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..

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, ISO 14001 | Tagged , | Leave a comment

Refrigerant Types

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

 

 

 .

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, ISO 14001 | Leave a comment

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.



.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Tagged , | Leave a comment

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

 .

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in DOT, ISO 14001 | Tagged | Leave a comment

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..

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in OHSAS 18001, OSHA | Tagged , , | Leave a comment

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.



.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in OSHA | Tagged , , | Leave a comment

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



.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance | Tagged , , | Leave a comment

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.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in OHSAS 18001, OSHA | Tagged , | Leave a comment

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
.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Tagged , | Leave a comment

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!!.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, ISO 14001 | Tagged , | Leave a comment

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..

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in OHSAS 18001, OSHA | Tagged | Leave a comment

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.

.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Tagged | Leave a comment

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.



.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Leave a comment

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

 

 .

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Leave a comment

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.

                                       

.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, ISO 14001 | Tagged , , | Leave a comment

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.


.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 45001, OHSAS 18001, OSHA | Tagged , , | Leave a comment

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

 


 

 

 .

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance | Tagged , | Leave a comment

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.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Leave a comment

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

.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Tagged , , | Leave a comment

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.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in OSHA | Tagged | Leave a comment

Social Accountability – SA8000 Standard

Many major companies – Apple, Walmart, etc. – have become interested in the social accountability of their world-wide suppliers.  Child labor and unsafe working conditions have resulted in some very bad press for these companies.

Some companies have decided to become more proactive in assessing these social performance of their supply chain. Social Accountability International (SAI) an organization to advance the human rights of workers around the world has developed the SA8000 standard.

SA8000 is one of the world’s first auditable social certification standards for decent workplaces, across all industrial sectors. It is based on conventions of the ILO, UN and national law, and spans industry and corporate codes to create a common language to measure social compliance. It takes a management systems approach by setting out the structures and procedures that companies must adopt in order to ensure that compliance with the standard is continuously reviewed. Those seeking to comply with SA8000 have adopted policies and procedures that protect the basic human rights of workers.

EHS-MS has helped clients develop programs to become SA8000 compliant and to prepare for 2nd party audits. Please feel free to contact us with any questions related to this standard at James.Charles@iso14001-training.com . We can also assess your supply chain to determine their compliance with basic social programs. These type of risk based assessments can help reduce exposure to liability and public relation issues.

 

 .

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Leave a comment

Changes to ISO 14001 and OHSAS 18001 – they are coming!!

Both the ISO 14001:2004 and OHSAS:2007 standards are heading for changes. The revised changes to ISO 14001:2007 are planned to be finalized in 2015.

ISO 14001 Status:
ISO has issued Guide 83 “High level structure and identical text for management system standards and common core management system terms and definitions.” This document will change the structure of current ISO standards when revised, with the intent of enhancing consistency and integration of all management system standards. These “structural” changes will likely be the primary changes to ISO 14001.

The ISO Working Group 5 is responsible for revising the standard. The revised version of ISO 14001 is presently at the Working Draft stage. A draft version of 14001 may be published later this year (2013), with the final standard expected early 2015.

OHSAS Status:
New proposal for ISO 18001, ballot for approval closes June 11, 2013

ISO 14001 Update

The new format for the revised ISO 14001 is expected to 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.

Some key changes could include:

 • Section 4: Similar to current Section 4.1 with respect to scope, but “context” may result in expansion with respect to evaluation of environmental interactions of the organization.
• Section 5: more emphasis on management responsibility, and potential expansion into mitigating risks, sustainable resource use, climate change, biodiversity and restoration of natural habitat.
• Section 6: environmental aspects to consider life cycle assessment, and determination of Key Performance Indicators (KPIs) for objectives.
• Section 7: expansion to include communication strategy, and external reporting procedure
• Section 8: expansion to include environmental considerations in design and procurement (similar to ISO 50001).
• Section 10: New section on continual improvement with respect to environmental performance

 We will keep you posted of changes or updates as we become aware of them. Please contact us with any questions..

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001, OHSAS 18001 | Tagged , | Leave a comment

OSHA Mandates New Hazard Communication Training by 12/1/13

Don’t procrastinate!!

OSHA has adopted new hazardous chemical labeling requirements as a part of its recent revision of the Hazard Communication Standard, 29 CFR 1910.1200 (HCS), bringing it into alignment with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This is getting to be old news but as the deadline approaches most companies have yet to complete the required training.

