Preventing the Most Common Materials Handling Injuries Posted on December 03, 2013 by Joel Gregier
For many US workers, handling and storing materials in the workplace is an every-day job responsibility. “Materials handling” takes place in a number of ways and involves operations including, but not limited to:
- Working cranes to move heavy objects,
- Utilizing fork lifts to transport loads,
- Stacking and storing bulky items like drums or lumber,
- Feeding raw materials into manufacturing units, and
- Manually lifting and carrying items like heavy boxes or bulky bags in the workplace.
These types of daily activities are critical to general industry. When performed incorrectly, though, these tasks can cause injuries, sometimes serious ones.
Injury Frequencies for Materials Handling and Storing
The US Department of Labor collects information on workplace injuries and makes that data available to the public. According to its most recent statistics, over 15% of injuries that require days away from work or restricted or transferred duties (DART) are caused by overexertion in lifting or lowering.
Causes of Injuries Involving Handling and Storage
According to the Bureau of Labor Statistics, over 50% of all DART injuries are soft-tissue damage (sprains, strains, tears, soreness, and bruises). Common causes of soft-tissue injuries include lifting objects that are too heavy, are too bulky, or have their weight unevenly distributed. During the lifting process, employees may bend, twist, or turn their bodies in ways that result in injury. It is critical to train employees on proper lifting techniques to prevent these types of injuries.
Protect your workforce with expert OSHA training from Lion Technology. Convenient and effective, OSHA online courses are available 24/7 and can be completed at your employees’ own pace. From comprehensive 10-hour training to courses on material handling and storage, fall protection, electrical safety, hearing conservation, and more, you will find a complete list of training at www.Lion.com.
New RCRA Exclusion for Solvent-contaminated Wipes Posted on November 26, 2013 by James Griffin
On July 31, 2013, at 78 FR 46448, the United States Environmental Protection Agency (EPA) promulgated a new final rule to relax hazardous waste management requirements for solvent-contaminated wipes (i.e., shop towels). Solvent-contaminated wipes that are laundered will be conditionally excluded from regulation as solid waste. Solvent-contaminated wipes that are discarded will be conditionally excluded from regulation as hazardous waste.
This rule comes after several years of consultation between the EPA and the regulated community. The purpose of this final rule is to provide a consistent regulatory framework appropriate to the level of risk posed by solvent-contaminated wipes. The aim is to protect human health and the environment, while reducing overall compliance costs. The rule will become effective at the Federal level on January 31, 2014. However, in most states and territories the exclusion will not become effective until the local waste management agency takes steps to formally adopt it.
Wipes contaminated with a solvent are one of the most common forms of waste in industrial sectors. They are used for cleaning and other purposes in industries from auto manufacture and repair to chemical processing, electronics, printing, furniture, and many others.
The EPA estimates tens of thousands of facilities use wipes as some part of their process, facilities that can benefit from this rulemaking. Managing contaminated wipes as non-hazardous waste can help facilities reduce the transport and disposal costs otherwise associated with having the wipes treated and disposed of as hazardous waste. Taking advantage of this exclusion will help minimize the amount of hazardous waste generated at a facility, which may in turn help reduce the facility’s generator status.
What Exactly Will Be Excluded
The solvent-contaminated wipe exclusions will apply to wipes that contain one or more of the solvents designated as hazardous waste in 40 CFR 261, Subpart C or D, specifically:
- The spent solvent descriptions F001 through F005 at 40 CFR 261.31 (e.g., spent acetone or spent benzene); or
- The corresponding P or U lists found at 40 CFR 261.33 (e.g., unused acetone or unused benzene).
The exclusion will also apply to:
- Wipes that exhibit a hazardous waste characteristic resulting from any of the before-mentioned solvents, or
- Wipes that exhibit a hazardous waste characteristic of ignitability when containing one or more non-listed solvents (e.g., isopropyl alcohol or ethanol).
