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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OSHA's New National Emphasis Program: Safeguarding Workers in High-Risk Industries from Warehouse Injuries and Heat Hazards
OSHA recently launched an NEP focused on preventing injuries in warehouses, processing facilities, distribution centers, and high-risk retail establishments. Learn more.
National Emphasis Programs, also known as NEPs, are “temporary programs that focus OSHA's resources on particular hazards and high-hazard industries,”(OSHA 2023). On July 11th, 2023, OSHA launched a NEP focused on preventing injuries in warehouses, processing facilities, distribution centers, and high-risk retail establishments. This NEP decision was made based on ten years of injury history in these workplaces. According to the OSHA national news release, warehouses and distribution centers currently employ 1.9 million people, and the injury and illness rate is higher than the overall private industry.
The NEP will last three years and will consist of inspections focused on hazards related to powered industrial vehicle operations, material handling and storage, walking and working surfaces, means of egress, and fire protection. These safety focuses would be considered high-risk, which means if an injury occurs then there is a higher chance it will result in a serious injury or fatality.
The NEP also focuses on other safety topics that are not considered high-risk but attributed to the high injury rate: heat and ergonomic hazards. Additionally, OSHA may expand an inspection’s scope when evidence shows that violations may exist in other areas of the establishment. Overall, these are great areas of focus within these industries. Throughout my five years of being in the warehouse and distribution center sector, sprains and strains have been the most frequently occurring injury type and contributed to around half of all injuries I encountered. OSHA inspections related to ergonomics should look at packaging and loading workstations. The workforce in warehouse and distribution centers tend to be diverse, and one employee’s size and height could be completely different from another. Workstations, however, will be fixed. Heat-related illnesses vary throughout the United States, but states like Arizona tend to have 40-50 work-related fatalities due to heat stress.
For more information, visit: https://www.osha.gov/news/newsreleases/national/07132023#:~:text=%22This%20emphasis%20program%20allows%20OSHA,ensure%20worker%20health%20and%20safety.%22
Tyler Sandy is a Health and Safety Specialist and consults with clients in the area of worker safety. Tyler's experience includes industrial hygiene services, safety training, RCRA as well as OSHA and EPA compliance. His experience includes working with the packaging industry, railroad, welding, warehouse, food and medical waste, chemical manufacturing, and casting.
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Recent Changes to the SARA Title III TRI (Toxic Release Inventory)
Think you are ready to file your Toxic Release Inventory (TRI), aka Form R, reports just the same as you did last year? Hold on a minute. While you might not have an issue doing this, make sure to check the TRI Chemical List for any changes before you press submit. The Environmental Protection Agency (EPA) is making major changes to the list over the next two years.
The EPA makes changes to the TRI chemical list on a periodic basis though EPA-initiated review and the chemical petitions process.
Recent TRI Chemical List ChangesUnder the automatic listing provisions of the 2020 National Defense Authorization Act: Four PFAS were added for reporting year 2022. Reporting forms on these chemicals are due July 1, 2023, for 2022 data if TRI reporting thresholds are met. Nine PFAS were added for reporting year 2023. Reporting forms on these chemicals are due July 1, 2024, for 2023 data if TRI reporting thresholds are met. See Addition of Certain PFAS to the TRI by the National Defense Authorization Act for more information. In November 2022, EPA added 12 chemicals in response to a petition submitted under Section 313(e) of EPCRA. Reporting forms on these chemicals are due July 1, 2024, for 2023 data if TRI reporting thresholds are met.
*from epa.gov
For the Cliff’s Notes version from our technical expert (and skip the clicking)…Or easier still…just call us to help!
For the 2022 reporting year, due by July 1, 2023, the EPA has added four Per- and Polyfluorinated Substances (PFAS) to the EPCRA Section 313 reportable chemical list:
CAS RN Chemical name
375-73-5 Perfluorobutane sulfonic acid (de minimis 0.1%)
29420-49-3 Potassium perfluorobutane sulfonate
65104-45-2 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10- heptadecafluorodecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,14- pentacosafluorotetradecyl 2-methyl-2-propenoate and 3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl 2-methyl-2-propenoate
203743-03-7 2- Propenoic acid, 2-methyl-, hexadecyl ester, polymers with 2-hydroxyethyl methacrylate, γ-ω-perfluoro-C10-16-alkyl acrylate and stearyl methacrylate
Note that the de minimis value for each of these PFAS is 1% unless otherwise noted above. The manufacturing, processing, and otherwise use reporting threshold is 100 pounds for each of the PFAS listed above.
Please also note that the PFAS chemical names and CasRNs are listed on separate tables from the remainder of reportable chemicals on the List of Lists.
For the 2023 reporting year, due by July 1, 2024, the EPA automatically added in 9 PFAS to the EPCRA Section 313 reportable chemical list:
375-22-4. Perfluorobutanoic acid
2218-54-4 Sodium perfluorobutanoate
2966-54-3 Potassium heptafluorobutanoate
10495-86-0 Ammonium perfluorobutanoate
45048-62-2. Perfluorobutanoate
2728655-42-1 Alcohols, C8-16, γ-ω-perfluoro, reaction products with 1,6-diisocyanatohexane, glycidol and stearyl alc.