The revised HCS changes the existing Hazard Communication Standard (HazCom 1941) from a performance-based standard to one that has more structured requirements for the labeling of chemicals. The revised standard requires that information about chemical hazards be conveyed on labels using quick visual notations to alert the user, providing immediate recognition of the hazards. Labels must also provide instructions on how to handle the chemical so that chemical users are informed about how to protect themselves. Safety Data Sheets (SDSs), which must accompany hazardous chemicals, are the more complete resource for details regarding hazardous chemicals. The revised standard also requires the use of a 16-section safety data sheet format.

The HCS requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: product identifier; signal word; hazard statement(s); precautionary statement(s); and pictogram(s); and name, address and telephone number of the chemical manufacturer, importer, or other responsible party.

NOTE: This is a requirement of the “chemical manufacturers, importers, or distributors” not the employer.


Workplace Labels
OSHA has not changed the general requirements for workplace labeling. If an employer has an in-plant or workplace system of labeling that meets the requirements of HazCom 1994, the employer may continue to use this system in the workplace as long as this system, in conjunction with other information immediately available to the employees, provides the employees with the information on all of the health and physical hazards of the hazardous chemical.

Employers may continue to use rating systems such as National Fire Protection Association (NFPA) diamonds or HMIS requirements for workplace labels as long as they are consistent with the requirements of the Hazard Communication Standard and the employees have immediate access to the specific hazard.

Employer Responsibilities
Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, and drums. This means that labels must be maintained on chemicals in a manner which continues to be legible and the pertinent information does not get defaced or removed in any way. The employer must relabel items if the labels are removed or defaced.

Required Training (by 12/1/13)
By December 1, 2013 employers must have trained their workers on the new label elements and the SDS format. This training needs to include the following:

  • Training on labeling requirements;
    • Product Identifier
    • Signal Word
    • Pictogram
    • Hazard Statement
    • Precautionary Statement
    • General training on how to read and understand labeling information
  • Training on the format of the SDS and how to determine chemical hazards.

Please contact Jim Charles if you need support updating your existing training program.  We can prepared the training program and train your staff on the new requirements.


 

Teach your supervisors to speak Spanish!! Rocket Languages – Spanish, French, German, Chinese, online quizzes, iPod/iPhone compatible, and more!!.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, OSHA | Tagged , , | Leave a comment

Solvent-Contaminated Shop Rags (Wipes) – new EPA rule

At long last—we have clarity from the U.S. Environmental Protection Agency (EPA) on solvent-contaminated shop rags (also known as wipers).  On July 31, 2013, EPA published a rule on the proper handling and disposal of solvent-contaminated rags/wipes.  EPA’s new rule contains a “conditional exemption” that excludes solvent-contaminated wipes that are disposed of from the definition of hazardous waste.



In the past, ambiguity from EPA on the waste classification of shop rags has resulted in a patchwork of state regulations; most states consider rags contaminated with solvents to be subject to hazardous waste rules.  On the other hand, reusable wipes (i.e., rags that are laundered by a commercial laundry and reused) have been exempt from hazardous waste regulations in most states. The EPA states in the July 31 ruling that it is providing national consistency in regard to the regulation of shop wipes.

The rule stipulates the following conditions must be met for solvent-contaminated rags:

  1. Rags may not be stored on site for more than 180 days.
  2. No free liquids are permitted, as determined by the Paint Filter Liquids Test (U.S. EPA Test Method 9095B).
  3. Rags must be stored in a non-leaking closed container.
  4. Facilities must maintain documentation demonstrating that rags are being managed as excluded solvent-contaminated wipes.

The rule also states that rags that are laundered and reused are exempt from solid waste regulations.

A couple of caveats:  Rags contaminated with trichloroethylene are not part of this exclusion.  In addition, the EPA rule does not go into effect until January 31, 2014, so facilities that generate solvent-contaminated rags should continue to follow their state’s requirements for handling and disposal.


.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, EPA, ISO 14001 | Tagged , , | Leave a comment

Behavior Based Systems – Safety, Quality, and Environmental make them lean

Behavior-Based approaches have impacted the safety community for over many years. The BBS process has also been used to enhance our quality and environmental programs. While BBS is based on a few core principles, any consistent methodologies have been slow to evolve. Methodology providing results must eventually be enhanced or may become obsolete. Moreover, any process that isn’t efficient (i.e., Lean) in its search for increasing effectiveness will overburden those supporting it.

