Health and Safety Sustainability: Does Your Operation Go "Above Compliance"?
Earlier this year, I wrote an article entitled “Where the S in ESG intersects with HS in EHS.” While I stand behind the tenor of that piece, there is one thing I said that gives me some pause. I wrote “Today, compliance with Environmental, Health, and Safety (EHS) regulations is a given. Employers must go beyond compliance.” That statement is true when viewed through the ESG and sustainability lens. But my history with clients, including recent work, has shown that sometimes even the most sophisticated of our clients still falls down when it comes to compliance with OSHA regulations. At times, companies within the regulated community have difficulty remaining in compliance with applicable regulations. So, how can they go beyond compliance to sustainability?
I’ll be the first to admit that compliance with governmental regulations doesn’t always equate to a healthy and safe workforce. Unfortunately, it doesn’t always work that way; however, when regulators discover violations and take enforcement action, investors, competitors, and employees will take notice. You simply cannot have strong ESG performance without a good compliance record.
Take the Hazard Communication Standard (HazCom) for example. Failing to properly label chemicals or not keeping an updated chemical list and corresponding Safety Data Sheets (SDSs) is always one of the Top 10 Most Frequently Cited Standards. In 2020, it was #2 on the list. HazCom has been around since the beginning of my career. You can do some research and see that is a very long time — over 30 years! What that means is that in three decades, many facilities still struggle with basic aspects of labeling and documentation. A recent project at a very large corporate client demonstrated this, when we discovered almost 99% of their chemical list was outdated or missing SDSs.
Another frequently cited Standard is Energy Control (a.k.a. Lockout/Tagout). It was #6 in 2020. We do dozens of projects each year with very large clients, and it is unanimous that if OSHA took even a cursory look at their procedures and training, violations could follow. Conducting lockout, training employees, writing procedures for each piece of equipment, and inspecting the procedures each year is required.
One reason more enforcement doesn’t occur is that OSHA is a very small agency. Inspections fell drastically in 2020 due to the pandemic. In 2019, over 33,000 inspections were conducted. This dropped to under 22,000 in 2020. In early 2021, the Department of Labor Office of Inspector General called OSHA out on this reduction, and everyone agreed that more and deeper inspections were needed. In short, expect more inspections and investigations.
Additionally, in October, Douglas Parker was confirmed as OSHA’s new leader. It bears mentioning that he is a past chief of California’s Division of Occupational Safety and Health (Cal/OSHA). Anyone with experience in California knows the approach taken there to worker health and safety. It is a much more enforcement-focused regulatory scheme. It is likely that some of that scheme will follow Mr. Parker to the Federal OSHA he now leads.
So, the question is, are you ready to go beyond compliance? If you do not have a good feeling about your compliance program, the answer may be “no.” And, if that is the case, what are you risking beyond the health and safety of your workers? If sustainability and ESG performance are what you aspire to, you may be risking investment, growth, and the long-term outlook of your business.
Further Information
As ESG reporting becomes more vital and more publicly transparent, Cornerstone’s industrial health and safety experts can help ensure that your programs and data are ready for the spotlight. Contact us at info@corner-enviro.com or visit our website for more information regarding our ESG services.
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Are You Prepared for the Tier II Emergency and Hazardous Chemical Inventory Reporting Deadline?
Tier II Emergency and Hazardous Chemical Inventory Reports are due annually on March 1. Since these reports cover materials for the entire previous year, it’s important to continually track the chemicals/products entering and leaving your facility. Maintaining on-site inventory throughout the year will allow for a smooth Tier II reporting season. Don’t let the deadline sneak up on you!
The following is a quick overview of the EPCRA regulation and Tier II reporting:
What is EPCRA?
The Emergency Planning and Community Right-to-Know Act of 1986 was created to help communities plan for chemical emergencies. This regulation requires industry to report on the storage, use, and release of hazardous substances to federal, state, and local governments. EPCRA serves as the governing body for Tier II reporting.
What makes a chemical reportable under Tier II?