Restrictions to the New Exclusion
There are a few restrictions to the exclusion. Wipes that contain or are contaminated with solvents other than those listed in F001–F005 or the P and U lists are not eligible for exclusion. Likewise, wipes that exhibit a hazardous waste characteristic (toxicity, corrosivity, reactivity, ignitibility) due to non-listed solvents or non-solvent contaminants (i.e., oil, metal shavings, etc.) are also not eligible for exclusion. Lastly, trichloroethylene will not be afforded the exclusion in disposable wipes.
Managing Your Contaminated Wipes on Site
Whether the wipes will be laundered or discarded, the new exclusions are conditional. This means that in order to qualify for the exclusion the generator must manage the wipes in a sound manner before reuse or disposal.
The wipes may be accumulated for up to 180 days regardless of the facility’s hazardous waste generator status, and the wipes will have to be stored and transported in non-leaking, closed containers that contain no free liquids. Additionally, containers will need to be labeled with the words “Excluded Solvent-Contaminated Wipes.”
Lastly, generators must maintain documentation that includes the name and address of the laundry, dry cleaner, landfill, or combustor to which they send the wipes; some type of record to indicate that they complied with the 180-day time limit; and a description of the process used to determine there are no free liquids in the wipes.
Update your RCRA certification for 2014 with expert hazardous waste management training from Lion Technology. Learn the latest US EPA hazardous waste management regulations to keep your facility safe and in compliance, including new RCRA rulemakings and industry best practices. Presented in convenient locations nationwide, the Hazardous/Toxic Waste Management Workshop and the Advanced Hazardous Waste Management Workshop for experienced RCRA personnel, both satisfy the EPA’s annual training requirement.
Classifying Marine Pollutants Posted on November 19, 2013 by Kathleen Caton
In addition to setting standards for the safe transport of explosives, compressed gases, acute poisons, various fire hazards, and biological and radioactive hazards, the US DOT’s Hazardous Materials Regulations also protect the long-term health of the public and the environment by regulating various substances that are hazardous to the air, water, and land. One of the primary categories of environmental hazardous substances are marine pollutants—substances that are toxic to aquatic life.
US vs. International Criteria for Marine Pollutants
The US DOT defines marine pollutants as materials that contain an elevated concentration of one or more of the chemicals listed in 49 CFR 172.101, Appendix B. For most materials the marine pollutant threshold is a 10% concentration of Appendix B chemicals. Others, known as “severe marine pollutants” (designated by the letters “PP” in Appendix B), are regulated at a 1% concentration.
The international authorities use a different set of criteria for marine pollutants. As codified by the International Maritime Organization in its Dangerous Goods Code, also known as the IMDG Code, a substance is a marine pollutant if it is toxic to the aquatic environment when evaluated by the test methods given in Chapter 2.9.3 of the IMDG Code.
Known and suspected marine pollutants are indicated by the symbol “P” in Column 4 of the Dangerous Goods List in Chapter 3.2 of the IMDG Code or in the MP column of the Code Index. When a substance’s effect on the aquatic environment is unknown, or when you are offering a mixture or solution that contains a designated marine pollutant, you must evaluate the material according to IMDG 2.9.3.
Shipping Marine Pollutants
When transported by vessel, marine pollutants are shipped in much the same way as other hazardous materials. Some additional rules apply, such as extra descriptions on shipping papers and marking requirements for packages. [49 CFR 172.203(l) and 172.322] Also, if a marine pollutant meets the criteria of Hazard Classes 1 through 8, it should be assigned to the appropriate hazard class. If not, then the material should be assigned to Class 9 Packing Group III unless there is a specific entry in Class 9 for the substance. When shipped by ground or air in the United States, marine pollutants require additional communications only when shipped in bulk packages. [49 CFR 171.4]
It is very important to understand the differences in classification in order to properly regulate a material that could pose a danger to an aquatic environment, while at the same time avoiding over-classification.
