Final Comment Period for Indiana Stormwater Permit
In September 2024, the Indiana Department of Environmental Management (IDEM) issued a draft Industrial Stormwater General Permit (ISGP), which is open for public comment until November 19, 2024. Upon completion of the public notice period the new permit is expected to go into effect in 2025. The new permit requirements will be more stringent in terms of sampling frequency, pollutant benchmarks, inspections, and corrective actions.
For a new facility, within 30 days prior to the occurrence of any discharge a new permit application Notice of Intent (NOI) must be submitted. For facilities that have existing permit coverage, within 180 days following the effective date of the new permit the facility will need to take one of the following actions:
Submit a new NOI
Request to terminate permit coverage;
Notify IDEM of eligibility for an exclusion from permit coverage;
Submit an application for an individual permit.
All permitted facilities are required to continue to meet the conditions of the current Indiana Permit (as defined in 327 IAC 15-6) including sampling and inspection requirements until the new ISGP permit is issued sometime in 2025. If your current permit coverage is set to expire before the new ISGP permit is issued you still need to submit a renewal NOI to maintain that permit coverage.
We understand the new upcoming changes to the Indiana stormwater permit may feel daunting.
If you’d like to be informed of the finalization of these regulation and tips for compliance, please drop your email below, and we will be in touch. Feel free to contact us if you’d like
Upcoming Changes to Indiana Stormwater Permits
In alignment with other states and Federal permit guidelines, Indiana is making some big changes to its Stormwater General Permit. This draft permit is currently in public notice review until November 19, 2024. Upon completion of the public notice period, IDEM will be working to finalize the new permit early in 2025. A key change to the permit is the addition of “subsectors” based on industry SIC codes, creating variable requirements for facilities in differing industries.
We understand these changes may feel daunting. If you have any questions or would like assistance with stormwater reporting management, we’re here to help. Our turnkey services ensure you’re up to date with the latest regulations, submission details, and reporting deadlines.
If you’d like to be informed of the finalization of these regulation and tips for compliance, please drop your email below, and we will be in touch.
Here’s a look at high level changes you’ll see in the draft:
Changes to Inspection Requirements
Quarterly Routine Facility Inspections are still required, but now required to have at least once per year done during a period where stormwater discharge is occurring (i.e. when it’s raining)
Added Quarterly Visual Assessments for each outfall even if they are substantially similar.
Changes to Annual Report
First annual report due within 365 days of effective date of permit coverage. The annual report for years 2 through 5 is due within 365 days of the last report submitted.
Annual reports must now include summary of facility inspections, visual assessments, confirmation SWPPP is updated, confirmation of impaired waterbody review, sampling information and any correction actions.
Additional Changes
Non-stormwater discharges allowed under the permit,
Minor changes to Facility Layout requirements
Additions items to include in SWPPP
Changes to Notice of Intent
Annual fee structure has changed.
Lots of additional information is now needed as part of the NOI and they must be submitted electronically through the IDEM Regulatory Services Portal (RSP).
Within 180 days of the effective date of the new permit facilities must submit a new NOI, request a termination of permit coverage, request no exposure exclusion, or apply for individual permit. Subsequent renewals 5 years later are still due 90 days before general permit expires.
Changes to Stormwater Monitoring Requirements
All facilities must conduct stormwater monitoring for three “indicator benchmark parameters” (i.e. pH, Total Suspended Solids, Chemical Oxygen Demand)
Additional monitoring requirements is broken down by subsector and/or waterbody
pH measurement must still be taken at the time the grab sample is taken using a pH meter. Calibration records of the pH meter must be kept with the SWPPP (cannot rely on a lab to provide/maintain these records).
Changes to Stormwater Monitoring Reports
Discharge Monitoring Reports must be submitted online in NetDMR system
To stay up-to-date on these changes, drop your email address in the form above!
“What If?” : How to Ace Unexpected Inspections
“Hello, my name is Bill Hess, and I represent Cornerstone Environmental, Health and Safety. Who is your EHS representative here on site?”
There are a surprising number of places that I “cold call” in person where the front desk employee has no clue who the Environmental, Health, and Safety (EHS) person is or the responsibilities that position holds. If I were an OSHA or Environmental Regulatory Inspector, that person and the company would be off to a very bad start to their day.
In my role with Cornerstone as Manager of Business Development for our Northern Midwest Region for the past 25 years, I have probably visited and prospected over a thousand sites in person. These visits are often unannounced, and I fit them in between other scheduled meetings that I have. Given the turnover rates that many companies experience these days, it’s really no surprise that the front desk person does not know the key people in their organization. However, the front desk person (if there is one) or whoever answers the lobby phone should be well informed of who the facility EHS Manager is and know how to reach them.
In the case of regulatory inspections, it is critical to get off to a good start. First impressions can set the tone of the entire day. Facility management has a responsibility to coach gatekeepers with how to handle an unannounced inspection, and how to manage the inspector until the appropriate EHS person can arrive to meet them. Understanding the importance of this initial interaction is crucial. A respectful and knowledgeable greeting shows the inspector that your organization takes compliance seriously.
Your EHS Manager should also be instructed as to how to manage the inspection. Some simple guidelines include:
Be Cooperative. Throughout the inspection process, your attitude should be one of cooperation. If corrective actions can be taken care of during the inspection, then get it done by you or someone else who is capable.
Just answer the question. Do not elaborate, tell stories, or reveal anything but what is asked or needed. “Loose Lips Sink Ships” is still true in 2024.
Stay on the path. Many inspectors are curious about your operations, but you need to keep them on the path to where they want to go or for what they want to see. This does not need to be a full-day tour unless they state that it is a wall-to-wall inspection.
Monitor pictures. If the inspector takes photos, they may need your permission if it involves proprietary technology or materials. Be sure to take the same pictures they have taken for your own defense.
Take good notes. You may be paying attention to everything during the inspection, but the written report you get from the inspector may take weeks for them to complete. Your notes should match their notes, so don’t rely on your memory for details.
Closing Conference. Be sure to address any questions that you have or that the inspector has during the closing conference. If additional information is needed, establish a date for when it can be delivered to the inspector.
In summary, be prepared and organized. Getting off to a good start could make your day.