2738952-61-7 Acetamide, N-[3-(dimethylamino)propyl]-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs.
2742694-36-4 Acetamide, N-(2-aminoethyl)-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., polymers with N1,N1-dimethyl-1,3-propanediamine, epichlorohydrin and ethylenediamine, oxidized
2744262-09-5 Acetic acid, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., 2-hydroxypropyl esters
The EPA has also added the following 12 chemicals to the EPCRA Section 313 list beginning reporting year 2023, in response to a petition filed by the Toxics Use Reduction Institute:
683-18-1dibutyltin dichloride
96-23-11,3-dichloro-2-propanol75-12-7formamide
1222-05-51,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran;*111-41-1n-hydroxyethylethylenediamine
5064-31-3nitrilotriacetic acid trisodium salt140-66-9p-(1,1,3,3-Tetramethylbutyl) phenol87-61-61,2,3-trichlorobenzene
2451-62-9triglycidyl isocyanurate115-96-8tris(2-chloroethyl) phosphate13674-87-8tris(1,3-dichloro-2-propyl) phosphate
25155-23-1tris(dimethylphenol) phosphate
*classified as a Persistent Bioaccumulative, and Toxic (PBT) chemical with a 100 pound reporting threshold
SEC Rule on Climate-related Disclosures
In January 2023, the Securities and Exchange Commission (SEC) cited April as the release date for a long-anticipated final action – a rule on companies' climate-related disclosures.
For reference:
Scope 1 emissions are considered direct greenhouse gas (GHG) emissions from sources that are controlled by a company such as emissions from energy to run equipment, heating and cooling, and company vehicles.
Scope 2 emissions are indirect GHG emissions created by the production of energy (electricity, steam, heat, or cooling) the organization buys.
Scope 3 emissions are indirect GHG emissions that are not owned or controlled by the reporting organization. This category is much more encompassing as it addresses emissions generated by customers who use the products and by suppliers making products the company uses. Addressing Scope 3 involves tracking emissions across the entire value chain from suppliers to end users.
Scope 1 and 2 emissions tend to be easier to track, measure, and, to an extent, control. Options, such as solar and other renewable energy sources and switching company vehicles to electric models, are a few examples. With regard to Scope 3 emissions, EPA suggests that an “organization may be able to influence its suppliers or choose which vendors to contract with based on their practices.” For other companies, the focus can be less on suppliers and more about their customers’ use of products.
The reality is the upcoming SEC final rule release will regulate publicly traded companies; however, these publicly traded companies will be obligated to heighten their demands on the private sector suppliers to the companies subject to the SEC rule. Private companies will very likely be affected by new vendor or customer requirements. Small and mid-market organizations may not have the capability to effectively manage in-house. For those organizations already addressing Scope 1 and 2, it will be critical to ensure the process is accurate. A periodic third-party audit will be prudent. While not anticipated to have a reporting date before 2025 (for FY 2024), if not yet addressed, a plan to identify, manage and measure Scope 3 should be considered.
It is and will be critical for organizations to publicly communicate accurate, complete, and reliable environmental data, which includes environmental risks, opportunities, and practices as well as GHG emissions that are useful in decision-making for stakeholders.
A recent article in Environment+Energy Leader reminds us that there is good news. “…the good news is that these new standards and requirements are aligning around a common core, giving the markets more comparable information, and giving companies clearer direction. Organizations must understand that C-suites and Boards of Directors will be held accountable for disclosures and data management. It will be critical to ensure that data is reliable.”
Important Notes:
The proposed SEC rule would provide a safe harbor for liability from Scope 3 emission disclosure and exemption from Scope 3 emissions disclosure requirement for smaller reporting companies.
The proposed disclosures are anticipated to be similar to currently accepted disclosure frameworks such as ISSB (IFRS) and CDP.
Sources:
https://www.epa.gov/climateleadership/ghg-inventory-development-process-and-guidance
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Proposed Changes to CWA Discharge Planning
In late March, the Environmental Protection Agency (EPA) proposed the “Clean Water Act Hazardous Substance Worst Case Discharge Planning Regulations.” The proposed rule will require all non-transportation related onshore facilities that store hazardous substances with potential to cause substantial environmental harm above Clean Water Act (CWA) threshold amounts to prepare and submit a Facility Response Plan (FRP) to the EPA. The response plans will address potential worst-case discharges into or on navigable waters or conveyances to navigable water under adverse weather conditions.
The rule will apply to facilities meeting the following criteria:
Capacity to store certain substances: facilities with a maximum capacity above 10,000 times the Reportable Quantity (RQ) of CWA hazardous chemical such as sulfuric acid, ammonia, benzene, sodium hydroxide, hydrochloric acid, etc.
Location: facilities within a half mile of navigable waters or conveyances to navigable waters.
Potential harm (based on past chemical releases or modeled worst case discharges): facilities which meet the first two criteria will have to evaluate whether a discharge could cause harm to public water system receptors or to fish, wildlife, and sensitive environments. A facility will also be required to submit an FRP if they have met the capacity and location criteria and have had a reportable discharge of a CWA hazardous substance within the last five years.