Ensure compliance with the International Maritime Organization’s rules for shipping hazmat by vessel at the Hazardous Materials Vessel Shipper Certification Webinar! Mandatory compliance with the IMDG Code, Amendment 36-12, begins on January 1, 2014. Don’t be caught off guard when the new rules go into effect.
The Advantages of the EPA’s Self-Audit Policy Posted on November 12, 2013 by James Griffin
The US Environmental Protection Agency has a system in place that allows you to reduce the civil penalty assessment for a violation of environmental protection regulations. Commonly referred to as the “Self-Audit Policy,” this system is officially titled “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations.”
Designed during the 1990s with input from the regulated community and the public, the policy rewards regulated facilities for bringing themselves into compliance with Federal environmental law and regulation. Since 1995, these incentives have led to the voluntary discovery, disclosure, and correction of numerous non-compliant conditions, allowing the US EPA to focus its investigation and enforcement efforts elsewhere.
How the Self-Audit Policy Works
If you discover your facility is in violation of any Federal environmental law, you can notify the EPA that you know you are in violation and take positive steps to correct the situation. Because you self-reported your noncompliance, the authorities may choose to forego most civil penalties and are less likely to enforce a mitigation action or other punitive measures.
If you identify a noncompliant condition at your facility and want to qualify for relief from possible civil penalties under the Audit Policy, you must comply with the following nine conditions:
- Implement a compliance management system or environmental auditing program to systematically discover noncompliance. (Even if you don’t have a systematic self-auditing system, you can still obtain some relief if you comply with the following conditions.)
- The noncompliant condition must have been discovered by means other than the monitoring, sampling, or inspection procedures required by law.
- The noncompliant condition must be disclosed to the US EPA promptly, generally within 21 days from the day of discovery.
- The noncompliant condition must be discovered, and disclosed, before the US EPA or other party with authority would have identified the violation through its own investigation.
- The condition must be corrected and/or remediated within 60 calendar days from the date of discovery; in limited cases this timeframe may be extended.
- The regulated entity must take steps to prevent a recurrence of the violation.
- Repeat violations are ineligible. No entity may obtain relief under the Audit Policy for actions that constitute a pattern of noncompliance.
- Certain types of violations are ineligible for relief under the Audit Policy. Generally, those that result in serious actual harm or present the potential for imminent danger are ineligible.
- Lastly, the regulated entity must cooperate with the authorities during the correction period.
Copies of the Audit policy, the Audit Protocols for each major regulatory program, and other important guidance documents can be found in the EPA’s library.
Ensure your facility is in compliance with the EPA regulations that apply to your operations at the
Complete Environmental Regulations Workshop. The workshop covers critical elements of the EPA’s major programs: from air and water permitting rules under the Clean Air and Clean Water Acts to chemical reporting responsibilities under TSCA, and much more. The workshop is an engaging, effective introduction to the environmental regulations for those new to EHS compliance and essential for those seeking ISO 14001 certification.
Do you have a self-audit system in place to make sure you stay in compliance with environmental regulation? Comment below.
The GHS Training Deadline Is Almost Here Posted on November 05, 2013 by Joel Gregier
By December 1st, all companies subject to OSHA’s Hazard Communication Standard (HazCom) must ensure that their employees are trained on the HazCom rules adopted from the Globally Harmonized System (GHS) for classifying and labeling chemicals. [29 CFR 1910.1200(j)(1)]
OSHA has always required employers to train employees on the dangerous chemicals they work with. But OSHA’s adoption of new rules from the GHS into its HazCom Standard added new criteria that workers need to be trained on.
The GHS is an international system for chemical classification, hazard labeling, and Safety Data Sheet (SDS) formatting. Full implementation of these GHS amendments is scheduled for June 1, 2015, but employees must learn to recognize, read, and understand new HazCom marks, labels, and documentation before the new standards become mandatory in the workplace. In order to ensure the approximately 40 million affected employees are prepared to protect themselves from the hazards in their workplace, OSHA mandated employee training be completed before December 1, 2013.