Lean does not mean less. Rather, it is a focus on value-add and the continued identification and removal of activities and efforts that add waste; or more simply put: greater value through less work. As the 90’s brought the popularity of Lean Methodologies and Lean Thinking, a natural evolution to BBS was not far behind.

Opportunities for Lean BBS:

  1. Integration – One of the most effective ways to minimize resistance to change is to minimize the perception of it. What existing structure, process, team, or cultural capability would produce a shorter path to results and create the impression of evolution rather than revolution? Perhaps the 5S team becomes the 6S, or integrate your focus on quality to include safety with Behavior-Based Quality or Environmental & Safety? Both have proven successful in the right environment. What about an existing team or sub-team or committee?
  2. Training – Overtraining is a common problem when the focus is on implementing a methodology rather than recognizing rapid and sustainable results. Consider what information is needed at this time to accomplish results in the next 90 days? How can you build on that once success is recognized? Why teach a team how to analyze data and develop action plans until they have their own data?
  3. Steering Team Size – A team that can never all get together isn’t a team. A successful process needs a team representing the interests of the population to make the important decisions of improving process and safety. What that team looks like, how many are on it, and the makeup of levels involved is culturally specific and based largely on trust.
  4. Checklist size – Effective BBS processes determine the most important behaviors to focus on based on historical incidents and observed common-practice data. A focus on more than five or six items is not a focus. Moreover, centering attention on the wrong things is not very efficient. If your checklist isn’t focused, neither is your process. Further, the checklist needs to adapt to fit the needs of the process. A process should never revolve around a checklist or be dependent on others to print and modify it.
  5. Observation Strategies – Blanketing observations is a tactic to capture a sampling of all common practice. Too often this becomes the only observation plan. There are four other common observation methods: Aimed, Blitz, Seeing without Explaining to Every Person and Self. Depending on the data and value that needs to be derived from the process, the observation strategy should evolve to focus on new results. Is it aiming at the right thing, time of day, etc.? Is it blitzing where most needed based on identified influence? S.W.E.E.P. observations are often used to validate a high percent-safe finding, and self-observations are often used with logistically challenged workforces.
  6. Data Utilization and Feedback– Far too many processes do not analyze their data on a frequent enough basis to understand how to: prioritize action plans, address data quantity and quality, identify trends and influences on behaviors, and respond to these influences. Any mature process combined with a healthy safety management system can indicate where, when and why the next incident will occur with a high degree of accuracy, based on observed practices.
  7. Voice Of The Customer – When a process is launched, all who will be impacted should be briefed to begin to address the “What’s In It For Me” question. Realize, however, the question never goes away; the answer will change over time. This process must treat others like the customers they are. If process leaders are not communicating in a way that creates strong knowledge and value recognition (e.g., everyone can name the behaviors of focus and recent successes), the support will wane.
  8. Documented Roles, Responsibilities and Results – Change initiatives for decades have experienced the middle-management backlash, due to bottom-up and top-down approaches. BBS has been no different. We desperately need supervisors to support the process, yet most processes fail to explain and develop approaches to ensure this occurs. The roles, behaviorally-defined responsibilities and results expected need to be developed for all involved, from those observing to those supporting leading (e.g., integrate with leader standard work) and serving only in a customer capacity.



The goal of BBS is to improve safety and help those impacted by it to make safer decisions and address the factors that might influence risk-taking (e.g., perceptions, habits, obstacles and barriers). While there is certainly much more to the Lean BBS methodology, consider how you can use this Lean BBS thinking to eliminate unnecessary or non-value added steps and maintain a results orientation rather than a crank-the-process one.

Many times an effective BBS program can take a safety management system (OHSAS 18001 or ANSI Z10) to the next level and make your program much more proactive.  This is also a key component in developing the safety culture that most companies desire. Please contact us for help developing your BBS or certified safety management system.


.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Leave a comment

Risk management using ISO 31000

Risks affecting organizations can have consequences in terms of economic performance and professional reputation, as well as environmental, safety and societal outcomes. Therefore, managing risk effectively helps organizations to perform well in an environment full of uncertainty.