Reporting is applicable for any OSHA-hazardous chemical stored on site that exceeds the federal threshold quantity of 10,000 pounds, and any EHS stored in excess of 500 pounds or its threshold planning quantity (TPQ), whichever is less. Exceeding the threshold at any time during the reporting year triggers the reporting requirement. It is also important to note that individual states may have more stringent reporting requirements.
What is an EHS?
The Extremely Hazardous Substance (EHS) list identifies chemicals that could cause serious irreversible health effects as a result of a release. A full list of EHS chemicals can be found on epa.gov.
What storage information is needed to file the Tier II?
Reporting requirements include details of specific location(s) within a subject site where reportable chemicals are stored. In addition, the type of container utilized and exact maximum amount (typically measured in pounds) of hazardous chemicals present at the facility at any one time during the previous calendar year must be reported.
How do I know what reporting requirements exist for my state?
Although each state’s reporting system may vary, any subject facility must file a Tier II report annually with the State, County (LEPC), and local Fire Department. Additional information regarding filing criteria by state, along with associated fees, can be found at https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures.
Further Information
With a well-organized system in place, compliance with the Tier II reporting requirements is much easier to achieve. Cornerstone is an industry leader in chemical inventory management, electronic SDS imaging, and software management systems. Our proprietary software (FOUNDATION) combines both EPA and OSHA chemical tracking and reporting functions and provides a foundation for all compliance recordkeeping and reporting. Additionally, we have a team of experts who can assist with Tier II reporting and help keep your hazardous chemical data up to date throughout the year, so you will always be ready for the March 1 deadline.
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Industrial Hygiene Services Prevent Health Hazards for the Plastics Industry
The U.S. plastics industry employed just under one million workers in 2020 and continues to grow and expand. Leading the way in production and employment are Texas, Ohio, and California. In addition to environmental and safety issues, health hazards associated with the production of plastic products are a concern and should be recognized.
Man manufacturing upvc frame
Types and Characteristics of Commonly Used Plastics
The major types of plastic are classified as thermosets, elastomers, and thermoplastics. Thermosets are heated and require a curing agent which results in a permanent form that cannot be reground and reused. Elastomers can return to the original shape and size after deformation but are not formed by the same process as rubber. Thermoplastic polymers (resins) are widely used because they can be re-ground and re-molded; thereby eliminating waste and reducing production costs.
The most common thermoplastic polymers in use include:
Polyethylene
Polypropylene
Polyvinyl chloride (PVC)
Polystyrene
Acrylonitrile-butadiene- styrene (ABS)
Styrene acrylonitrile
Styrene-butadiene copolymers
Prior to molding, thermoplastic resins are mostly inert and present a low health risk except for any unreacted residual monomers, or molecules that bond together to form the polymer structure. A striking example of the effects of overexposure to resin dusts occurred in the 1970s when several workers who handled PVC resins were diagnosed with angiosarcoma, a rare liver disease. A significant reduction in exposure that lowered the risk for the development of disease was achieved when controls were applied to reduce the amount of unreacted monomer present in PVC resins. The levels went from as high as 1 percent to 0.001 percent.
Other sources of exposure can occur when the additives are combined with the resins to produce specific properties for the end product. Ideally, this occurs in a closed-looped system that exhausts the dust and minimizes exposure. In smaller operations, this is often not the case.
Additives are added to modify the properties of resins, aid in the molding process, and provide color. Common additives include flame retardants, antioxidants, blowing agents, optical brighteners, antistatic agents, UV light absorbers, fillers, solvents, curing agents, and reinforcements. Nearly 2,500 different chemicals are used in the production of additives. Additive compounds that commonly pose risks include:
Phthalates in plasticizers
Antimony, boron, bromine compounds in flame retardants
Hydrochlorofluorocarbons (HCFCs) and azodicarbonamide in blowing agents
Toxic heavy metal compounds (lead, cadmium, and chromium) in colorants
Thermal degradation products from organic colorants that are used as alternatives to metal compound colorants
Hazards During the Molding Process
The next phase where hazards exist is during the molding process, when the mold is released, and during purging and maintenance. Purging is performed whenever there is a resin or color change, or maintenance is needed on equipment. During purging, higher than usual molding temperatures are needed to clear the equipment of residue, and smoke is produced that may contain thermal degradation products from the resin and additives.