Who Needs Full or Update GHS Training?
New employees who work with hazardous chemicals need full HazCom training. The standards for the required training can be found at 29 CFR 1910.1200(h).
Those employees who have already received HazCom training in the past will not need to be retrained on all elements. Instead, they need update training explaining how the new GHS elements will affect their job duties.
Topics to Be Covered at a Minimum
At a minimum, employees will have to be brought up to speed on the new format for labels and SDSs. For labels, employees should understand the different components that make up a GHS label, such as signal words, pictograms, hazard statements, and precautionary statements. For example, see a sample of a GHS label for acetone on the right. For SDSs, employees will have to understand the new 16-section format, and what information is found in each of those sections.
GHS has also modified how chemicals are classified under HazCom. Most employees will not need to be trained on the technical details of how to classify a chemical. Although it is not explicitly required, it would be a good policy to brief employees on what new hazards are being regulated, such as combustible dusts and simple asphyxiants, and it may be necessary to remind employees of the other hazard classes since labels and SDSs are based on the chemical’s classification.
Make sure your employees are trained on OSHA’s revised HazCom Standard before the December 1, 2013 deadline! For managers in charge of overseeing a smooth transition to the revised standard, Lion Technology offers the Preparing for OSHA’s New GHS Rule Webinar, which covers how the new standards will affect your facility, important implementation deadlines, and what you must do to comply. For employee training on the updated standard, we also offer the Hazard Communication Online Course, available 24/7. This online course covers the newly adopted GHS criteria for classifying chemicals, marking and labeling hazards, and using 16-section Safety Data Sheets (SDSs) and is designed to satisfy OSHA’s hazard communication training requirement.
Scary Stories of Noncompliance Posted on October 29, 2013 by Joel Gregier
As Halloween approaches, you are probably hearing a lot of scary stories. You may enjoy these tales of terror, but if you are not careful with how you manage your facilities, you may find yourself in a scary story of your own.
Depending on what your company does, several government agencies may require you to comply with their regulations. For instance, the Occupational Safety and Health Administration (OSHA) has rules to protect workers in the workplace, the Environmental Protection Agency (EPA) has laws to keep the environment clean and unpolluted, and the Department of Transportation (DOT) has requirements to make sure hazardous materials are transported safely.
Skirting these regulations can cost your company big; some fines for regulatory noncompliance start in the hundreds of thousands of dollars. As scary as that sounds, some companies face fines in the millions of dollars. Many industry professionals would rather face Freddy Krueger than a seven-figure penalty.
Below are just a few examples of some enforcement actions that occurred within the past few months. Turn off the lights, grab your flashlight, and prepare to be terrified!
$8.75 Million Penalty for Failure to Comply With the CAA
In September, a Texas refinery was hit with a chilling $8.75 million dollar fine for failing to comply with the terms of a 2007 settlement that resolved alleged violations of the Clean Air Act (CAA). The original settlement required the company to pay a $2.9 million penalty and upgrade its facility to reduce emissions of harmful air pollution. However, the company failed to perform those corrective actions, and is now facing the consequences. This is a good lesson; you cannot just ignore the problem and hope it goes away.
San Antonio Agrees to Upgrade Sewer Systems for $1.1 Billion
In July, San Antonio, CA agreed to spend an approximate $1.1 billion to achieve compliance with Clean Water Act (CWA) standards. The city is upgrading its sewer systems in response to allegations that it was illegally discharging raw sewage. In addition to the upgrades, the city is required to pay $2.6 million in civil penalties to the EPA. This situation goes to show that if your facility is large, or even a major U.S. city, the fines can be downright blood-curdling.