Mastering Health and Safety Risk Assessments in Industrial Environments
Ensuring health and safety in an industrial setting is paramount for the well-being of employees and the overall success of the business. This requires more than just a familiarity with compliance regulations; there must be an understanding of the risk associated with exposure to workplace hazards. I have visited many workplaces and observed many industrial processes and their associated hazards. I have had opportunities to conduct both compliance assessments and risk assessments. Through my experiences, I’ve noticed a gap in many safety professionals’ understanding of risk assessments and how to conduct them. This article will explain a simple approach to mastering health and safety risk assessments in industrial environments.
Understanding the Importance of Health and Safety Risk Assessments:
Risk assessment involves calculating the severity of potential outcomes from hazard exposure and the probability of their occurrence. Developing a risk matrix based on these factors helps visualize the level of risk, emphasizing the importance of not overlooking high risks. Regular risk assessments are key to preventing accidents, reducing liabilities, and boosting productivity. Here is an example of a risk matrix:
Key Components of a Health and Safety Risk Assessment:
The key components of a health and safety risk assessment involve hazard identification, risk evaluation, and risk control. When identifying hazards, various factors such as machinery, materials, processes, and human factors must be considered. When assessing risk, it is crucial to determine the type of injury or illness resulting from exposure to the hazard and evaluate the effectiveness of existing controls in mitigating the risk.
To illustrate, let's perform a hypothetical risk assessment on a table saw with an unguarded saw blade. The unguarded blade is identified as the hazard, with the severity of potential injury being finger amputation (i.e., Catastrophic [4]). The probability of contacting the blade is high due to its unguarded nature and frequent use (i.e., Probable [3]). Calculating the risk as 4 x 3 = 12 places it in the red portion of the risk matrix, indicating an unacceptable level of risk.
To address this, we must implement risk controls. Following the NIOSH hierarchy of controls, we prioritize engineering controls over elimination and substitution controls, as they are not feasible for our workplace. Implementing an engineering control such as a self-adjusting guard reduces the probability of injury. Upon reassessing the risk with the guard installed, the severity remains unchanged, but the probability is reduced (i.e., Improbable [1]). The calculated risk is 4 x 1 = 4, placing it in the tan portion of the risk matrix, signifying an acceptable level of risk.
Steps to Conducting Effective Risk Assessments
Preparation: Gather necessary information and resources.
Hazard Identification: Identify potential hazards in the workplace.
Risk Assessment: Evaluate the likelihood and severity of identified hazards.
Risk Control: Implement measures to eliminate or mitigate identified risks.
Review and Monitoring: Regularly review and update risk assessments to ensure ongoing effectiveness.
Common Challenges and Solutions:
Implementing workplace changes can face obstacles such as limited resources, expertise gaps, and resistance. Overcoming these challenges involves leaning on the NIOSH Hierarchy of Controls, emphasizing employee training, and nurturing a safety culture. Sharing success stories from real-world risk assessments can illustrate the approach's effectiveness and encourage its adoption.
Summary
Mastering health and safety risk assessments in industrial environments is vital for protecting workers and ensuring the sustainability of the company. Companies that are proactive in terms of risk management ensure workplace safety and compliance. I encourage you to prioritize regular risk assessments as an integral part of your health and safety management practices.
References
Department of Labor, Occupational Health and Safety Administration “Recommended Practices for Safety and Health Programs” https://www.osha.gov/safety-management/hazard-Identification
ANSI B11.0 / ANSI B11.19 / B11.TR3 Risk Assessment and Safeguarding of Machinery Package
From Report to Response: The Role of Tier II Data in Community Safety
Every year, businesses like manufacturers, warehouses, and other facilities that handle hazardous chemicals submit Tier II Reports. These reports provide vital information about chemical storage to state and local emergency response authorities, helping them prepare for potential incidents. As a consultant who assists in preparing and submitting these reports, I often find myself wondering: How is this information actually used by emergency personnel? Does the Tier II Report play a role in making our community safer?
To answer these questions, I reached out to the West Lafayette Fire Department and an Emergency Response Team (ERT) Chief at a large manufacturing facility. Through these conversations, I hoped to gain a better understanding of how local responders use Tier II data to protect our community.
Interview with the West Lafayette Fire Department
Q: Do you receive Tier II reports electronically or by mail?
A: Most of the Tier II reports are provided to us electronically, but we still see some come through in the (ground) mail. We also can access all the reports through the State (Department of Homeland Security website).
Q: What do you find most helpful in the Tier II reports?
A: We typically already have awareness about quantities of hazardous materials, water supply, and alarm information because of Pre-fire Plans. We visit every building in town every four years and collect a lot of information. We have new reporting software that we are still figuring out.
Q: Is the Tier II information on the new reporting software?
A: No, we access that (Tier II) information on the DHS website, but we plan to start adding the Tier II reports as attachments on our Pre-fire Plans.
Q: Do you think the facility layouts will be helpful?
A: Yes, our Pre-fire Plans have aerial views and information we collect on visits, but any additional information will be helpful.
Q: How does the technology work (on your new software)?
A: Every engine has a computer. The Battalion Chief acts in command when there is an emergency and runs the computer. The software provides them with a lot of information for decision-making.
Q: A lot of our clients report sulfuric acid found in forklift battery-operated equipment. How do you deal with this information in an emergency?
A: Forklift battery equipment is tricky because they are mobile and can be anywhere. We typically know where the charging areas are and then are prepared for acid spills afterward.
Q: Not exactly Tier II related (for this geographic area), but have you dealt with lithium batteries and fires associated with those?
A: Yes, we just had an electric scooter catch on fire this past month. We have a lot of concern about lithium batteries because you cannot put the fire out with water. Lithium batteries are becoming more prevalent and are in a lot of consumer items. We are being proactive and purchasing equipment to handle this type of fire.
I appreciate the insights shared by the West Lafayette Fire Department, highlighting the importance of Tier II data in emergency planning and response.
Interview with an ERT Commander
I also spoke with an ERT Commander, who explained how his team uses Tier II information and chemical inventories during their annual training exercises. The training, facilitated by the Fire Department, includes real on-site chemical scenarios to “test the system as much as possible.”
“In the spill training, we rely heavily on the SDS (safety data sheets) to figure out what the product is and how we should respond. So we simulate releases of known chemicals at the facility as part of our training,” he said.
It was encouraging to hear how emergency responders actively use the Tier II data to prepare for potential hazards at their facilities.
Conclusion
The insights gathered from these interviews underscore the importance of Tier II Reports in the hands of local emergency responders. While technology and accessibility continue to improve, ongoing collaboration and accurate reporting between businesses and emergency response teams remain crucial. By equipping emergency personnel with detailed, up-to-date chemical information, we can help ensure that our community is prepared to respond effectively in times of crisis.