To protect workers, it is necessary to provide adequate exhaust ventilation in and around molding lines. If ventilation controls are inadequate in controlling dust levels during mixing, mists and vapors during mold release, or smoke generated during purging, occupational exposures should be assessed.
Sampling Strategy
The starting point for designing a good strategy for sampling is to review Safety Data Sheet (SDS) information for the resin and additives used in the process to determine regulated components and thermal degradation products. Some examples of constituents that are commonly assessed during personal sampling include the following:
Butane- contained in n, and acrolein in polypropylene resins
Hydrogen chloride in PVC resins
Styrene contained in polystyrene
Phenols and butadiene contained in ABS resins
Nuisance dust
When results from sampling are available, it can be determined if exposures have exceeded occupational exposure limits (OELs) established by the Occupational Safety and Health Administration (OSHA), the American Conference of Governmental Industrial Hygienists (ACGIH), and the National Institute of Occupational Health and Safety (NIOSH). If exposures exceed OELs, the proper respiratory protection can be provided to the workers in accordance with the OSHA Respiratory Protection standard but should be used only as a stopgap before control measures can be implemented and tested for effectiveness.
Noise Exposure
Another health hazard to consider in the plastics industry is noise exposure. It is common for noise exposures to exceed the OSHA Action Level (AL), which is 85 “A”-weighted decibels (85 dB(A) for hearing conservation.
In a typical operation, there is a high density of noise sources such as motors, fans, hydraulic pumps, and other equipment. Depending upon the size of the operation, exposures can even exceed the Permissible Exposure Limit (PEL) of 90 dB(A), and when that occurs, engineering and/or administrative controls are needed to reduce exposures.
Personal noise exposures are easily assessed utilizing calibrated noise dosimeters that record and average sound levels throughout the work period. The data logged is then used to determine the 8-hour time-weighted average exposure which can then be compared with the AL and PEL.
Further Information
Cornerstone serves clients that produce plastic products or packaging used by the food and beverage industry, health and beauty products, and a variety of consumer goods. Our Health and Safety department can perform a Personal Exposure Assessment to observe operations, job tasks, and work practices for air, noise, and ergonomic safety. Our experts provide reports of risks, prioritize areas for changes, and recommend control measures. Contact Cornerstone at info@corner-enviro.com or on our website for more information.
Mary Dunlap CIH, is a Senior Industrial Health and Safety Specialist and Certified Industrial Hygienist. She works with Cornerstone’s clients to develop exposure assessment strategies tailored for their work environments. She regularly performs ergonomic assessments using a variety of OHA and NIOSH tools to rate severity of risk for work related to musculoskeletal disorders.
References:
Recognition of Health Hazards in Industries – Second Edition, William A. Burgess
The Hazards of Plastic Injection Molding and Recommended Engineering Safety Controls – Sentry Air Systems
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OSHA Frequency Requirements for Safety Training
Don’t let Worker Health and Safety Training slip through the cracks! The safety of your workplace depends on providing your employees relevant, up-to-date training — plus it is a key requirement to comply with OSHA regulations.
Is your workforce receiving the training they need when they need it?
Digging through OSHA’s website to find this information can be time-consuming, and often training requirements may still be unclear after reading the regulations.
Cornerstone’s worker safety team members have decades of experience from industry, agencies, and the military. We will work with your organization to deliver an effective worker safety program that helps ensure OSHA compliance and prevent workplace emergencies.
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Air Quality Modeling: What Is It?
Frequently, a manufacturing plant or industrial operation may have processes that emit air pollutants into the atmosphere. In most cases, the operation will be required to calculate the potential, and sometimes actual, emissions and present the findings to their State’s environmental agency. Then, the type of emission sources and the potential and/or actual emissions rate will be used to determine if an air permit is required. The State will also review the sources and emissions and apply specific regulations to the plant to allow those emissions to be released into the environment. This information will typically be summarized and included in an air permit. Additionally, depending upon the amount or nature of the emissions, the permit may include requirements for controls or limits on emissions.