OSHA Violations Lead to $1.1 Million Fine
The EPA is not the only agency that hands out hair-raising fines. In August, the Department of Labor doled out fines to an Ohio steel manufacturing plant that added up to $1,138,500. The company was cited for 24 violations, 15 of them willful violations of OSHA’s fall protection standards. According to OSHA, the company has a history of failing to address fall issues, which culminated in serious injuries for two workers in June and August. As you can see, purposefully avoiding compliance rules can really add up.
Refrigerated Food Warehouse Cited for 63 Safety Violations
This one will give you chills. A refrigerated food warehouse in Hawaii was fined $251,330 after an OSHA inspection uncovered 63 violations of worker health and safety regulations. Violations included blocked emergency exits and improper management of highly hazardous chemicals. “The employer’s shocking decision to seal exit doors and block emergency exit routes to gain additional storage space placed the workers in great jeopardy,” said Galen Lemke, director of OSHA’s Honolulu Area Office. By placing their workers in jeopardy with these unsafe conditions, the facility opened themselves up to a six-figure penalty.
Avoid a horror story at your facility. Ensure your team is prepared to meet any compliance challenge with effective training on the U.S. DOT hazmat shipping, EPA hazardous waste, and OSHA workplace safety regulations from Lion Technology. At www.Lion.com you can choose from nationwide public workshops, convenient 24/7 online courses, and live, instructor-led webinars for expertly designed training that fits your schedule.
Have a happy and safe Halloween!
Cutting Costs With Life Cycle Assessment Posted on October 22, 2013 by Roseanne Bottone
Life Cycle Assessment is a critical tool for organizations seeking ways to reduce their environmental impact, manage waste more efficiently, and reduce compliance costs. Also called life cycle analysis or “cradle-to-grave” analysis, a Life Cycle Assessment (LCA) is designed to gauge how a product will impact the environment throughout its life—from the initial sourcing of raw materials to eventual waste disposal.
By incorporating “life-cycle” thinking into standard operating procedures (SOPs), organizations can reduce overall costs related to inventory acquisition, waste generation and management, the off-site shipment of waste, and its treatment or disposal. Often, policies and procedures that bring together purchasing departments, manufacturing units, and hazardous waste management departments produce dramatic inventory savings and a reduction in waste-related spending and reduce negative environmental impacts resulting from wastewater discharges, dangerous air emissions, landfilling or incineration, and other treatments.
To perform an LCA, organizations should evaluate the chemicals and other materials they use through four major life-cycle phases:
- Use in manufacturing, maintenance, or R&D;
- Recycling processes; and
- Waste management, including on-site storage, off-site shipping, treatment, and/or disposal.
Procurement or Purchasing
By implementing a screening process to ensure purchasing requests are vetted, you can reduce the quantity of unused chemicals that become waste and consider substitutions that are less toxic. Always consider the “greener choice” when quality control specs allow for this option.
Manufacturing, Maintenance, or R & D
Look at your manufacturing/production processes, maintenance schedule and protocol, and laboratory practices to identify changes that you can make to minimize the volume and toxicity of waste generated.
Recycling and Reuse
For hazardous waste facilities operating under the 90-/180-/270-day rules, the recycling process itself is exempt from RCRA regulation. That also means that obtaining a RCRA permit is not necessary to recycle on site (State RCRA regulations may vary; see 40 CFR 261.6(c)). An added benefit is that recycled materials that are produced from recycling wastes that were already counted in the same month are not counted a second time when they become waste again (see 261.5(d)). In addition, the hazardous waste regulations provide a built-in relief for reusing materials in certain ways that exclude them from the definition of solid waste (see 40 CFR 261.2(e)).
“An ounce of prevention is worth a pound of cure”. The best scenario is to not generate the waste to begin with, but if it has been generated, then an aggressive recycling program (on- or off-site) is environmentally prudent.
Much of the costs associated with chemical management occur on the backend; it’s a problem many employees upstream are not aware of. Inventory management systems (e.g., bar codes, approvals, etc…), the creation of “haz marts” for the redistribution of still viable materials, charge-back policies (i.e., requiring departments using chemicals to pay for the off-site shipment, treatment, and disposal of their waste), periodic monitoring, reassessing SOPs, and incorporating these issues into your company-wide training classes are good management practices.