Using AI In the Workplace
Artificial intelligence (AI) is a type of technology that allows computers and machines to mimic human thinking and problem-solving skills. It's like teaching a computer to think and act like a person! AI can do things that would normally require a human to do, like understanding language, recognizing things, making decisions, and even creating art. There are different kinds of AI, from simple ones that focus on specific tasks, like voice assistants like Siri or Alexa, to more complex ones many that are still being developed, which goals are to be as smart as humans. AI is becoming increasingly common in our daily lives, powering everything from self-driving cars to medical diagnoses. It's a rapidly evolving field with the potential to revolutionize many aspects of our world (IBM, 2024).
AI is like a super-smart computer brain that learns from a ton of info, kind of like cramming for an exam. It analyzes that info, spotting patterns to make educated guesses about new stuff. Imagine showing a chatbot tons of texts to teach it how to chat or feeding an image tool millions of pictures to help it recognize objects. Python and similar programming languages are the go-to tools for coding this new tech. But AI's not just about crunching numbers and data, it's getting creative too! It can make new images, music, and even come up with fresh ideas. And the best part? It's constantly learning and improving, just like we do as humans (Laskowski & Tucci, 2024).
Here are some tips for using AI safely at work:
Be mindful of data privacy: AI often relies on vast amounts of data to learn more information. When a user enters data into the AI, the AI will learn that data and will use it in the future.
Verify AI-generated information: While AI can be helpful, it's not foolproof. Always double-check information generated by AI systems, especially when making important decisions.
Be aware of potential biases: AI algorithms can sometimes reflect human biases present in training data. Be vigilant and critically assess AI-generated results to avoid perpetuating unfairness.
Keep your AI systems updated: Regular updates are essential to patch security vulnerabilities and ensure optimal performance of your AI tools.
Educate yourself and your colleagues: Understanding the capabilities and limitations of AI is crucial for responsible use. Invest in training to stay informed about best practices and emerging trends in AI.
Establish clear guidelines: Develop clear policies on how AI should be used in your workplace to maintain ethical standards and mitigate risks.
Sources:
IBM. (2024, March 19). What is Artificial Intelligence (AI)?. IBM. https://www.ibm.com/topics/artificial-intelligence
Laskowski, N., & Tucci, L. (2024, April 15). What is Artificial Intelligence (AI)? everything you need to know. Enterprise AI. https://www.techtarget.com/searchenterpriseai/definition/AI-Artificial-Intelligence
Raising Environmental Awareness: A Personal and Professional Journey
I was raised in a school. For my whole life, my mother has been an elementary school principal. I have fond memories of riding my bicycle and scooter up and down the school hallways during the early hours of the morning or late in the evening. I was eating elementary school breakfast in the early hours of weekday mornings before I even started Kindergarten. Some of the most influential people in my life have been educators. When I started to consider college, much to my mother’s surprise, I realized that I had no interest in pursuing traditional classroom education. Instead, I was passionate about animals and the environment and wanted to spend my career working outdoors and inspiring younger generations. I eventually decided to study Environmental Science in college, and through my studies, I discovered the field of environmental education. I have worked in various internships and jobs throughout my career including as an educator at an accredited zoo, a science center, and a research forest. I have taught environmental education topics to hundreds of children throughout the region and am passionate about introducing the future generations to environmental awareness and stewardship.
The term “environmental education” covers a wide range of programs and institutions, each with its own unique approach to promoting environmental awareness and sustainability. Examples of educational programs include camps, field trip programs at zoos and science centers, and forest schools, among many others. While there is no single definition of environmental education, the goal is to encourage individuals to become more informed and engaged in environmental issues and to take action to protect and preserve the natural world around us. Environmental education is important because it exposes children to topics they may have never heard of, helps them understand the problems facing our planet, and gives them age-appropriate skills to address these issues. It can also help to foster a love and appreciation for the natural world around them.
Although widely used in the environmental professional sphere for decades, the term “Environmental Literacy” began appearing within the realm of education in the 1990s. Environmental Literacy is “an individual’s understanding of how their actions and decisions affect the environment” (Environmental Education Association of Indiana, 2024).
In 1990, the EPA passed the National Environmental Education Act, and with it, established the Office of Environmental Education (OEE). The OEE supports environmental education programs throughout the country by providing professional development, educator and student recognition, and grants to fund environmental education programs. With the passing of the National Environmental Education Act, many states began to implement environmental education programs into state curriculums.
In 2008, the Environmental Education Association of Indiana developed the state’s Environmental Literacy Guidelines. These guidelines provide information to educators on environmental literacy competency areas and are a key step in Indiana’s effort to introduce environmental education in grades K-12. The goal of the environmental literacy program is to create an “Environmentally Literate Citizen”. This person “has the knowledge, tools, and balanced perspective to weigh various sides of environmental issues to make responsible decisions as individuals and as members of the community” (Environmental Education Association of Indiana, 2024).
Why should you care about environmental education exposure at a young age? When children are exposed to environmental education, they are more likely to grow into adults who are passionate and care about our environment. Laying a strong environmental foundation at a young age will help to create a robust and passionate EHS workforce in the decades to come. Although I never went into traditional classroom education, I consider my current work as an environmental consultant a form of education. My main objective is to educate professionals on environmental regulations and the most effective environmental management practices. Although it's often said that you can't teach an old dog new tricks, environmental education is something that should never be discontinued.
Many institutions throughout Indiana and the surrounding states offer support to educators and families in order to meet states’ environmental literacy benchmarks. Below is a list of several of the most well-known and robust environmental education programs in and near Indiana:
Indianapolis Zoo: https://www.indianapoliszoo.com/learn-explore/
Louisville Zoo: https://louisvillezoo.org/education/
Indianapolis Children’s Museum : https://www.childrensmuseum.org/educators
Indiana Department of Environmental Management: https://www.in.gov/idem/iee/
Environmental Education Association of Indiana: https://www.eeai.org/
Kentucky Association for Environmental Education: https://www.kaee.org/
Kentucky Science Center: https://kysciencecenter.org/education/classes-and-labs/
Marian University: https://www.marian.edu/about-marian/nina-mason-pulliam-ecolab/programs
Indiana DNR: https://www.in.gov/dnr/state-parks/programs/school-and-group-programs/
Sources:
Environmental Education Association of Indiana (n.d.). Environmental Literacy Guidelines. Retrieved February 16, 2024, from https://www.eeai.org/
Altered Reality’s Role in Transforming Environmental Health Services
In an era where technology intersects with every aspect of life, environmental health services stand on the brink of a significant transformation. Altered reality —encompassing both augmented (AR) reality and virtual reality (VR)—is poised to revolutionize how professionals and the public engage with environmental health issues. As the planet faces unprecedented environmental challenges, from climate change to pollution, innovative solutions are not just desirable—they are necessary.