In some cases, a regulatory agency may ask an operation to present information beyond the amount of calculated air emissions released into the atmosphere. The plant may have to determine what the impact of their emissions is on the surrounding community. When an operation has the potential to release chemicals that, in high concentrations, could cause unhealthy conditions, State regulatory agencies may require an estimate of downwind effects of air pollution emissions. This is accomplished by using air quality modeling.
How do you calculate downwind air pollutant concentration?
Calculating the volume of pollutants being emitted from a stack is relatively straightforward, however, using air quality modeling to determine the concentration of pollutants downwind of the facility is a more complex process. Air quality modeling uses computer programs to calculate the release of a pollutant into the atmosphere and determine how it disperses as it travels downwind. The program will then calculate the eventual concentration of that pollutant at a certain location.
The U.S. EPA has developed many different air quality models to calculate downwind air pollutant concentrations, and these models vary in size and complexity. Simple air quality models, known as Screening Models, can quickly determine concentrations and require limited information about the emissions and the emission points. Screening Models are relatively quick to prepare, do not require a lot of site-specific information, and will provide general estimates of downwind concentrations.
Other more sophisticated models, known as Refined Models, require more detailed information to generate results. These models use site-specific information, such as local weather data, terrain elevation around the site, and other specifics about the emission sources. Due to the complexity and amount of information required, Refined Models require significantly more set-up time and effort to obtain proper results.
You may ask, “If the Screening Model is so easy to use, why would anyone want to use the Refined Model?” The simple answer is that Screening Models are not as accurate as Refined Models. Usually, Screening Models tend to estimate concentrations on the high end to prevent underestimating the downwind impacts. Screening Models are also very general and are not designed to estimate emissions from complex scenarios. Refined Models are able to model complex situations and are site-specific.
Which model should you use — Screening or Refined?
In most cases, Screening Models are used as a “first step” and, since they tend to overestimate emissions, provide a conservative estimate of concentrations from a source. If the calculated concentrations from a Screening Model show no adverse health effects, then one can assume the emission source will not adversely affect the surrounding environment. If, however, a Screening Model shows concentrations higher than allowable values, all is not lost. A Refined Model can be used to provide more accurate and often lower concentrations, possibly showing that the emission source would not have detrimental effects on the downwind area.
Further Information
Cornerstone can help you determine whether air quality modeling is necessary for your facility. Our team of experts has provided clients with both Screening and Refined Modeling analyses to assist them with State agency modeling requirements and other studies. For more information about our air quality services, please visit our website or contact us to discuss your specific needs.
John Nuckels, Sr. Environmental Engineer
John helps clients with the preparation of air permits and supports them in responding to inquiries by State permitting agency personnel. His expertise in air quality monitoring, stack tests, recordkeeping, and reporting assists clients in achieving and maintaining air quality compliance. Industry experience includes aerospace, aluminum, motor vehicle / automotive parts, government, plastics, military, and other manufacturing clients in both public and private sectors.
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Incident Investigation and Injury/Illness Reporting Requires a Systematic Approach
No one wants to have workplace accidents, but when they happen it’s important to have an Incident Investigation and Injury/Illness Reporting Program in place. The program must include the procedures necessary to properly investigate the incident and determine the cause as well as how to prevent a recurrence. The following is a summary of the steps necessary to properly respond, investigate and record an incident to meet OSHA compliance.
Reporting the Incident
First and foremost, employees must immediately report all incidents and near misses to their supervisor who will then notify the person responsible for incident investigation and injury/illness reporting. Depending upon the type and severity of the incident, notification to OSHA may also be required.
Investigate the Scene
All incidents, regardless of severity or impact, need to be thoroughly investigated. The process must look beyond what happened to discover why it happened. This will allow for the identification and correction of shortcomings in the safety and health management programs. The principal incident investigators must go to the site of the incident to conduct the investigation. It is critical that the scene is preserved to prevent material evidence from being removed or altered. Using cones, tape, and/or other guards may be required. Facts must be carefully documented.
Collect Information
The principal incident investigators must collect information through interviews, review of documents, and other means. Using a checklist may help ensure that all information pertinent to the incident is collected. In addition, other sources of useful information may be sought out such as equipment manuals and training records.