Even if a facility did not meet all three criteria, an EPA Regional Administrator could still require the facility to complete an FRP based on site-specific factors.
The response plans will include identification of qualified individuals and key response resources, hazard evaluations, drills and exercises, release detection, response actions, and communication plans with Local Emergency Planning Committees (LEPC).
EPA enacted regulations for worst case discharges of oil under 40 CFR Part 112, subpart D in 1994. It has not proposed any regulations for CWA hazardous substances until this rule, which could affect a variety of industries and manufacturers. The proposed rule considers the impact of climate change on increased discharge risks as well as impacts to communities with environmental justice concerns.
Recently, the EPA extended the comment time for the proposed rule to July 26, 2022. When the final rule is issued, facilities will be required to determine if they are subject, and if so, prepare and submit an FRP within twelve months of the effective date of the rule. Newly constructed facilities will be required to submit a FRP before starting operations. In addition, updates to the FRP will be required every 5 years or within 60 days of a change that impacts the facility’s potential to cause substantial harm to the environment.
Catherine Nies is a Chemical Data Management Specialist. Her responsibility 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, state and local regulatory updates.
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OSHA Proposes a New Scheme for Injury and Illness Reporting
On March 28, 2022, OSHA announced a proposed rule to amend the federal occupational injury, illness recordkeeping regulation. If approved, the proposed rule will change the requirement to submit illness and injury summaries (OSHA 300-A) for many companies with 20-249 employees and almost all employers with 250 employees, and would potentially require fewer establishments to report more detailed information.
The proposed change will require establishments with 100 or more employees, in certain high-hazard industries, to electronically submit not only the 300-A summary but more detailed information from their log of injuries/illnesses (OSHA 300) and the Injury and Illness Incident Reports (OSHA 301).
The “high-hazard industries” (found in Appendix B to the proposed rule) includes a wide swath of the economy including agriculture, manufacturing, wholesale, retail, transportation, warehousing, real estate, healthcare, art, entertainment as well as hotels and food service.
Another critical change will require establishments to include their company name when making electronic submissions to OSHA. This is very important when you consider that the submissions are posted online. That has been the case for years and the data is very revealing, but only in a limited way. The additional reporting requirements would make details about your worker injuries and illnesses a matter of public record. In addition, accurately recording and reporting the information will become even more critical. (The data reported currently is available at https://www.osha.gov/Establishment-Specific-Injury-and-Illness-Data)
At a time when your company’s data is more accessible than ever by a global audience, it is crucial to understand how and when it is shared. Cornerstone will monitor this proposed rule and keep you informed. In the meantime, we recommend that all impacted employers read and understand the proposed rule and comment as needed. Comments must be submitted by May 31, 2022.
Read the full release and get more information here: https://www.osha.gov/news/newsreleases/national/03282022-0
John Scifres is Cornerstone’s Director of Health and Safety Services. He is a Certified Hazardous Materials Manager and is a Provisional Lead Auditor for ISO 14001 and OHSAS 18001. He oversees Cornerstone’s team of EHS Project Managers. In addition, he consults with clients nation-wide to ensure compliance with EHS regulations and evaluate opportunities to go above and beyond compliance.
#OSHA #Safety #InjuryandIllness #OSHA-300-A
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EPA Identifies More Substitutes for Ozone-Depleters
In May, EPA published a final rule expanding the list of substitutes for ozone-depleting refrigerants, such as chlorofluorocarbons (CFCs), and flame retardants. This rule becomes effective June 7, 2021 and specifically:
Lists R–448A, R–449A and R– 449B as acceptable, subject to narrowed use limits, for use in retail food refrigeration—medium-temperature stand-alone units for new equipment
Lists R–452B, R–454A, R–454B, R–454C and R–457A as acceptable, subject to use conditions, for use in residential and light commercial air conditioning (AC) and heat pumps for new equipment
Lists R–32 as acceptable, subject to use conditions, for use in residential and light commercial AC and heat pumps—equipment other than self-contained room air conditioners, for new equipment
Removes Powdered Aerosol E from the list of fire suppression substitutes subject to use conditions in total flooding applications.
What is EPA’s SNAP Program?
EPA is finalizing these new listings after its evaluation of human health and environmental information for these substitutes under the Significant New Alternatives Policy (SNAP) program. Section 612 of the Clean Air Act (CAA), established EPA’s SNAP program which requires the agency to reviews substitutes within a comparative risk framework in the following industrial sectors:
Adhesives, Coatings, and Inks
Aerosols
Cleaning Solvents
Fire Suppression and Explosion Protection
Foam Blowing Agents
Refrigeration and Air Conditioning
Sterilants
Tobacco Expansion
The SNAP program evolves the list as EPA makes decisions that are informed by its overall understanding of the environmental and human health impacts as well as its current knowledge about available substitutes. Section 612 also provides that EPA must prohibit the use of a substitute where EPA has determined that there are other available substitutes that pose less overall risk to human health and the environment. Read the full rule in the Federal Register