The potential of AR and VR in environmental health is vast and varied. For professionals in the field, these technologies offer new avenues for education and training. Imagine, for instance, a VR simulation that immerses trainees in the aftermath of a chemical spill, teaching them how to respond safely and effectively without real-world risks.
Augmented reality technology could emerge as a critical ally in high-stakes scenarios. For example, AR-enabled helmets or goggles could enable firefighters to instantly receive detailed chemical information about the substances present within a facility, directly overlaying this vital data onto their real-world view of the site. This immediate access to information about flammable materials, toxic gases, and other hazardous chemicals could allow them to make informed decisions on the fly, ensuring they adopt the safest and most effective approach to controlling the fire and preventing environmental contamination.
The past decade has seen rapid advancements in AR and VR technologies, opening up a new world of possibilities in the environmental health and safety sector. By combining emergent technology with the current methods of maintaining and tracking environmental health, the field might see vast improvements in both safety and workflow. While the potential is exciting, only time will tell how it will affect the field of environmental health services.
Retro Rewind: How Did I Get Here?
This story starts in a magical place called The 90s when an optimistic, strong-willed 19-year-old packed up her belongings, her beloved Boston Terrier, and moved to Bloomington to complete her degree in Entrepreneurship.
I got lost riding my bike to my very first class in the basement of the Rec Center and showed up dumping sweat. I felt defeated after my first day and even worse as the semester went on. The School of Business was NOT my thing, and I could tell those in my classes were not my people (you know, the ones you’re told you’ll find when you leave home for college). So, I rounded out my first year at Indiana University, still staying the course with business as my major, and tried to fulfill my personal interests in subject matter through books.
Sidebar: To set the stage a bit better, this was the early 2000s, and while home internet was readily available on our personal computer (PC), it wasn’t as robust as we now regularly take for granted. I was carrying a Nokia 5120 phone, which was wildly cool because I could play ‘Snake’ on it.
Having always loved animals, I was drawn to a book titled Next of Kin: My Conversations with Chimpanzees, a remarkable story of Roger Fouts’ journey in human–chimpanzee communications through sign language.
I finished the book quickly, perched myself in front of my pressboard corner desk that held my PC, and opened my favorite search engine, askjeeves.com. I quickly located the website dedicated to this book and Fouts. I emailed the general information address on the page to ask how to get into the field of human-chimpanzee conversation! I was shocked when I received an email back directly from the AUTHOR! Feeling I’d won the World Wide Web, I eagerly absorbed Mr. Fouts’ words advising me to change my major to anthropology and take two semesters of sign language. Following a year of sign, I was encouraged to enlist in a summer internship at the Chimpanzee and Human Communication Institute on the campus of Central Washington University.
Sadly, I didn’t get the opportunity to attend. As it turned out, I was not at all interested in Anthropology (I was mostly just interested in finding out what secrets chimps held!). I did, however, sign up for a course in Wildlife Management that piqued my interest, and, as luck would have it, an engaging professor who encouraged me to enroll in other courses in Environmental Management.
I joined my peers at the (then) School of Public and Environmental Affairs and graduated with a Bachelor of Science in Environmental Management in 2004, when AOL Instant Messenger still existed but everyone preferred Yahoo Messenger because Chat Rooms, DUH.
With the ink on my diploma barely dry, I started an “intermittentship” (their word, not mine) at the Indiana Department of Natural Resources (DNR) as a Fisheries Aide. The good people at the State quickly realized I knew how to use the interwebs, so I was tasked with writing facts sheets on aquatic invasive species to publish on their website. After nearly a year with the DNR, my time was up, and I was forced into finding a real long-term position and start officially adulting.
*me circa 2007 on a job site in Plymouth, Indiana; before Carhartt had a women’s line (but I still wear this gem)
Sitting on the laminate flooring of my first home, I cried while reading my first rejection letter from a private environmental consulting company. I had my degree but no experience. Like every time before when my heart hurt, I called my parents (landline because it was 2006). My dad answered and, just like every time before, he had a solution. Through my father’s professional network, I was granted an interview with another environmental consultant in Indianapolis for a field position doing Environmental Site Assessments (Phase I ESAs), soil surveys, and indoor air quality assessments. My manager would later tell me that he hired me because I went to IU (his alma mater), and I had a great personality that he knew would fit in with his team.
While I am no longer with that company or in the field, I’m grateful every day that he gave me a chance to shine so that 11 years later, I could find my way to Cornerstone in a role supporting clients with EHS and sustainability goals.
Discharge Monitoring Reports: No Discharge vs No Sample Taken
Stormwater monitoring requirements vary with each permit; therefore, monitoring may or may not be required for your facility. If stormwater samples are required, samples must be collected at each outfall representing the facility's discharge. The stormwater permit will indicate what type of monitoring is required, along with the frequency and submission of any monitoring data.
A Discharge Monitoring Report (DMR) contains the results of stormwater monitoring. The stormwater permit will outline how monitoring data needs to be submitted and the due dates for DMRs. Permittees are encouraged to sample early in the monitoring period in case the opportunity is not available later. Permittees can collect a stormwater sample and submit DMRs prior to the due date; however, extension and/or late reports are typically not allowed past the end of the monitoring period.
What happens if you don’t collect a stormwater sample during the monitoring period? You must still submit a DMR and mark the report as either “No Discharge” or “No Sample Taken.” What’s the difference? One is a legitimate reason the sample was not taken, and the other is not following the stormwater regulations.
Maybe it didn’t rain that much during the monitoring period, or your site is designed to hold water and there was no discharge at your outfall. In that case, you can submit the DMR as “No Discharge,” indicating there are no discharges that occurred during the monitoring period. Additional documentation will need to be submitted with the DMR and can include inspections, photographs, and precipitation information (e.g., rain logs) indicating there was no opportunity to collect the sample at any time during the entire monitoring period in which a sample could be taken (i.e., no measurable storm events occurred during the monitoring period or if there was a measurable storm event no discharge occurred).
