The National Fire Protection Association (NFPA) is an organization tasked with developing and maintaining fire protection and life safety standards in the United States and worldwide. In addition to subjects such as sprinkler design, flammable liquid storage, and emergency exit requirements, NFPA has standards that deal specifically with combustible dust; a topic that CTI has been focused on for over a decade. There are several NFPA Standards that address combustible dust: NFPA 652 – Standard on the Fundamentals of Combustible Dust, is the overarching standard that applies to all facilities, and there are also several commodity-specific dust standards (e.g. 61 for agricultural and food, 664 for wood products, 484 for metals). CTI is a principal member of the NFPA 61 Technical Committee for Agricultural Dust and has worked with several of the other committees. All of these standards are changing, and CTI is here to help our clients understand what that will mean for them. Continue reading “Changes to Combustible Dust Standards”
Come say hello to Adam Haroz, one of CTI’s Engineering Managers, as he will be speaking at this year’s Region IV VPPPA Conference in Chattanooga, TN on June 19th.
Adam Haroz will be discussing how the regulations governing industrial machinery have shifted the need for conducting risk assessments on robotic systems from a good practice to now a mandatory requirement. The discussion will emphasize the benefits of conducting an on-site risk assessment. It will also highlight the need to identify the hazards and assess the potential risks associated with robot operations when selecting and designing safeguarding measures. He will review the methodology for conducting a risk assessment for different robotic systems, as well as other industrial equipment, how to assess the adequacy of current safeguards, and methods for determining the risk reduction measures required.
The Voluntary Protection Program (VPP) is designed to encourage cooperative efforts between employees, management and OSHA for the purpose of improving workplace safety and health. The VPP concept recognizes that workplace safety and health can be enforced in a compliance atmosphere and can be enhanced in a cooperative atmosphere. OSHA recognizes and partners with worksites that demonstrate excellence in Safety and Health.
Region IV VPPPA is the region that serves the eight Southeast states. (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee)
For more information on the VPPA or to register for the Region IV VPPA Conference click the following link: http://www.regionivvppconference.com/
On November 25, 2018, the National Fire Protection Agency (NFPA) issued an updated version of NFPA 45 – Standard on Fire Protection for Laboratories Using Chemicals. NFPA 45 includes information regarding fire protection requirements for laboratories, laboratory design, vent hood use, and safe quantities of flammable materials allowed to be stored and used in the laboratories. The 2019 edition of the standard includes minor changes from the previous 2015 version. Inspection, testing, and maintenance of fire-extinguishing systems in ductwork and chemical fume hoods has been revised from a specific time interval to a schedule that is deemed suitable for the type of system. Also, a minimum inspection frequency of 1 year has been added for chemical storage. The revision of the standard includes references to NFPA 30 – Flammable and Combustible Liquids Code for quantities of flammable and combustible liquids within liquid storage areas that are indoors.Continue reading “Is Your Laboratory Compliant with OSHA and NFPA Requirements?”
On December 12, 2018, the Occupational Safety and Health Administration (OSHA) began to enforce compliance with the updated Beryllium Rule that went into effect on May 20, 2017. The purpose of this updated Rule is to limit employee exposure to beryllium, which is known to cause lung cancer and other chronic beryllium disease. Continue reading “Updates to the OSHA Beryllium Standard”
On January 17, 2017, The Occupational Safety and Health Administration (OSHA) updated their Walking-Working Surfaces and Fall Protection standards. While most of the changes to the rule have already been put into effect, several provisions have delayed effective dates, many of which are coming up soon. Is your facility ready to comply with these new rule changes? Continue reading “Is Your Facility Ready For The Updated OSHA Ladder Rules?”
Changes to EPA “Once In Always In” Policy for MACT Rules
On January 25th 2018, the EPA released a guidance memo reversing the “Once in Always in” (OIAI) policy regarding the classification of major source facilities subject to MACT (Maximum Achievable Control Technology) standards. A major source is defined as any facility which emits at least 10 tons of any Hazardous Air Pollutant (HAP), or 25 tons of any combination of HAPs. This policy, which has been in place since 1995, stated that any major source that becomes subject to a MACT rule must stay in compliance with that rule permanently, even if the facility finds a way to drop emissions below major source thresholds. Continue reading “Federal, State, and Local Changes to Air Permitting Requirements”
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”
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.
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.