Determining Root Cause of the Incident
The principal incident investigators must determine and document the underlying reasons the incident occurred and the corrective actions required to prevent future incidents. At a minimum, a determination must be made whether there are deficiencies in any area, and in doing so persistently ask the question “Why?” at least 5 times to probe the area in depth.
Corrective Actions
The investigation is not complete until corrective actions are implemented that address the root causes of the incident. Implementation entails program-level improvements and must be supported by senior management. It is important for the person(s) responsible for incident investigation and injury/illness reporting to review the root cause factors and corrective actions and forward the information to appropriate management personnel for follow-up and implementation. It is recommended for management personnel to(s be responsible for ensuring corrective actions are implemented.
Training
The person(s) responsible for incident investigation and injury/illness reporting must also provide training to management employees who are assigned duties under the program. The training must cover a review of the Incident Investigation and Injury/Illness Reporting Program, including all the information needed and steps involved in the process.
Records Required by OSHA
The person(s) responsible for incident investigation and injury/illness reporting must ensure all injury/illness records required by OSHA are completed and maintained. The company must record information about every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid. Significant work-related injuries and illnesses diagnosed by a physician or licensed health care professional must also be recorded. In addition, the company must record work-related injuries and illnesses that meet any of the specific recording criteria listed in 29 CFR 1904.8 through 1904.12.
OSHA recordkeeping and reporting requirements are extensive and necessitate a robust system for reporting and retaining records related to incident investigations. To ensure all the necessary information is investigated and reported properly, ask an expert for help when implementing an Incident Investigation and Injury/Illness Reporting Program.
Further Information
Cornerstone offers a structured software application for Incident Management which can be an invaluable tool to support incident prevention programs and facilitate the process of investigating and recording incidents. We also offer safety management programs and training to help prevent injuries and illnesses in the workplace. Learn more about Incident Management Systems.
David Blane is a Senior Health and Safety Specialist. He is a Certified Safety Professional by the Board of Safety Professionals. He currently provides health and safety compliance auditing, program development, training, and industrial hygiene monitoring to Cornerstone’s industrial and construction sector clients. Blane formerly served as an OSHA compliance inspector.
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Cornerstone's Waste Services Support RCRA Compliance
Many organizations are subject to the requirements outlined in the Resource Conservation and Recovery Act (RCRA), yet they do not know if they are compliant. Cornerstone offers a variety of waste services to assist our clients in understanding their regulatory obligations, identifying areas of non-conformance, and developing a facility-specific plan to maintain compliance. Our goal is to ensure that compliance is not only met, but sustainable. Two of the services we offer can assist you with both, the Hazardous Waste Compliance Assessment and the Waste Compliance Program. There are a number of differences between these services. Our team of experts will work with your organization to guarantee your specific needs are met.
Hazardous Waste Compliance Assessment
Hazardous Waste Compliance Assessments are most beneficial to facilities with multiple hazardous waste streams. A Cornerstone waste team member will conduct a detailed review of your operations and practices to determine the status of compliance with applicable RCRA regulations. Specifically, labeling, storage, container management, disposal, recordkeeping, and reporting. These particular areas can lead to significant penalties if discovered during a regulatory inspection. Our Hazardous Waste Compliance Assessment is a proactive step to identify areas of gaps in compliance.
Waste Compliance Program
The Waste Compliance Program is a facility-specific program designed to provide clients with detailed information about their waste streams, applicable compliance requirements based on their generator status, and supporting documentation for maintaining compliance. This service is particularly useful for plants that are not sure how to manage their various waste streams. Even Small Quantity Generators (SQG) and Very Small Quantity Generators (VSQG) can benefit from this program since many sites do not receive the necessary guidance to fully comply with applicable regulations.
The Waste Compliance Program goes beyond the assessment and provides an actionable written plan with both required and recommended best practices to manage your waste streams. Based on the waste streams at your facility, Cornerstone will confirm that the necessary practices and procedures are in place to comply with regulatory requirements. The site-specific evaluation includes a thorough look at hazardous waste, non-hazardous waste, universal waste, used oil, and recyclable materials. The program provides information, tools, and resources to achieve and maintain compliance with generator requirements.