What if you just forgot to take the sample, or there was no one qualified/trained to take the sample? If you cannot collect and report the stormwater sample, you must submit the DMR as "No Sample Taken.” You must also add comments to the DMR to explain the missing data. It is the permittee’s responsibility to ensure that there is a trained/qualified person to oversee the stormwater requirements. Permittees must emphasize to employees the importance of stormwater sampling and ensure the stormwater training program is up to date, conducted annually, and repeated more often if there are new employees.
The only time you can report “No Discharge” is when there has actually not been any discharge. A “No Discharge” report cannot be used if your facility was discharging stormwater but you were sick, out on vacation, busy, or just simply forgot to collect the sample. It’s not technically correct to report “No Discharge” if there, in fact, was a discharge. In many instances, severe enforcement actions occur because of incorrect reporting.
Stormwater permits require self-monitoring, and the regulatory authorities place the responsibility on you as the permittee to follow the regulations and take the stormwater samples within each monitoring period. If the facility fails to take a stormwater sample within the set monitoring period and therefore reports a DMR as “No Sample Taken,” this indicates a failure to comply with the permit conditions and, therefore, will likely result in a permit violation. The violation created for submitting as “No Sample Taken” is less significant than not submitting a DMR at all. Failure to submit a DMR creates a significant violation, which puts the facility on certain lists that can lead to enforcement.
DMRs will require the responsible official to “acknowledge” reported violations and missing fields prior to being signed and submitted. Therefore, it is important that the signatory authority review the DMR to verify that all required information has been successfully entered and submitted.
Need help with your stormwater permit program? Cornerstone EHS has been involved in helping facilities get and stay in compliance with stormwater permits across the United States since our founding in 1995. Our qualified professionals know the ins and outs of stormwater regulations and can help you. Contact us today.
An Important Letter From Our President
To Our Valued Customers,
"Change is the only constant in life. One’s ability to adapt to those changes will determine your success in life.” - Benjamin Franklin
As Cornerstone is now well into our 29th year of business, constant change and adaptation in serving our customers has helped us endure. With that in mind, I’m excited to share a bit of news that will allow us to extend our growth for many more years to come. Cornerstone is merging with Foresight Management, a leading sustainability and energy management firm. This partnership expands our range of compliance services and tools by incorporating Foresight’s expertise in providing comprehensive sustainability solutions.
Headquartered in Grand Rapids, Michigan, Foresight Management is dedicated to championing energy management, accelerating sustainability, and increasing profitability for its clients. Over the years, we have had the opportunity to collaborate with Foresight, getting to know their people, their values, and their work. While we could not have predicted where things would lead, it was clear from the start that Cornerstone and Foresight were a great team. We could not have imagined a better partner.
We believe this collaboration creates a distinctive platform of services to assist our clients in addressing the market and regulatory challenges they are facing. With our background in EHS compliance and Foresight’s expertise in sustainability, clean energy, and decarbonization, we can offer a truly unique suite of tools to help tackle those pressures. For you, our clients, this means that we can support you with an extended list of services, knowledge, and experience.
Through this merger, rest assured that the qualities you love about Cornerstone will remain unchanged. Your point of contact, your favorite expert, and the professional services you rely on will remain consistent, but now we have the resources to significantly broaden the scope of work that we deliver to you and your facilities.
In this ever-changing world, we believe this merger will further reinforce our commitment to providing the highest quality service possible. We would like to thank you for your continued support and partnership and for the ongoing opportunity to be of service to your business.
Sincerely,
Mark Miller
President
Cornerstone Environmental, Health and Safety, Inc.
EPA Finalizes National Primary Drinking Water Regulation for Certain PFAS
On April 10, 2024, EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS.
On April 10, 2024, EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS. To inform the final rule, EPA evaluated over 120,000 comments submitted by the public on the rule proposal, as well as considered input received during multiple consultations and stakeholder engagement activities held both prior to and following the proposed rule. EPA expects that over many years the final rule will prevent PFAS exposure in drinking water for approximately 100 million people, prevent thousands of deaths, and reduce tens of thousands of serious PFAS-attributable illnesses.
EPA is also making unprecedented funding available to help ensure that all people have clean and safe water. In addition to today’s final rule, $1 billion in newly available through the Bipartisan Infrastructure Law to help states and territories implement PFAS testing and treatment at public water systems and to help owners of private wells address PFAS contamination.
EPA finalized a National Primary Drinking Water Regulation (NPDWR) establishing legally enforceable levels, called Maximum Contaminant Levels (MCLs), for six PFAS in drinking water. PFOA, PFOS, PFHxS, PFNA, and HFPO-DA as contaminants with individual MCLs, and PFAS mixtures containing at least two or more of PFHxS, PFNA, HFPO-DA, and PFBS using a Hazard Index MCL to account for the combined and co-occurring levels of these PFAS in drinking water. EPA also finalized health-based, non-enforceable Maximum Contaminant Level Goals (MCLGs) for these PFAS.
The final rule requires:
Public water systems must monitor for these PFAS and have three years to complete initial monitoring (by 2027), followed by ongoing compliance monitoring. Water systems must also provide the public with information on the levels of these PFAS in their drinking water beginning in 2027.
Public water systems have five years (by 2029) to implement solutions that reduce these PFAS if monitoring shows that drinking water levels exceed these MCLs.
Beginning in five years (2029), public water systems that have PFAS in drinking water which violates one or more of these MCLs must take action to reduce levels of these PFAS in their drinking water and must provide notification to the public of the violation.
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News Update: SEC Adopts Rules to Enhance and Standardize Climate-Related Disclosures for Investors
UPDATE, April 5, 2024
The Securities and Exchange Commission (SEC) has delayed the implementation of its climate-related disclosure rule in response to legal challenges from two fracking companies and various business groups. This decision awaits the judgment of the U.S. Court of Appeals for the Eighth Circuit on the appeals. Despite this, the SEC continues to assert its authority to mandate public companies to disclose their climate-related risks to investors and is prepared to defend the rule's validity in court. The stay temporarily halts the rule, which would first apply to large accelerated filers for fiscal years beginning in 2025, with other companies following at least a year later. Legal experts recommend companies continue preparing for compliance, while the appeals process could extend over months or years.
