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Imagine you are installing a new process line at your facility, and a building addition to house that line. During the construction and installation, along with your employees, you may have a general contractor on site to oversee the project, subcontractors to do the wiring and other specialized work, additional subcontractors to assist the construction or demolition of the surrounding area, temporary workers to clear the land, venders on site to tell you how great their equipment is, and maybe even some visitors from corporate. With these companies and workers walking and working on your property at any given time, how do you know who is responsible for preventing injuries and accidents? And, in case there is an injury or illness, who has failed to provide a safe workplace and is not compliant with OSHA requirements? Continue reading “To Record or Not to Record: Responsibilities on a multi-employer worksite”

Over the past several decades, the Occupational Safety and Health Administration (OSHA) as well as the National Fire Protection Association (NFPA) have been expanding and enforcing regulations and standards designed to lessen the potential for disasters in facilities that handle combustible dusts. Any facility that processes or handles combustible solids or dusts, such as food products, wood, plastics, and metals should take preventative measures in identifying and managing the potential fire and explosion hazards present during normal operations at an industrial facility. A catastrophic incident of a facility failing to properly identify and mitigate the hazards associated with handling combustible dust is the explosion at the Imperial Sugar factory in east Georgia back in 2008. This combustible dust explosion killed 13 people and injured 40 more. This accident was entirely avoidable. Continue reading “Combustible Dust Regulation Updates”

In November of 2016, the Environmental Protection Agency (EPA) published its final rule on hazardous waste generator requirements. This rule provides guidance and best management practices (BMPs) for all levels of hazardous waste generators. This article will explore some of the changes in requirements for hazardous waste generators with the passage of the new rule. Continue reading “Changes to Hazardous Waste Generator Regulations”

OSHA is now requiring employers to submit OSHA 300A information online.

The Occupational Safety and Health Administration (OSHA) has set up its new Injury Tracking Application (ITA). The online form allows employers to submit the injury and illness information from their completed 2016 OSHA 300A form.

According to the rule, establishments with 250 or more employees must electronically submit data from their OSHA 300, 300A, and 301 forms annually.

Establishments with 20 to 249 employees in industries that OSHA has deemed highly hazardous must submit information from their 300A form annually. (OSHA’s list of highly hazardous industries can be found here).

The data that is submitted, according to OSHA, will be made readily available to the public on OSHA.gov. OSHA’s goal for the transparency in employer injury and illness data is to encourage employers to improve their efforts for preventing occupational injuries and illnesses and to also allow industry groups and researchers to use the disclosed data to advance workplace safety.

The deadline for covered employers to submit their data is December 1, 2017.

See the table below for establishment guidelines and upcoming submission requirements:

To submit your injury and illness information online, go to the ITA page on OSHA’s website here.

The US EPA mailed the ICR by registered mail to 391 facilities in the PCWP industry that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering National Emission Standards for Hazardous Air Pollutants (NESHAP) applicability.

 Recipients are asked to complete the ICR by February 9, 2018.

Continue reading “The EPA Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) Was Mailed by the EPA and is Due February 9, 2018”

The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), for the “Plywood Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP) Risk  and Technology Review (RTR)” (Kiln MACT) to the office of Management and Budget (OMB) for preview and approval.

This Kiln MACT applies to every sawmill that is a Major Source or Synthetic Minor Source for Hazardous Air Pollutants (HAP).

The ICR will be sent to all known operators of PCWP facilities that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering NESHAP applicability. The information collection seeks to collect facility-level information (e.g. facility name, location, contact information, and process unit details), emissions information, compliance data, control information, and descriptions of technological innovations.

The EPA will either establish an emission limit or work practices in order to minimize emissions for process units included in the PCWP MACT source category. Capturing, controlling, and the measurements of kiln emissions is not feasible. Installing emissions capture and add-on control equipment for VOC/HAP removal have not been identified. It is therefore predicted that facilities will choose to use work practice requirements in lieu of emission limits.

The purpose of work practices is to minimize HAP emissions. For most kiln schedules, the HAP emissions increase near the end of the drying cycle when the wood reaches its final moisture content. HAP emissions increase as the moisture content decreases.

If you operate a lumber kiln, you will need to develop a plan for minimizing HAP emissions from the lumber kiln(s) by minimizing the annual average variability in dried lumber moisture content. Plans must be required to be submitted to the appropriate regulatory agency with your Notice of Compliance Status and you will need to maintain appropriate records of compliance with the work practices.

Changes in kiln operating temperatures can significantly affect mill operations and drying capacity. Lower kiln temperatures result in longer drying times. This is a production and capacity issue for mills. A mill operating four lumber kilns at full capacity at 225OF would have to add two more lumber kilns to dry the same amount of lumber at 180OF. To overcome the potential Kiln MACT limitation, facilities will need to prepare a compliance work practice plan that minimizes emissions with the least affect to drying production.

Shortly Major Source and Synthetic Minor Source of HAPs will receive an ICR survey. You will have 120 days after ICR mailout to submit it. CTI is experienced in this area in assisting many lumber mills in the permitting process that includes most of the information requested in the survey. CTI also has assisted facilities with ICR for other regulations in the past.

Upon receipt of the ICR, feel free to contact us for a proposal to assist you to prepare it. If you have any questions or need additional information, please contact us.

After two rounds of public comments, the final version of Georgia’s General Multi-Sector Industrial Storm Water Permit (GAR050000) renewal has been issued. The permit will become effective on June 1, 2017. Covered industrial facilities will need to meet the following compliance deadlines:

All NOI’s and Annual Reports must now be submitted via Georgia EPD’s Online System (GEOS). Below are links to the final permit and to the GEOS website. If you have any questions or need assistance with submitting an NOI or updating or developing your SWPPP, please contact us.

New Georgia Multi-Sector Industrial Stormwater Permit – http://epd.georgia.gov/sites/epd.georgia.gov/files/related_files/site_page/FinalSigned2017IGP-20170306.pdf

GEOS Website – http://epd.georgia.gov/geos/

Georgia EPD’s NPDES Industrial Storm Water General Permits website – http://epd.georgia.gov/npdes-industrial-storm-water-general-permits

With the end of 2016 came many things. Of course we say hello to 2017, but we also start this year with a new President of the United States and many new members of our government. Under President Obama, a number of regulatory initiatives were achieved, including a rule on crystalline silica, an electronic submission of injury/illness data, and an increase in penalties from OSHA citations. The election of now President Donald Trump brings questions of what 2017 will bring for industry, employers, and the occupational safety and health policies and regulations across the board. I will go over what OSHA has published as its plans going forward in 2017, without the unknowns of a new administration. Keep in mind that some items may be moved on aggressively by OSHA before the new administration has time to step in and negate them. Continue reading “What to Expect from OSHA in 2017”