The following resources from the U.S. EPA may help you develop your LCA:
- The EPA’s National Risk Management Research Laboratory (NRMRL) maintains a guide to performing Life Cycle Assessment (LCA) on its website.
- The Comprehensive Procurement Guideline (CPG) program is part of EPA’s continuing effort to promote the use of materials recovered from solid waste. Buying recycled-content products ensures that the materials collected in recycling programs will be used again in the manufacture of new products. Currently, there are 61 products designated in eight categories.
- The National Waste Minimization Program “supports efforts that promote a more sustainable society, reduce the amounts of waste generated, and lower the toxicity and persistence of wastes that are generated.” The program focuses on reducing 31 priority chemicals found in products and wastes by addressing methods to eliminate or reduce their use by reclamation or reuse.
- EPA’s Design for the Environment Program “helps consumers, businesses, and institutional buyers identify cleaning and other products that perform well, are cost-effective, and are safer for the environment.”
Learn More Ways to Cut Costs
Learn more ways to streamline your operations, minimize the waste your facility generates, and lower costs at the Advanced Hazardous Waste Management Workshop. Designed for experienced hazardous waste managers, this two-day workshop satisfies the U.S. EPA’s annual training requirement and covers the critical RCRA rules for managing waste on site.
Lithium Batteries Make Frequently Cited Violations List Posted on October 15, 2013 by Roger Marks
In an October 2 Final Rule published in the Federal Register, the Pipeline and Hazardous Materials Safety Administration (PHMSA) added a number of lithium battery-related shipping mistakes to its list of Frequently Cited Violations. The unique hazards posed by lithium batteries caught the attention of regulators in part due to a growing number of uses for these batteries, an increase in shipping volume, and many improperly prepared or damaged battery shipments causing incidents in transit. The manager of compliance and enforcement at the Federal Aviation Administration has called lithium batteries “today’s greatest threat to aviation safety.”
The Frequently Cited Violations list, found at Appendix A to 49 CFR Part 107, Subpart D, lists common hazmat shipping violations under the Hazardous Materials Regulations (HMR) and provides a suggested baseline penalty amount for each based on the type and/or severity of the violation. While these baseline minimums are not mandated by the Act, inspectors often use these baselines as a guide when assessing penalties.
New, lithium battery-related entries to the DOT’s list of Frequently Cited Violations include:
|Offeror Requirements – All Hazardous Materials|
|Violation Description||Section or cite||Baseline assessment|
|A. Undeclared Shipments||172.200,172.300, 172.400,172.500|
|4. Offering for transportation a lithium battery, without shipping papers, package markings, labels, or placards (when required):|
|a. For air transport||$40,000|
|b. For ground transport||$20,000|
|E. Package Labeling Requirements|
|8. Failure to place a Cargo Aircraft Only label on a package containing a primary lithium battery or failure to mark a package containing a primary lithium battery as forbidden for transport on passenger aircraft:||172.402(c), 172.102(c)(1), Special Provision 188, 189, 190|
|a. For air transport||$10,000|
|b. For ground transport||$1,000|
|Offeror Requirements – Specific Hazardous Materials|
|Violation Description||Section or cite||Baseline assessment|
|F. Batteries||173.159,173.185, 173.21(c)|
|1. Offering lithium batteries in transportation that have not been tested:|
|a. Ground transport||$15,000|
|b. Air transport||$30,000|
|4. Offering lithium batteries in transportation that have not been protected against short circuit||$15,000|
|5. Offering lithium batteries in transportation in unauthorized packages||$12,500|
|7. Offering lithium batteries in transportation on passenger aircraft or misclassifying them for air transport||$30,000|
|8. Failure to prepare batteries so as to prevent damage in transit||$6,000|
In addition to adding a number of lithium battery violations to the Frequently Cited Violations list, this rulemaking also raises the baseline, or suggested minimum, penalty for many of the violations on the list. The DOT raised these baseline penalty amounts to account for inflation and the increase in maximum civil penalties for all hazmat violations under the Moving Ahead for Progress in the 21st Century Act (MAP-21) last year.