Washington D.C., March 6, 2024
The Securities and Exchange Commission today adopted rules to enhance and standardize climate-related disclosures by public companies and in public offerings. The final rules reflect the Commission’s efforts to respond to investors’ demand for more consistent, comparable, and reliable information about the financial effects of climate-related risks on a registrant’s operations and how it manages those risks while balancing concerns about mitigating the associated costs of the rules.
The adopting release is published on SEC.gov and will be published in the Federal Register. The final rules will become effective 60 days following publication of the adopting release in the Federal Register, and compliance dates for the rules will be phased in for all registrants, with the compliance date dependent on the registrant’s filer status.
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Combating Burnout: Key Strategies for a Healthier Workplace
Exploring the shadowy impact of workplace stress, this article delves into how pervasive job-related burnout threatens personal well-being and dampens productivity and communication. Discover essential strategies for employers to foster a supporti...
Workplace stress is a significant yet often overlooked safety risk that can impact a number of people. According to research by the American Institute of Stress, 83% of workers in the United States experience stress related to their jobs.1 Workplace stress causes, on average, 120,000 deaths each year.2 This stress doesn't just impact personal well-being; it also undermines job performance, productivity, and interpersonal communication.
There are many different causes of workplace stress. Concerns about job security, such as the fear of reduced hours or layoffs, can weigh on employees. Similarly, taking on additional responsibilities without adequate support or feeling unable to take sufficient breaks can increase stress levels. A significant stressor for many is being unable to maintain a healthy work-life balance, especially if there is an expectation to respond to work-related emails and answer work calls during personal time.
While the list of stressors extends beyond these examples, the collective impact can significantly affect your overall well-being. Fortunately, there are steps employers can take to alleviate workplace stress. A survey conducted by the American Psychological Association in 2021 revealed that over 87% of employees believe employers can help alleviate stress by offering flexible work hours, promoting the use of PTO, or encouraging employees to take regular breaks throughout the day.3 These proactive measures not only improve employee satisfaction but also foster a healthier and more productive work environment. The World Health Organization estimates that for every dollar an employer spends on mental health concerns, they receive a return of four dollars.1 Investing in mental health support benefits individuals and produces a return for employers, highlighting the importance of employee well-being in the workplace.
When we are stressed, fatigued, or mentally unwell, our ability to perform tasks safely and effectively is decreased. By addressing mental health concerns and providing support, employers promote a healthier work environment and enhance overall safety. Take some time to see what kinds of support your workplace offers.
1 World Health Organization. “Mental Health at Work.” 2022. https://www.who.int/teams/mental-health-and-substance-use/promotion-prevention/mental-health-in-the-workplace.
2 Goh, J., Pfeffer, J., & Zenios, S. A. “The relationship between workplace stressors and mortality and health costs in the United States.” March 13, 2015. Management Science, 62(2), 608-628
3 American Psychological Association. “Vacation Time Recharges US Workers, but Positive Effects Vanish within Days, New Survey Finds.” June 27, 2018. https://www.apa.org/news/press/releases/2018/06/vacation-recharges-workers.
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Clarifying Representation: The Department of Labor's Newest Regulatory Update
Discover the latest regulatory update by the Department of Labor, aiming to redefine representation during OSHA workplace inspections. This pivotal adjustment could significantly enhance inspection effectiveness and safety outcomes, marking a new ...
On August 29, 2023, the Department of Labor proposed a change to its Representatives of Employers and Employees regulation. According to the U.S. Department of Labor, this rule serves to clarify who can be authorized to serve as a representative during OSHA workplace inspections; stating that the representative may be an employee or someone from a third-party. It also clarifies that third-party representatives are not limited to industrial hygienists or safety engineers, a common misunderstanding of the existing regulation. If the compliance officer deems the individual has skills, knowledge, or experience that would be helpful, they may be granted permission to represent the employee during the inspection. The main goal of this proposed change is to have a more effective inspection conducted to prevent possible injuries (Godinez, 2023).
Should this pass, this would mean that Cornerstone could be a third-party representative for clients who have a scheduled OSHA inspection. Frequently, however, physical OSHA inspections occur without a heads-up from the OSHA officer. In this case, it would be very difficult for a third-party to be involved. That said, in the case that an inspection is scheduled ahead of time, bringing in outside representation would be much easier to coordinate.
Another limiting factor to Cornerstone’s involvement would be whether the client knows what areas of the workplace will be inspected. If the OSHA officer does not provide a scope of what will be inspected, then consulting oversight might be a moot point. That said, Cornerstone can help clients review inspection results and propose recommendations accordingly, regardless of our ability to be involved in the inspection itself.
Ultimately, this change would be a benefit to all parties involved with physical OSHA inspection. It will help make sure the right people are involved and, therefore, will lead to better outcomes.
Godinez, Victoria. “Department of Labor Announces Proposed Changes to Clarify Regulations on Authorized Employee Representation during Workplace Inspections.” Occupational Safety and Health Administration, August 29, 2023. https://www.osha.gov/news/newsreleases/national/08292023.
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Using Artificial Intelligence to Interpret and Predict ESG Initiatives
I think there is a misunderstanding in today’s world regarding what AI is and what it can do. The latest trend is generative AI, a form of artificial intelligence capable of generating new content. This can be seen from things like ChatGPT, which can write entire novels when given a prompt on a particular subject, or DALL-E, which can create amazing images. Not every AI falls into this category, though. Other types of AI, such as predictive analytics and machine learning algorithms, are also relevant. This distinction is helpful in realizing that AI cannot independently generate completely new ideas; AI models are trained on existing data and patterns. Recognizing this fact will help set realistic expectations for what AI can and cannot do. It will not create an unknown product that the world has never seen.
“If the hot new fad is AI, surely there must be some way to incorporate that into our current business to make us more efficient.” The answer is yes! AI algorithms can analyze large datasets to identify trends, assess environmental impacts, or evaluate organizational social governance practices.
AI can make all aspects of your company’s environmental, health, and safety goals more efficient. You can leverage current AI tools with no platform by feeding it your data and asking for suggestions on improvements. For example, you can train generative AI with your current accident data. With a few of the correct prompts, it can generate a safety plan to help improve worker safety or perhaps identify vulnerabilities you haven’t even thought of.
In the future, AI will not only interpret existing data but also predict our future goals. Using predictive analytics and AI-driven forecasting models, we can anticipate environmental risks, forecast resource demands, and predict social trends. Looking further into the future, I can envision a scenario where workers wear AI components to help them identify hazards, prevent injuries, or even maximize their productivity.
