The US Environmental Protection Agency (USEPA) and US Army Core of Engineers (USACE) have issued a revised regulation to define what qualifies as Waters of the United States (WOTUS), and this will become effective on August 28, 2015. The new definition is an attempt by the USEPA and USACE to determine their jurisdictional limits in what has become an ambiguous regulatory framework thanks to two Supreme Court cases in 2001 and 2006.

The new definition will not: Continue reading “Waters of the United States”

Earlier this week, NFPA published the Second Draft Meeting Minutes for the next edition of NFPA 664 – Standard for the Prevention of Fires and Explosions in Wood Processing and Wood Working Facilities.  This meeting was held in Atlanta on July 14-15, and I was in attendance both days. For those of you in the wood products industry in North America, this is the go-to guide to fire protection.  This meeting was to discuss the 2017 Edition of 664, which, contrary to its name, is scheduled to be released in Fall of 2016. Continue reading “NFPA 664 (Wood Products) Revision Update”

The EPA’s Risk Management Plan (RMP) regulation (40 CFR Part 68) was issued in multiple stages, beginning in 1994. The regulation was modeled after OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119). The RMP regulation is about reducing chemical risk at the local level. The information from the RMP aids local fire, police, and emergency response personnel in responding to chemical accidents. It also helps citizens to understand the chemical hazards in their communities. The regulation has been left relatively unchanged since its issuance.

Under the regulation, companies of all sizes that use listed regulated flammable and toxic substances above threshold quantities are required to develop a Risk Management Plan and submit the plan to the EPA every 5 years. The RMP must include: Continue reading “Modernizing the Risk Management Plan (RMP) Regulation”

Today, during the Technical Meeting at NFPA’s 2015 Annual Conference, there were two certified motions up for a vote related to the new NFPA Standard on Fundamentals of Combustible Dust – NFPA 652.  One motion was to remove the requirement for a Dust Hazard Analysis, and the other was to delay the issuance of the Standard completely.  Both motions were defeated by an overwhelming majority of the NFPA voting members, including myself. These votes were the last hurdle in the issuance of the Standard later this year.

NFPA 652 is the first step in developing a single, overarching standard to deal with fire and explosion hazards associated with combustible dust of all types and in all industries.  Currently, there are several industry and commodity specific standards, such as NFPA 61 for agricultural dust and 664 for wood dust, that often lack consistency, leading to confusion among users, authorities having jurisdiction (e.g. OSHA), and safety professionals. The development of NFPA 652 intends to alleviate some of the confusion … eventually. Over the coming months, CTI will be writing articles, providing presentations at conferences and online, and consulting our clients with the specifics of the standard.  If you are interested in staying in touch with these developments and other news, please email cti@conversiontechnology.com and ask to be included on our Newsletter list.

As of January 1st, 2015, the updated standards for injury & illness reporting officially came into effect. There are some slight changes to the standard that affect a large number of employers.

Under the old rule, employers were required to notify OSHA only of workplace fatalities or if three or more employees had to go to the hospital due to workplace injury or illness. According to the updated standard, employers must notify OSHA of the following: Continue reading “OSHA’s New Incident Reporting Requirements”

The new Globally Harmonized System (GHS) is upon us. OSHA, with help from the U.N. and global community, has updated the HazCom Standard in an effort to standardize and simplify the communication of chemical hazards. Before this new system, a worker handling drums of flammable material from different manufacturers could notice an array of different warning labels. One manufacturer could have labeled the material as “Flammable”, while another could have labeled it as “Extremely Flammable” or even “Caution Flammable Vapors”. The material is all the same, but now there is confusion as to the level of the hazard present. It is for this reason why the GHS is here.

Continue reading “OSHA GHS Deadline Approaching Fast…Are You Ready?”

Sources are required to submit a Notification of Compliance Status regarding the initial tune-up by July 19, 2012. 

On March 13, 2012, the EPA issued a No Action Assurance (NAA), stating that it would not enforce the Notification. The NAA states that it remains in effect until either (1) October 1, 2012, or (2) A final rule addressing the proposed reconsideration of the Area Source Boiler Rule, whichever occurs earlier.

On July 18, 2012, EPA extended the NAA for Boiler Area Source to December 31, 2012, or until the final rule is issued whichever occurs earlier.

For more information visit www.boilermactcompliance.com.