A Necessary First Step
With the current emphasis on Environmental, Social and Governance (ESG), many corporate executives understand the need to go beyond environmental regulatory compliance to satisfy stakeholder expectations. Their EHS Managers are being tasked with finding sustainability improvements including the evaluation of waste streams and identification of recyclable materials. Cornerstone’s Waste Compliance Program provides the necessary baseline information to move towards the Environmental Pillar of ESG. The identified processes, waste streams, and current disposal practices can then be used to identify targets for disposal alternatives, including waste to energy, reuse, recycling, and zero waste goals. Developing accurate baseline information for waste streams is the first step in determining realistic reduction goals and sustainable goal development. You cannot manage what is not measured.
Further Information
Contact us for more information on waste services that will benefit your organization.
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Emergency Generator Inspections and RICE MACT Compliance
This year was the first in my career in which EPA issued a Notice of Violation to a client due to non-compliance with a facility’s emergency generator maintenance and records.
The majority of my clients have an emergency generator on site. Many maintain them appropriately and keep the required records, but sometimes these requirements can slip through the cracks. Facilities should be aware of the requirements that apply to generators and ensure they are documenting compliance.
The potential consequences of non-compliance include inspection violations, fines, and required reporting in annual compliance certifications.
DOES YOUR FACILITY HAVE AN EMERGENCY GENERATOR?
The first step is to determine if your facility has generators on site. This may seem obvious, but I have seen several instances where a facility’s environmental team was either unaware they had a generator or did not know the specific requirements that applied to the units. I have also seen generators installed without the environmental team’s knowledge. If you are unsure, ask your maintenance department to verify.
ACTIONS TO BE TAKEN IF YOUR FACILITY HAS ONE OR MORE EMERGENCY GENERATORS
Determine what type of engine drives your emergency generator.
Find out when the unit was manufactured, what type of fuel it uses, and the unit’s horsepower rating. This information is often on the nameplate of the unit.Determine if your emergency generator must be permitted.
Depending on your state and its operational activities, your generator may or may not require an air permit. This is a state-by-state determination since each state has its own rules for handling emergency generator permitting. Some states may have a general permit for emergency generators at facilities that would otherwise not have an air permit. Others may have regulations that apply beyond the federal requirements.Determine what requirements apply to your generator(s).
Based on the above information, the generator will be subject to parts of 40 CFR 60, Subpart JJJJ, 40 CFR 60, Subpart IIII, and/or 40 CFR 63, Subpart ZZZZ. These regulations are referred to as the RICE MACT (Reciprocating Internal Combustion Engine Maximum Achievable Control Technology).
WHAT ARE THE “NEW” OR “EXISTING” GENERATOR CATEGORIES?
The manufacturer date will determine if your emergency generator is considered “new” or “existing” with respect to the requirements. For example, a generator with a compression ignition (diesel) engine is considered new if it was manufactured after April 1, 2006.
“New” Emergency Generators
For most new units, owners achieve compliance by purchasing an engine that is certified by the EPA and by installing, configuring, operating, and maintaining the engine per the manufacturer’s instructions. To comply with regulations, it is necessary to maintain records of the certification and maintenance conducted.
If a facility that is already classified as a major source installs a generator with greater than 500 horsepower, EPA requires the facility to submit an initial notification to their agency. This is the only type of emergency generator that requires the notification submittal.
“Existing” Emergency Generators
Compliance for “existing” generators can be achieved by adhering to the following requirements and specific maintenance items on schedule:
Maintenance Items (Applies to all emergency generators except >500 HP at major sources)
Change oil and filter and inspect all hoses and belts every 500 hours of operation or annually, whichever comes first
Alternately, the operator may use oil an analysis program instead of prescribed oil change frequency
Compression Ignition (diesel) – Inspect air cleaner every 1,000 hours or annually, whichever comes first
Spark Ignition (natural gas, gasoline, propane, etc.) – Inspect spark plugs every 1,000 hours or annually, whichever comes first
Compliance Requirements
Operate/maintain engine and control device per manufacturer’s instructions or owner-developed maintenance plan
Emergency engines must have a meter and record hours of operation
Retain all maintenance records
OPERATING HOURS
Each emergency generator (except >500 HP at major sources) must have a non-resettable hour meter installed. This is critical to accurately record the hours of operation. For each operating event, owners must record the hours and distinguish if the event was used for emergency response or in a non-emergency situation.