There are some drawbacks to AI that also need to be considered. Ultimately, the predictive models are only as good as the data given to them. Companies are also responsible for protecting private individual data. It’s essential to make sure the data is high-quality and ethically handled. Companies must have a transparency and accountability policy regarding sensitive data.
AI technologies will have a positive and profound impact on sustainability, social responsibility, and corporate governance, and I encourage you to begin researching how AI data-driven models can help your company right now.
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EPA News Update: Proposal to Change RCRA Regulation
News Update
On January 31, 2024, the United States Environmental Protection Agency (EPA) signed a proposal to change the Resource Conservation and Recovery Act (RCRA). This change adds nine per- and polyfluoroalkyl chemicals to its existing list of hazardous constituents.
To learn more about this change, read here. To read more EPA news, visit the EPA website.
Update: Notice of this proposal was published in the Federal Register on February 8, 2024.
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Understanding Metalworking Fluids: Types, Risks, and Control Measures
Learn about the four categories of metalworking fluids, including their risks and control measures.
What are Metalworking Fluids?
Metalworking fluids (MWFs) refer to fluids used during grinding and machining and include four classes of MWFs: straight oil, soluble oil, semisynthetic, and synthetic MWFs. MWFs serve to prolong the life of the tool, carry away metal debris that results from cutting and grinding, protect the part being produced, and carry heat away from the ground or cut surface.
Occupational exposures to MWFs are a concern and need to be controlled. Repeated inhalation of MWF mists can cause respiratory illnesses and asthma, leading to non-reversible lung damage. Additionally, contact with skin can cause various skin diseases, most notably allergic dermatitis.
Types of MWFs
MWFs are grouped into four categories. The first category is “straight” oil (neat oil) MWFs. These oils are solvent-refined petroleum oils, animal, marine, vegetable oils, or synthetic oils that are not diluted with water. The straight oils may or may not contain additives that may include corrosion inhibitors, emulsifiers, buffers, and extreme pressure additives.
The next class are the soluble oils (emulsifiable oils), which are between 30 to 85 percent severely refined lubricant base oil with emulsifiers and may also contain additives. Soluble oils also contain a small percentage of water.
The semisynthetic class contains less of a percentage of the severely refined lubricant base oil (5-30%) and contains a higher percentage of emulsifiers and up to 50 percent water.
The final category is synthetic MWFs, which contain no petroleum oils and are diluted with 10-40 parts of water.
Occupational Exposure
Occupational exposures to MWFs occur either by inhaling mists and aerosols or from direct skin contact. Besides the MWF aerosols and the added additives or biocides, exposure risk can include metals and alloys from the parts ground or machined. Additionally, background contaminants in the work area and bacterial or fungal contamination in the water component of MWFs pose a risk.
The National Institute of Occupational Safety and Health (NIOSH) has established a Recommended Exposure Limit (REL) of 0.5 milligrams per cubic meter (mg/m3) for an eight-hour time-weighted average exposure. The REL applies to all categories of MWF. In addition to NIOSH, the Occupational Safety and Health Administration has established a Permissible Exposure Limit (PEL) of 5 mg/m3, which only applies to mineral oil-based MWFs. The NIOSH REL is based on regular and recent reviews of health hazard data and is the occupational exposure limit referred to for best practices.
During machining operations, the risk of Inhalation exposures is greater depending upon how close the worker is to the machine, whether there is an enclosure or splash guard, and whether the machine is operating at a high speed and making deep cuts. Other factors contributing to exposures during machining or grinding are whether there is exhaust ventilation installed to capture mists and aerosols near the point of generation and whether the exhaust system has been poorly designed or maintained. Additionally, improper machine maintenance can result in excessive fluid application or contamination of the oil with machine tramp oils.
In addition to inhalation, skin contact is a major concern with respect to exposure. Exposures occur when there are not enclosures or guards to protect from splashes during machine operation, and from handling parts, tools, or equipment without personal protective equipment (gloves and aprons), or prolonged contact with clothing contaminated with oil.
Health Effects
The NIOSH REL was established to address non-malignant respiratory disease. MWF concentrations above the REL in nine out of ten studies have been shown to cause respiratory conditions, including hypersensitivity pneumonitis (HP) which produces flu-like symptoms, acute airway irritation, chronic bronchitis, impaired lung function, and asthma. Cases of HP have been linked to water-based or diluted oils, and microbial contamination is believed to be the most likely cause. Three recent studies have shown that the risk of developing asthma is elevated and up to three times greater for workers exposed to synthetic MWFs than for workers who are not exposed.
A variety of skin diseases can result from direct skin contact with MWFs. The following factors contribute to the development of disease:
The MWF category and additives used
The duration of the skin contact
An existing skin abrasion or cut
Individual susceptibility
Inadequate or infrequent skin cleansing following contact
The use of irritating soaps or detergents
High or low humidity, hot or cold temperatures
Wearing MWF-soaked clothing or handling soaked rags.
The general cleanliness of the surrounding work area
Lack of controls i.e., machine enclosures, exhaust ventilation, personal protective equipment (gloves, sleeves, aprons)
The most reported skin diseases are irritant contact dermatitis or allergic contact dermatitis. The latter type of dermatitis is caused by an immune response to a substance that the body has become sensitized to. Dermatitis causes skin lesions and discomfort from burning and itching. Dermatitis is common with contact with soluble, semisynthetic, and synthetic MWFs.
Other skin diseases, including folliculitis (hair follicle infection), oil acne, and keratosis (rough, scaly skin patches), are linked to contact with straight oil MWFs.
Controlling Exposures to MWFs
The machine tool industry has undergone major changes in recent decades, leading to significant exposure reductions. The changes made have included the increased use of synthetic MWFs, which have increased tool and cut speeds which reduce machining time. Technological advances have also been made, leading to the development of machines with partial enclosures and the installation of local exhaust ventilation. During the 1970s and 80s, industries began installing air cleaners (mist collectors) and improving the recirculation of air and filtration.
Recommendations for Controlling Exposures
NIOSH recommends developing and implementing a comprehensive health and safety program to control exposures to MWFs. For programs to succeed, management must have a strong commitment and include worker involvement. The four main components recommended are safety and health training, worksite analysis, hazard prevention and control, and medical monitoring of exposed workers.