Other New Lithium Battery Rules
This rulemaking is the latest in a series of changes to the lithium battery shipping rules. In 2012, the International Civil Aviation Organization (ICAO) amended its Technical Instructions to partially regulate large shipments of small batteries by air. The U.S. DOT is currently moving forward with a rulemaking originally proposed in 2010 to address the risks of lithium batteries in transport, including enhanced packaging, hazard communication, and operational requirements for various types and sizes of lithium batteries. According to the Office of Management and Budget, a Final Rule is expected this November.
Learn the latest rules for lithium battery ground (49 CFR), air (IATA), and vessel (IMO) shipments at the Shipping Lithium Batteries Webinar on November 5! The live, instructor-led presentation covers critical rules for preparing lithium battery shipments to avoid incidents in transit, injury to personnel, and costly civil penalties. Prefer to train at your own pace? Lion’s Shipping Lithium Batteries Online Course is available 24/7 and provides general awareness, security awareness, and function-specific training for shipping personnel as required at 49 CFR 172.704
EPA Programs You May Not Know About Posted on October 08, 2013 by Anthony R. Cardno
Most Americans are familiar with flagship U.S. EPA’s programs like the Clean Air, Clean Water, and Safe Drinking Water Acts. EHS managers and industry professionals know that in addition to these high-profile programs, the EPA also regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA), chemical manufacturing under the Toxic Substances Control Act (TSCA), and pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
The EPA has also established regulatory programs that cover a bevy of industrial facilities, processes, and wastes. It is important that, whatever industry you are in, you are able to identify and comply with all the regulations that may affect your business, even the EPA rules you may not be aware of.
Nuclear Power Plant Operations
While many regulatory controls on nuclear power plants are promulgated and enforced by the Nuclear Regulatory Commission (NRC), the EPA sets its own limits on radiation doses and radioactive materials emitted into the environment. These annual limits, found at 40 CFR 190, Subpart B, affect operations that are part of the nuclear fuel cycle.
Spent Nuclear Fuel
Operations at nuclear waste disposal sites are regulated by the NRC and the Department of Energy. The EPA, which regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA), also sets standards for facilities that manage and dispose of spent nuclear fuel, high-level radioactive wastes, and transuranic radioactive wastes from nuclear fuel reactors. These standards are meant to limit the general public’s exposure to radioactive waste both in the short term (40 CFR 191, Subpart A) and the long term (40 CFR 191, Subpart B).
Radon Proficiency Programs
The Radon Measurement Proficiency (RMP) Program, which is voluntary, was established by EPA to assist states and the public in selecting qualified organizations to measure indoor radon levels. The Radon Contractor Proficiency (RCP) Program is also voluntary, developed to evaluate radon mitigation contractors and provide that information to the public. Although both programs are voluntary, radon remediation contractors and others who wish to participate must pay the fees established at 40 CFR 195.
In the Noise Control Act (NCA) of 1972, Congress declared that inadequately controlled noise presents a danger to the health and welfare of the public. While the primary responsibility for control of noise sits with State and local governments, the EPA has set regulations to control noise from commercial sources. 40 CFR 201 sets controls for noise generated by rail cars and non-steam locomotives, while 40 CFR 202 sets controls for noise from motor carriers (trucks with a gross weight rating ≥ 10,000 engaged in interstate commerce). Noise control requirements for motorcycles built in or after 1983 can be found in 40 CFR 205.
