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The first International Standard Organization (ISO) 14001, Environmental Management System (EMS) document was published in 1996 to provide a standard basis for all voluntary EMS’s to be certified as compliant systems by third party auditors. ISO14001 has since been revised twice, in 2004 and 2015, to make it more comprehensive and useful. In the newest revision, organizations and facilities can be certified under the 2004 standard for three years from the publication of the 2015 document. Therefore, organizations that wish to receive certification with ISO14001 have until September 2018 to update their EMS’s to be compliant with the 2015 revision. Continue reading “ISO-14001: Updating Your Environmental Management System”

One environmental reporting requirement that is often overlooked, but enforced regularly by the Environmental Protection Agency (EPA), the Georgia Environmental Protection Division (GA EPD), and other state agencies is Tier II Reporting under the Superfund Amendments and Recovery Act (SARA).

If your facility stores any chemical or product on site that requires a Safety Data Sheet (SDS) (e.g. petroleum products, grains, paints, lead-acid batteries, liquid oxygen, etc.) in amounts over 10,000 pounds, your facility is required to notify the state, your local emergency planning committee, and the local fire department of these materials on an annual basis. Additionally, if you store any extremely hazardous substances (e.g. sulfuric acid) above its reportable quantity, usually 500 or 1,000 pounds, your facility is also required to report under the SARA Tier II requirements. The annual deadline to submit Tier II reports is March 1.

If you would like assistance determining whether or not your facility is required to report under the SARA Tier II requirements, or need assistance completing the reports, please give me a call at (770) 363-6330, x.113 or email me at jhaar@conversiontechnology.com.

Assessing risk has always played a vital role in the development and implementation of industrial machinery. Industrial robots, in particular, and other machinery are evolving, and therefore so are the needs and regulatory requirements for the identification and understanding of the risks involved in working with these machines. Thanks to the passage and enforcement of regulations governing the use of industrial machinery by organizations such as the Robotic Industry Association (RIA), Occupational Safety and Health Administration (OSHA), the American National Standards Institute (ANSI), and the International Organization for Standards (ISO), conducting risk assessments on robotic systems and other machinery are not just good practices, they are mandatory. Continue reading “Risk Assessment Methodology for Robots and Other Machines”

The US Environmental Protection Agency (EPA) has proposed to issue an Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP), also known as the “PCWP MACT” or “Kiln MACT”. This is an important update for those in the lumber industry, as lumber drying kilns are one of the sources regulated under the standard. While the PCWP NESHAP covers many types of process units, this discussion will be primarily focused on the standard’s effect on sawmills operating lumber drying kilns.

 What is the history of the rule? Continue reading “EPA Proposes Collection of Information for “Kiln MACT””

The US Environmental Protection Agency (EPA) has issued a final rule to revise the Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program. The update contains over 60 revisions and will be effective May 30, 2017. One of the EPA’s objectives of the revisions is to reorganize the regulations to make them more user-friendly and easier to understand for generators. The revisions also include changes that address gaps in existing regulations, provide more flexibility for generators to mange hazardous waste, and make technical corrections. 

Below is a list of some the program changes: Continue reading “EPA Issues Changes to RCRA Hazardous Waste Generator Rule”

The publication of the new ISO 45001 Standard, Occupational Health and Safety Management System, is once again being delayed. While the drafting committee has processed several thousand comments from the first draft already, another meeting is being scheduled for February 2017 to discuss and review the remaining comments.  Once all of the comments have been reviewed, the committee is expected to publish the new standard by the end of 2017 or early 2018. With the additional time the finalization of the ISO 45001 standard is being delayed, companies now have more time to prepare and implement any programs and changes for the new requirements. Stay tuned for more information on the finalization of this standard.

EPA is working on the Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP). The comment period for preparing the ICR ended on November 7, 2016. This is the MACT standard commonly referred to as the Kiln MACT as it will apply to lumber drying kilns in some fashion, in addition to plywood and composite wood products. Continue reading “EPA Information Request for Kiln MACT Standard (40 CFR 63 Subpart DDDD)”

Most industrial facilities are required to maintain a Storm Water Pollution Prevention Plan (SWPPP) in order to minimize the discharge of pollutants from the property. The U.S. Environmental Protection Agency (US EPA) releases a Multi-Sector General Permit every five years that the majority of states model their permits after. These 6 steps are important for maintaining a compliant SWPPP in most states:

Continue reading “7 Routine Steps to Comply with Industrial Storm Water Pollution Prevention Plan Requirements”

swq_sdt1Under the Georgia Industrial Storm Water Permit, all covered facilities are required to conduct a smoke, dye, or equivalent test of all floor drains and sinks in industrial areas. These tests are to ensure that these sinks and floor drains do not discharge to storm water conveyances, and must be conducted by the end of the permit, May 31, 2017.

Continue reading “Have You Conducted Your Smoke and Dye Test?”

Pursuant to Executive Order (EO) 13650 “Improving Chemical Facility Safety and Security”, OSHA was directed to modernize their Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 CFR 1910.119). OSHA has issued potential revisions to the standard and convened a Small Business Advocacy Review (SBAR) Panel earlier this year. The Small Business Regulatory Enforcement Fairness Act (SBREFA) Panels were conducted back in June 2016, with the completed report placed in the federal docket on August 1, 2016.

Continue reading “OSHA to Modernize the PSM Standard”