Worker training programs should teach workers to identify potential exposure hazards in their work areas and the adverse health effects of MWF exposure.
Worksite analysis refers to monitoring work practices and assessing personal exposures (air sampling) to assess the effectiveness of controls.
Hazard reduction can be achieved by the proper selection of MWF, i.e., using the most non-irritating, non-sensitizing fluids, regular fluid maintenance, isolation of the operation, and installation of exhaust ventilation.
With respect to PPE, workers should be trained in the proper use and care of protective equipment. If personal exposure assessment indicates that respiratory protection is needed, a respiratory protection program must be established in accordance with the OSHA Respiratory Protection standard (29 CFR 1910.134).
For more in-depth information about MWFs and controlling exposures, consult NIOSH publication 98-116, Occupational Exposure to Metalworking Fluids
Mary Dunlap is a Certified Industrial Hygienist and has been with Cornerstone Environmental, Health and Safety since 2016. When she is not working, you can find Mary enjoying the outdoors.
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Safety First: The General Duty Clause's Impact on Toxic Substance Management
Don’t Forget the General Duty Clause! Even if you don’t violate a specific air quality regulation, you could still violate the General Duty Clause.
Don’t Forget the General Duty Clause! Even if you don’t violate a specific air quality regulation, you could still violate the General Duty Clause.
Under the Clean Air Act Section 112(r)(1), the General Duty Clause states: “The owners and operators of stationary sources producing, processing, handling or storing such substances [i.e., a chemical in 40 CFR part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the general duty clause in the Occupational Safety and Health Act (OSHA)] to identify hazards which may result from (such) releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.”
Environmental Protection Agency (EPA) has cited industries for violating the general duty clause of the Clean Air Act. The general duty clause requires facilities to take precautions to prevent the release of hazardous air pollutants, even if those pollutants are not explicitly regulated under the act.
Violations of the general duty clause have been cited, and violators fined. Just last year, for example, the U.S. Environmental Protection Agency (EPA) settled with Greenfield Global USA, Inc., a chemical repackaging and storage company in Brookfield, Connecticut, for alleged violations of the Clean Air Act's General Duty Clause (CAA GDC) and the Emergency Planning and Community Right-to-Know Act (EPCRA). Greenfield agreed to pay a penalty of $179,596 and certify compliance with all CAA GDC and EPCRA requirements.
EPA inspectors found that Greenfield failed to design and maintain a safe facility to prevent releases of toxic chemicals under the CAA GDC requirements. Additionally, the company did not correctly submit nine reports on certain toxic chemicals to EPA's Toxic Release Inventory (TRI) database for 2017 and 2018. Greenfield stored and processed various toxic chemicals, including highly hazardous substances like chloroform, formaldehyde, and sulfuric acid.
The facility's location near retail businesses, highways, and a residential neighborhood, as well as neighboring environmental justice concerns, raised concerns about potential risks to human health and the environment due to the presence of carcinogenic and highly flammable substances.
Don’t forget that you have a general duty to manage your toxic substances safely!
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Designation of PFOA and PFAS as CERCLA Hazardous Substances
EPA maintains a list of over 12,000 perfluoroalkyl and polyfluoroalkyl substances (PFAS), commonly referred to as ‘forever chemicals.’ Learn more.
The EPA maintains a list that currently includes over 12,000 perfluoroalkyl and polyfluoroalkyl substances (PFAS) that are known to accumulate in the environment as well as bodies of people and animals and may be linked to harmful health effects relating to reproduction, thyroid and liver function, the immune system, and cancer. These are commonly referred to as ‘forever chemicals’ because they contain a strong carbon-fluorine bond, don’t break down over time, and can dissolve in water.
In October 2021, the EPA released a PFAS Strategic Roadmap, which outlines plans to research, restrict, and remediate PFAS. The term PFAS refers to synthetic or man-made chemicals that have been used since the 1940s in many household and industrial products. They are known for their resistance to grease, oil, water, and heat and have been used in various products, including stain- and water-resistant fabrics, carpets, nonstick cookware, cleaning products, paints, and fire-fighting foams.
The PFAS Strategic Roadmap included a commitment to designate specific PFAS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Such designations would trigger various actions and regulations involving reporting, notification, cleanup, remediation, and cost/liability.
In September 2022, the EPA proposed a rule to designate two of the most widely used PFAS — perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), and their salts and structural isomers — as hazardous substances under CERCLA. The EPA is currently reviewing comments received on this proposed rule, and a final rule is expected as soon as August 2023.
If this designation is finalized, facilities across the country would be required to report releases of PFOA and PFOS that meet or exceed the reportable quantity assigned to these substances. CERCLA section 102(b) states that the reportable quantity of any hazardous substance is one pound unless changed by other regulations; therefore, any person in charge of a facility would need to report releases of PFOA and PFOS of one pound or more within a 24-hour period. The EPA has the authority to initiate or oversee the cleanup and remediation of sites contaminated with hazardous substances. So the hazardous substance designations would also enhance the ability of federal, tribal, state, and local authorities to obtain information about the location and extent of releases.
CERCLA already grants the EPA authority to address PFOA and PFOS releases because they are considered to be pollutants and contaminants, and EPA can respond if the release or threat of release presents an imminent and substantial danger to public health or welfare. However, if PFOA and PFOS are designated as CERCLA hazardous substances, then EPA can respond without making a determination of imminent and substantial danger.
CERCLA establishes a legal framework for holding responsible parties accountable for costs associated with cleanup. The proposed rule would, in certain circumstances, force the polluter to pay by allowing EPA to seek to recover cleanup costs from a responsible party or to require such a party to conduct the cleanup.
EPA anticipates that a final rule would generally encourage and create incentives for better waste management and treatment practices by facilities handling PFOA or PFOS. As more research is conducted, EPA plans to consider listing additional PFAS as hazardous substances. In April 2023, the EPA issued an Advanced Notice of Proposed Rulemaking (ANPR) asking the public for input regarding potential future hazardous substance designations of per- and polyfluoroalkyl substances (PFAS) under CERCLA.
For more information regarding PFAS, visit EPA’s website.
Catherine Nies is a Chemical Data Management Specialist. Her responsibilities focus on the output end of our Foundation system, verifying the information and deciding what reports to produce, including Tier II, permit summaries, EPCRA reports, and any other high-priority needs of our clients. A second responsibility for Catherine is tracking EPA, OSHA, CDC, and state and local regulatory updates.