard adds definitions for several terms that will bring clarity to interpreting requirements – in a future blog we will provide an update on these new definitions. It will be very interesting to see what the revised standard looks like!!




Foreword
Introduction
Scope
2 Normative references 
3 Terms and definitions
4 Context of the organization
4.1 Understanding the organization and its context
4.2 Understanding the needs and expectations of interested parties
4.3 Determining the scope of the environmental management system
4.4 Environmental management system
5 Leadership
5.1 Leadership and commitment
5.2 Environmental policy
5.3 Organizational roles, responsibilities and authorities
6 Planning
6.1 Actions to address risks and opportunities
6.1.1 General
6.1.2 Identification of environmental aspects
6.1.3 Determination of compliance obligations
6.1.4 Determining significant environmental aspects and organizational risks and opportunities
6.1.5 Planning to take action
6.2 Environmental objectives and planning to achieve them
6.2.1 Environmental objectives
6.2.2 Planning to achieve objectives
7 Support
7.1 Resources
7.2 Competence
7.3 Awareness
7.4 Communication
7.4.1 General
7.4.2 Internal communication
7.4.3 External communication and reporting
7.5 Documented information
7.5.1 General
7.5.2 Creating and updating
7.5.3 Control of documented information
8 Operation
8.1 Operational planning and control
8.2 Value chain control
8.3 Emergency preparedness and response
9 Performance evaluation
9.1 Monitoring, measurement, analysis and evaluation
9.1.1 General
9.1.2 Evaluation of compliance
9.2 Internal audit
9.3 Management review

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OSHA’s Top 10 Willful Violations for FY 2013

Safety & Health’s annual article on the top 10 for fiscal year 2013 had to use preliminary data. Rounding out the OSHA Top 10 update is a list of the top 10 willful violations of 2013:

Ranking – Standard – Number of violations

1. – Fall Protection (1926.501) – 73

2. – Excavations (1926.652) – 34

3. – Lead (1910.62) – 25

4. – Machine Guarding (1910.212) – 23

5. – Lockout/Tagout (1910.147) – 20

6. – Scaffolding (1910.451) – 19

7. – Guarding Floor and Wall Openings and Holes (1910.23) – 18

8. Respiratory Protection (1910.134) – 17

9. Process Safety Management (1910.119) – 14

10. Powered Industrial Trucks (1910.178) – 10

Please review your programs in these areas to make your facility is in compliance with the applicable OSHA programs.  Please feel free to contact us with any questions or for ways we can help improve your programs. James.Charles@iso14001-training.com.

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