Regulatory Reminder

May 2010 Edition


Welcome to the May edition of E&SSG’s Regulatory Reminder!

In this month’s edition:

  1. Upcoming EPA deadlines
  2. Monthly regulatory focus to keep your year on track

Upcoming deadlines


These “Regulatory Reminders” are designed to alert you to federally mandated deadlines and to help you determine if your state has any of its own deadlines for which your facility needs to comply. All regulations have (or had) an initial deadline for companies and facilities to execute. However, only a few have annual or other deadlines.

 Topic  Brief Overview  Deadline  Links
EPA

EPA
Toxic Release Inventory (TRI) Reporting (SARA, 313)


Facilities that manufacture process or otherwise use Section 313 chemicals must submit this report annually to the EPA. The TRI report outlines all activities including any releases, emissions or discharges from the site that may contain Section 313 Chemicals.

TRI reports due July 1st of each year based on the previous year’s inventory amounts.

EPA’s Online TRI Thresholds Determination Tutorial

Laws and Regs

TRI Program home page

TRI Reporting Materials and Guidance

Basic Info

FAQ






Monthly Focus


Overview and pep-talk


Can you believe it? If you’ve been following our program you have been able to mark 14 items off of your compliance to-do list, and in the process you have drastically decreased your environmental/safety exposure and provided a safer workplace for your employees. Whatever your goal, we’re here to help you every step of the way.

There’s no time to stop now, let’s keep taking bites out of this beast.


New focus Items


Toxic Release Inventory (TRI) Reporting (SARA, 313) -Listed above in the upcoming deadlines are the links and information to what you need to do to comply. If you aren’t 100% sure, we strongly recommend that you determine if your facility meets the requirements by going through the EPA’s Online TRI Thresholds Determination Tutorial.

Even though the deadline to file your TRI isn’t until July 1st , we recommend that you start now gathering your chemical inventory (MSDS) that contain any of the Specific Toxic Chemical Listings and your 2009 annual quantities for those products.

Completing the above process this month allows you the time, over the next two months, to access EPA’s TRI-MEweb and go through the process to file you TRI reports.

NOTE: If you are one of our Chemical Inventory Analysis clients, you already have a list of all the TRI candidates present at your facility; therefore, you can skip the data gathering process and go straight to the reporting process.

Sample page from E&SSG’s Chemical Inventory Analysis TRI candidate list present at your facility.



Hazard Communication Program 


The purpose of the Hazard Communication Program is to inform employees about hazardous substances in the workplace, potential harmful effects of these substances and appropriate control measures. The primary tools of this program are warning labels, MSDSs and employee training.

The Hazard Communication standard is a performance standard. That means you have the ability to adapt the rule to the needs of your workplace, rather than having to follow a specific set of requirements. It also means that you have the responsibility to implement an appropriate and effective program.

Employers that "use" hazardous chemicals must have a program to ensure the information is provided to exposed employees. "Use" means to package, handle, react, or transfer. This is an intentionally broad scope, and includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.

The requirements of the rule that deal specifically with the hazard communication program are found in the standard in paragraphs (e), written hazard communication programs; (f), labels and other forms of warning; (g), material safety data sheets; and (h), employee information and training. The requirements of these paragraphs should be the focus of your attention. Concentrate on becoming familiar with them, using paragraphs (b), scope and application, and (c), definitions, as references when needed to help explain the provisions.

  • A Chemical Inventory List (CIL), a list of all hazardous substances in the workplace - The list may be compiled for the workplace as a whole or for individual work areas and can serve as a checklist to ensure that all hazardous substances in the workplace have MSDSs and labels.
  • A completed MSDS for each hazardous material listed/used in the workplace - The MSDS contains useful information on the nature of the hazards and how to use, store, and dispose of the material. It also describes what protective measures to take while using the material and what first aid measures to follow if an exposure to the substance occurs. MSDSs must contain all of the sections required by the standard and be readily available to employees.
  • Methods for employee training and awareness - listed below
  • Labels and hazard warning information - Employers are required to use legible labels and other forms of warning to clearly and quickly communicate what’s in a container, its hazards, the safety precautions, and the name and address of the manufacturer. Labels and other forms of warning are to be conspicuously placed on containers so that the message is readily visible. Labels should not be removed and, if torn or defaced, they must be replaced.


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…Now back to Hazcom



Hazard Communication Training - Employees must receive training on the Hazard Communication program requirements including its location and availability, the identification and location of hazardous substances, and how to read and understand MSDSs. Training must be done at the time of initial work assignment or when a new material is introduced. Training must be appropriate in content and vocabulary for the education, literacy, and language comprehension level of the employee(s).
Train your employees on:

  • An overview of the requirements contained in 1910.1200 - Hazard Communication Rule
  • Chemicals (any element, chemical compound or mixture of elements and/or compounds) present in their workplace operations
  • Location and availability of the written hazard communication program
  • Physical and health effects of the hazardous chemicals
  • Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area
  • How to reduce or prevent exposure to these hazardous chemicals through use of control/work practices and personal protective equipment
  • Steps the facility has taken to reduce or prevent exposure to these chemicals
  • Safety emergency procedures to follow if the employee is exposed to these chemicals
  • How to read labels and review MSDSs to obtain appropriate hazard information




Can’t pull large groups of employees off the line to train? Take a minute to watch how you could be training..
Safety U Online Training

Hazard Communication
Content Sample
(1 min. 30 sec.)


That’s it for this month. Until next time, have a safe month! If you ever need some help, give us a call.

(800) 770-7767

We hope you found it helpful and informative. We welcome all of your comments, suggestions and any corrections that you see we need to make. All are very important to us, so if you have any… please let us know.

NEW: If we use your comment in an advertisement or on our website or implement your suggestion or correction. We will send you a Free E&SSG T-shirt to show our appreciation for your effort.







Regulatory Reminder Input



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