ISO 31000:2009

ISO 31000:2009, Risk management – Principles and guidelines, provides principles, framework and a process for managing risk. It can be used by any organization regardless of its size, activity or sector. Using ISO 31000 can help organizations increase the likelihood of achieving objectives, improve the identification of opportunities and threats and effectively allocate and use resources for risk treatment. However, ISO 31000 cannot be used for certification purposes, but does provide guidance for internal or external audit programs. Organizations using it can compare their risk management practices with an internationally recognized benchmark, providing sound principles for effective management and corporate governance.

Related Standards

A number of other standards also relate to risk management.

  • ISO Guide 73:2009, Risk management – Vocabulary complements ISO 31000 by providing a collection of terms and definitions relating to the management of risk.
  • ISO/IEC 31010:2009, Risk management – Risk assessment techniques focuses on risk assessment. Risk assessment helps decision makers understand the risks that could affect the achievement of objectives as well as the adequacy of the controls already in place.  ISO/IEC 31010:2009 focuses on risk assessment concepts, processes and the selection of risk assessment techniques.

Please contact us with any questions on how your organization can use this guidance document to enhance your risk management programs.


.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 31000 | Tagged , | Leave a comment

Significant Aspects – what are they? (ISO 14001)

The ISO 14001 standard does not define the term “significant aspect” and this can create some confusion when developing an EMS and have significant impact on the effectiveness of the EMS.  The goal of the ISO standard is to provide a framework for environmental management systems and NOT dictate what an organization must choose to manage in the context of their EMS. It is understood that organizations can have different impacts on the environment and varying resources available to manage these impacts.

Section 4.3.1 of ISO 14001 requires organizations to identify their environmental aspects and “determine those aspects that have or can have significant impact(s) on the environmental”.  This process is designed to allow an organization to FOCUS their attention on the aspects of their business that have (or CAN HAVE) the most significant impact.  The determination of significant aspects is a focusing process that allows top management of an organization to FOCUS the attention of their EMS resources on the biggest impact(s) and it is up to top management to determine what to manage within the context of the EMS.

One of the myths around EMS development is the belief there is a “correct list of significant aspects” and this simply is not true.  The standard allows the organization to develop the process to determine significance and final selection of significant aspects.  There is no right or wrong answers but there are effective and ineffective processes that yield a list of significant aspects.

The EMS must support top managements commitments to 1) the prevention of pollution, 2) comply with legal & other requirements, and 3) continual improvement.  One of the primary ways to support the commitment to the prevention of pollution is through the control of your significant impacts.

Once you identify an aspect as significant you must do the following:

  • Communicate to employees that this aspect is significant
  • Train employees involved in the activity
  • Develop operation controls for the aspect and written work instructions, when appropriate
  • Monitor & measure the activity as needed to gauge performance
  • Consider the aspect when setting EMS objectives (though setting an objective to improve is not required for each significant aspects)

Another common myth is once an aspect is determined to be significant there must be an objective set to improve the aspect.  If air emissions were determined to be a significant aspect and the facility emissions are meeting the requirements of their air permit, there is no requirement that an objective be set to reduce air emissions – only that this be considered by top management.


One of the most common methods for determining the significance of an aspect is through a hybrid of the failure mode effects analysis (FMEA) process that will use criteria like frequency and severity as well as other criteria (stakeholder concern, legal requirement, cost/volume, etc.) to assess the risk of each aspect.  It is through the selection of these criteria that a relative risk for each aspect can be established and the management team can then use this risk assessment to make the final determination.  This is where the management team can use judgment to make the final determination of significance based on their understanding of the organization and its operations.

Through the process of selecting significant aspects top management chooses what aspects to include or Focus the EMS.  This will determine the type of EMS that will be developed and are classified as follows:

  • Type 1 – Unfocused EMS
  • Type 2 – Focused EMS
  • Type 3 –  Comprehensive EMS

Type 1 – Unfocused EMS

The unfocused EMS is where either non-significance aspects are identified as significant or too many significant aspects are determined to be significant.  As an auditor this is the toughest type of system to audit because the ISO 14001 standard allows the organization to determine significance and there really is not wrong answer. The problem with having too many significance aspects is that this list is hard to communicate, training requirements can become over whelming, and monitoring & measuring activities become meaningless. The number one reason for Unfocused EMS is site that defines all aspects with legal requirements as significant – this yields things like disposal of bulbs, blood borne pathogens, and others as significant.   The result is an overall dilution of the effectiveness of the EMS and lack of FOCUS.

