Overview and pep-talk
There’s a lot to accomplish on an annual basis to simply maintain or “stay” in EPA and OSHA compliance. There is even more if you are starting at square one. But as you are well aware, staying in compliance is a vital part of being in business in the U.S. today. That’s why we are going to step you through how to eat this Regulatory Elephant… ONE BITE AT A TIME.
Since many of the EPA related reporting requirements are loaded on the front end of the year (mostly March and April) and the preparation time to do it correctly can be extensive, our monthly plan will reflect a heavier focus on EPA related issues in the first three months and heavier on the OSHA issues after that.
We (E&SSG) have been fortunate to provide a wide selection of EH&S online, consulting and occupational health services to thousands of companies over the past 17 years. Therefore, we provide links, from time to time, to those services that have proven to help many others in the past. While we would love the opportunity to serve you in that fusion, however, there is absolutely no obligation for you to do so. The Regulatory Reminder is a totally FREE service that we know will help you keep your business compliant.
The bottom line is that If you stay diligent and follow this monthly plan, you will have the EPA and OSHA EssentialsTM in place and up-to-date by the end of the year. So if you are starting at square one, filling in your missing pieces or just maintaining your compliance programs, the Regulatory Reminder Monthly Focus will be a very helpful plan for you to decrease your environmental/safety exposure and provide a safer workplace for your employees.
This month’s focus
Don’t be scared, it seems like a lot but it’s mostly planning and getting prepared for the months ahead. Time to get started:
OSHA Recordkeeping- Listed above in the upcoming deadlines are the links and information to what you need to do to comply. Heads up! OSHA’s on the “warpath” on this one (
read article), therefore we strongly suggest that you watch our FREE video below if you are not familiar with or if you need a refresher course on how to accurately record and report work-related fatalities, injuries and illnesses. Also included with the video is instruction on how to perform accident investigation and the forms to do it.
SARA Title III, Emergency Planning and Community Right-to-Know Act (EPCRA)- Listed above in the upcoming deadlines are the links and information to what you need to do to comply. We also have a fairly easy way for you to determine if this regulation affects you on the
Tier II page of our website.
Even though the deadline to file Tier II’s isn’t until March 1st, we recommend that you start gathering now your current chemical inventory (MSDS) and the maximum amounts that you had or will have at any given time throughout the year. Keep in mind that the main purpose of this section is so that state and local Emergency Planning Committees can prepare for any possible emergency response action. Therefore, when gathering your maximum amounts on any given day, a worst case scenario is best. For example, if you had a 55 gallon drum of a certain product and when that drum was half empty a new drum was ordered, then the maximum you have of that product at any given time is 1.5 drums or approximately 82.50 gallons. The container type and area stored in your facility will also be needed for all those products that contain chemicals requiring a Tier II.
Completing the above process this month allows you the time, over the next two months, to sift through the chemical constituents that comprise your products (MSDS), find the ones that are listed on the EPA Extremely Hazardous List (EHS) list, and aggregate them to determine if they exceed the EPA’s Threshold Planning Quantities (TPQ). We’ll discuss this process more in depth next month.
Annual / Biennial Hazardous Waste Reporting- Listed above in the upcoming deadlines are the links and information to what you need to do to comply. Most companies know where they stand in regards to their waste. We suggest gathering your waste manifest and other information in preparation for your reports.
Semi-annual Reports for Air Emissions Inventory (AEI) Reporting- The deadline for AEI reporting for Title V Major and Minor Source facilities varies by state and possibly your individual permit. However, it appears that if your permit requires semi-annual reporting, those reports are typically due by Jan. 31 and Jul. 31. For facilities that require only the AEI annual report, it is typically due by April 1. We will discuss the Air Permitting and AEI reporting more in the next issue and we presume that if your facility has an air permit, you are most likely very aware of your deadlines. EPA is getting very serious about permit violators (
read article “EPA unleashes its cops to target these 10 trouble spots).
If you’re looking for the easiest way to track your air permit
click here.
Schedule your Audiometric Testing and/or Respiratory Fit Tests- January is a great time to look at your calendar and schedule your employee’s annual hearing tests and/or respirator fit tests. This doesn’t take much time and is good to get it out of the way and worry about the details later. Since most companies don’t perform this testing in-house, they hire a mobile testing company to conduct the testing. By scheduling early, this will allow you to secure your most desirable date(s) with your vendor.
This “focus” is primarily for those of you that know you are required to do either annual hearing or respirator fit tests. We will be covering the Hearing Conservation as well as the Respiratory Protection requirements later this year. However, if you would like to get ahead of the game and look into if your company is required, or you would like to check out our onsite mobile testing services
click here.
Apology
Sorry about the plugs… just tryin’ to pay the bills :) Now more FREE stuff!
Tools to help you comply
Click below to view a FREE training video that will show you how to properly fill out your OSHA 300 logs and perform accident investigations. You will want download and print the PDF forms below prior to watching the video.