Although “hearing protection” is usually considered an OSHA concern, the NCA allows EPA to set labeling standards for hearing-protective devices to provide “accurate and understandable information … so that the public can make meaningful comparisons…” between products. [44 FR 56120, September 28, 1979]
Under the Marine Protection, Research and Sanctuaries Act of 1972, EPA has responsibility to “regulate the dumping of all types of materials into ocean waters and to prevent or strictly limit the dumping into ocean waters of any material which would adversely affect human health, welfare, or amenities, or the marine environment, ecological systems, or economic potentialities.” [33 U.S.C. 1401(b)] Most ocean dumping activities are prohibited, but it is still possible to obtain a permit from the EPA to dump, though the process is prohibitive.
Automobile Fuel Efficiency
Although the U.S. Department of Transportation’s National Highway Transportation Safety Administration (NHTSA) is responsible for establishing fuel economy standards for automobiles and light-duty trucks, the U.S. EPA calculates each car manufacturer’s “average fuel economy.” This calculation is essentially an average found by adding the fuel economy for each of a manufacturer’s cars and dividing by the number of cars built. [49 U.S.C. 32904(a)(1)]. EPA’s fuel economy regulations include specific technical standards, test methods, and calculations and are found at 40 CFR 600.
The U.S. EPA has more responsibilities than many people realize, and its regulatory reach affects facilities and workers in a broad range of industries. It is critical that EHS professionals can identify which programs affect their businesses and commit the resources needed to comply.
Learn the latest EPA rules at the Complete Environmental Regulations Workshop! The workshop covers crucial aspects of the Clean Air Act, Clean Water Act, TSCA, FIFRA, CERCLA/Superfund, and more and is essential for ISO 140001 certification.
Protect Your Employees from Machine Injuries Posted on October 01, 2013 by Joel Gregier
A Pennsylvania manufacturer faces a $61,600 fine for failing to have proper machine guarding on equipment, which led to a worker suffering a laceration injury. “Exposing workers to lacerations and possible amputation injuries by neglecting to ensure machine guarding is in place is unacceptable,” said OSHA Area Director Kim Nelson in Toledo. “Companies must be aware of the hazards that exist in their facilities and take all possible precautions to minimize the risk of injury.” (OSHA Press Release, 9/9/13)
In general, any machine that poses mechanical or physical hazards will require “guards” to provide a barrier of protection for the employees using the machine. Each guarding device should be designed to prevent the employee from having any part of his or her body in the danger zone of the machinery. Employers are responsible for identifying machine guarding hazard as required at 29 CFR 1910, Subpart O.
The employer must assess the workplace and identify machinery that could cause injury to any employee. [29 CFR 1910.212] One or more of the following could create a hazard to the machine operator and employees in the area of the machine:
- Point of operation
- Rotating parts
- In-going nip points
- Flying chips and sparks
Point of Operation
The point of operation is the area on the machine where the work is being performed on the material itself. Examples include cutting, shaping, boring, and forming operations.
See image on the right for an example of a point of operation.
Machinery with rotating motion can grip an employee’s clothing or by contact pull the employee into the machinery. Examples of rotating parts include collars, couplings, cams, clutches, flywheels, shafts, spindles, and meshing gears.
See image on the right for an example of a rotating part.
In-going Nip Points
These hazards are caused by rotating parts on machinery and are categorized into three types:
- Parts rotating in opposite directions (e.g., intermeshing gears, rolling mills, and calendars)
- Between rotating parts and tangentially moving parts (e.g., chain and sprocket, rack and pinion)
- Between rotating parts and fixed parts (e.g., spoked handwheels, screw conveyors, and grinding wheels)
See image on the right for an example of a nip point.
Flying Chips and Sparks
These operations have the potential to send particles toward the employee, resulting in burns, cuts, and other injuries. Examples include grinding, welding, sawing, and cutting operations.
See image on the right for an example of flying sparks.
Lion Technology offers convenient, easy-to-use OSHA online training available 24/7 to meet a number of training standards under 29 CFR, including the 10 Hour OSHA General Industry Online Course.