Type 2 – Focused EMS

This is where top management chooses 1 or 2 aspects to focus their attention for the purposes of defining goals and performance measures.  Many newly developed EMS programs choose to start as a Focused EMS to get the organization familiar with the EMS process and focus the time of their limited EMS resources. This type of EMS can allow the program to become more comprehensive over time, however many organizations choose to keep a focused EMS program with changing priorities focusing on different EMS aspects over time.  While is appears helpful to focus the program this long term approach to the EMS can be confusing to production employees and can prove difficult to measure improvements in environmental performance.

Type 3 – Comprehensive EMS

This is where an organization identifies a comprehensive yet focused set of significant aspects that represent the biggest overall impact to the environment. This will typically be a list of 3 to 5 major aspects that will be used to develop operational controls, training programs, and set objectives that are monitored & measured to determine performance.  It is these aspects, regardless of the maturity or effectiveness of controls,  that are the most significant.

Many sites (approximately 25% that I have audited) will reduce the significance of aspects based on having highly effective controls in place; however, I believe that we should rank the significance of the aspects without controls to gauge their true significance. A significant aspect that is well controlled only needs for the controls to fail or even be less than effective to realize the maximum possible impact – exactly what the EMS is trying to avoid.

REMEMBER the process to determine significant aspects is designed to FOCUS our EMS on the aspects that top management feels are the most significant activities the organization does to impact the environment. There is no right or wrong list of significant aspects and FMEA score does not need to dictate the final output of this process. So it is the management team and EMS that should make final determination of significance and great care should be taken to avoid the Type 1 – Unfocused EMS.

Please leave a comment to let us know what you think!!

Please contact EHS Management Strategies, LLC (www.ISO14001-Training.com) with any questions on your aspects identification and significance evaluation process.  We can help make your EMS work for you


.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001 | Tagged , , | 1 Comment

EPA TRI Reporting – Activity thresholds for chemicals prepared one year and distributed the following year

A facility processes pipes, stores them for the remainder of the reporting year, and then ships them off site the following year to be distributed in commerce.  Are TRI chemicals in the pipes that were prepared but not actually distributed during the reporting year considered to be processed for threshold determination purposes?

For purposes of the EPCRA §313 TRI threshold determination, amounts of a TRI chemical prepared for distribution in commerce are considered processed in the year that they undergo the processing step.  Therefore, even though the pipes were not distributed into commerce until the following reporting year, the chemicals in the pipes would be counted towards the processing threshold for the year in which they were prepared for distribution.


.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in EHS Compliance, EPA | Tagged , , | Leave a comment

What is “Management of Change”?

Although it is often used as a term of art in the safety field, “management of change” is not a defined term in OHSAS 18001:2007.  It is, however; vital to an effective OH&S management system.

Explicit requirements for management of change were added into section 4.3.1 of OHSAS 18001 in the 2007 revision of the standard.  This addition was an explicit request of the American Industrial Hygiene Association for purposes of aligning OHSAS 18001 with the U.S. Occupational Health and Safety Management System standard – ANSI/AIHA Z10-2005.  In addition, management of change is also an explicit requirement for safety management systems implemented to comply with the Seveso II Directive (see Annex III of EU Council Directive 96/82/EC).

The following requirements related to management of change were added in section 4.3.1:

The procedures for hazard identification and risk assessment shall take into account:

g) changes or proposed changes in the organization, its activities or materials; h) modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes and activities;…. For the management of change, the organization shall identify the OH&S hazards and risks associated with changes in the organization, the OH&S management system or its activities, prior to the introduction of such changes. 

In addition, reference to Management of Change was also included in section 4.4.6:

The organization shall determine those operations and activities that are associated with the identified hazard(s) where the implementation of controls is necessary to manage the OH&S risk(s). This shall include the management of change (see 4.3.1).

These new requirements cover four important concepts:

  • Identification of the hazards associated with “change”
  • Assessment of the risks associated with “change”
  • Consideration of OH&S hazards and risks prior to the introduction of the “change”
  • Implementation of the controls needed to address the hazards and risks associated with the “change”

For purposes of management of change within an OH&S management system, the changes that need to be addressed include:

  • Organizational changes (e.g. personnel or staffing changes)
  • Activity changes (e.g. changes to processes, equipment, infrastructure, software)
  • Material changes (e.g. new chemicals, packaging)
  • Changes to the OH&S management system (e.g. procedures)


Why is management of change so important?

