CTI EHS Blog

Over the past year, OSHA has been acting under a National Emphasis Program (NEP) to address combustible dust hazards at facilities. This NEP identifies the industries where combustible dust may be present and establishes an inspection schedule for these facilities. In August 2009, OSHA will issue an Advanced Notice of Proposed Rulemaking for combustible dust hazards where the Administration will begin evaluating the regulatory methods for reducing the hazards from combustible dust.

This means that combustible dust regulations will be in the works, and when they are issued, facilities will be required to adhere to them. Though the rules have not yet been written, it is important to note that OSHA is currently issuing citations for combustible dust hazards at facilities. These fines are being issued under the General Duty Clause, which requires employers to provide a workplace that is free of hazards likely to cause serious injury or death. To avoid costly citations and prevent fires and explosions, it is important that your facility identify and eliminate combustible dust hazards. This means conducting a hazard analysis, developing a combustible dust safety program, conducting employee training, and installing fire prevention and protection where needed.

CTI Combustible Dust Services

Posted by Brian Edwards at 09:50 AM | Permalink

It is that time of year again. Reporting year 2008 Form R (or Form A) reports as required by Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) are due by July 1, 2009.

The new EPA administration has stated that it will increase its focus on enforcement, and EPCRA violations are near the top of the list. In fact, several of our clients in Region IV have been visited by EPA inspectors conducting EPCRA spot-checks. If your facility has not submitted these yet for reporting year 2008, make sure that someone is working on it. Any facility that manufactures, processes, or otherwise uses a Section 313 chemical in quantities over the reporting threshold is required to submit a Form R to the EPA and state agency each year that they meet the reporting threshold.

CTI Reporting Services

Posted by Brian Edwards at 09:43 AM | Permalink