Ineffective management of change is one of the leading causes of serious incidents.  To quote the U.S. Chemical Safety and Hazard Investigation Board (CSB), “In industry, as elsewhere, change often brings progress.  But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.” (from CSB press release announcing its 8/28/2001 Safety Bulletin concerning “Management of Change”)  Ineffective management of change is one of the major contributing factors in many of the incident investigations conducted by the CSB.  To check it out, go to the CSB web site at http://www.csb.gov  and enter “management of change” as your search term at the link “Search this Site.”

.

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in OHSAS 18001 | Tagged , , | Leave a comment

IRCA CERTIFIED COMBINED EMS & OH&SMS AUDITOR/LEAD AUDITOR BASED ON ISO 14001 & OHSAS 18001 TRAINING CLASS

COURSE OVERVIEW

Combined EMS and OH&SMS Auditor/Lead Auditor course, based on ISO 14001 and OHSAS 18001 teaches students the principles, processes, and techniques used for the assessment of and management of:

  1. Occupational Health and Safety Hazards, Risks and Controls; and
  2. Environmental aspects and impacts; and
  3. Their significance for EMS and OHSMS auditors.

Experienced instructors guide students through the role of an Auditor in planning, conducting, reporting, and following up an audit (in accordance with ISO 19011:2011; ISO/IEC 17021:2011 and ISO/IEC TR 17022:2012 by interpreting the requirements of ISO 14001/18001.

IRCA COURSE CERTIFICATION (A17613)

This course meets the training requirements for individuals seeking registration as an Auditor/Lead Auditor under both the IRCA and RABQSA EMS and OH&SMS Auditor Certification Schemes.

Contact us to get registered at (616) 666-5490 or James.Charles@iso14001-training.com.

———————————————————————————————————

DETAILED COURSE BREAKDOWN

This course is a 48 hour/6 day course.

Course Start: 08:00a.m & Course Finish: 18:00p.m

Evening study will be required as part of this course. It is recommended that all delegates attending treat the course as residential.

A detailed course breakdown is as follows:

Day 1

  1. Accreditation and Certification/Registration
  2. International Environmental Management System Standard ISO 14001:2004
  3. International Occupational Health and Safety Management System Standard OHSAS 18001:2007
  4. Document Management Systems

Day 2

  1. Statutory and Regulatory and Other Requirements Framework
  2. Incident Management, Emergency Preparedness, Crisis Management
  3. Processes and techniques used for the assessment of Environmental Aspects/Impacts and significance and Occupational Health and Safety Hazards, Risk, and Controls
  4. Environmental Aspects/ Impacts and Significance Assessment
  5. Occupational Health and Safety Hazards, Risk and Controls Assessment


Day 3

  1. Introduction to Auditing
  2. Auditor Competence, Roles and Responsibilities and Performance
  3. Initiating the Audit and Preparing for the on-site activities
  4. Developing an Audit Plan/Scope
  5. Developing Audit Protocols/Checklists
  6. Conducting on-site audit activities
  7. Opening Meeting

Day 4

  1. Review of Case Study
  2. EMS Simulated audit Interviews based upon EMS case study
  3. OHMS simulated audit interviews based upon OHSMS case study

Day 5

  1. Audit Findings
  2. Writing Audit Findings including classification
  3. Audit Reporting
  4. Writing the Audit Report / Completing the Audit
  5. Evaluating Corrective and Preventive Actions including audit finding closure
  6. Audit Follow-Up Strategies

Day 6

  1. Analyzing the audit Findings
  2. Final Audit Team Meeting
  3. Closing/Exit Meeting
  4. Course Summary/Continuous Assessment Report
  5. Examination Instructions
  6. Completion of IRCA EMS Examination
  7. Completion of IRCA OHSMS Examination

——————————————————————————————————-

 .

Share and Enjoy:
  • LinkedIn
  • Facebook
  • Twitter
  • Yahoo! Buzz
  • RSS
  • email
Posted in ISO 14001, OHSAS 18001, Supply Chain | Leave a comment