Each generator may be operated for up to a maximum of 100 hours per calendar year for maintenance checks, readiness testing, emergency demand response, and non-emergency usage.
A limit of 50 of those hours can be non-emergency situations.
If either threshold is exceeded, EPA will reclassify the generator as a “non-emergency” unit, causing it to be subject to a different set of regulations including possible performance testing.
MAINTAINING COMPLIANCE
The most difficult part of emergency generator compliance is determining into which category your unit falls. Once you have made that determination, maintaining compliance is rather straightforward. You can conduct the prescribed maintenance at the established frequencies and record the hours of operation distinguishing between types of use.
The key is to maintain sufficient records demonstrating compliance with each requirement. This will help ensure your facility is in compliance with the RICE MACT generator requirements and avoid violations and possible fines in the future.
FURTHER INFORMATION
Contact Cornerstone for help regarding emergency generator inspections and RICE MACT compliance.
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Dramatic History of PFAS Leads to Present-Day EPA Actions
I’ll admit it — I’m a true crime junkie.
It started with a podcast and has moved into documentaries. Never, not once, did I imagine that my professional life would seep into my guilty pleasure. I was happily binging on a new podcast when suddenly the topic went from unsolved historical mysteries to the Dupont Chemical Scandal, which is a 20-year legal battle between Dupont (the manufacturers of such products as Teflon) and a West Virginia farmer whose cows kept mysteriously dying. Bonus: There’s a newer movie about this case as well! Dark Waters contains a rather star-studded cast too including Mark Ruffalo, Anne Hathaway, and Tim Robbins.
A recently proposed EPA rule has once again brought Per- and Polyfluoroalkyl Substances (PFAS) or ‘forever chemicals’ into conversations and compliance questions. For more technical information on what PFAS are and the proposed rule, check out our blog post on the topic.
Dupont Chemical and PFAS: An Extremely Abbreviated History
In 1802 (not a typo…1800s, people!), Éleuthère Irénée du Pont, who emigrated from France after the French Revolution, founded a company to produce gunpowder called E. I. du Pont de Nemours and Company near Wilmington, Delaware. Being a horrid name for all the marketing reasons (kidding, I have no idea why), the company was later renamed Dupont. Fast forward to 1930 when Dupont and General Motors joined to form Kinetic Chemicals to produce Freon.
In January 1935, E.I. du Pont de Nemours and Company formally opened the Haskell Laboratory of Industrial Toxicology, which at the time was "one of the first in-house toxicology facilities." According to a 1935 news item in the Industrial and Engineering Chemistry journal,“the purpose of the du Pont facility was to thoroughly test all du Pont products as a public health measure to determine the effects of du Pont's finished products on the health of the ultimate consumer and that the products are safe before they are placed on the market.”
Now, I’m not going to throw stones or try to spoil the ending here but based on what happens next, I’m not so confident that this Haskell Lab crew was cut out for the job.
In 1937, a 27-year-old research chemist named Roy Plunkett was working with Freon refrigerants and accidentally (yes, accidentally) invented a new chemical. Polytetrafluorethylene (PTFE), a saturated fluorocarbon polymer, would become known as the "first compound in the family of Perfluorinated Compounds (PFCs).” PFCs are a group of hundreds of human-made compounds collectively known as Per- and Polyfluoroalkyl Substances or PFAS or forever chemicals.
After ten years of research, this saturated fluorocarbon polymer would be introduced under its commercial name, Teflon. Side note: Roy would later be inducted into the National Inventor’s Hall of Fame for his invention of Teflon.
DuPont chemical plant in Washington, West Virginia, started using PFAS in their manufacturing process in 1951. Shortly after which, a Dupont employee received an inquiry into the possible toxicity of ‘C8.’ Quick explanation in the most simple way I can: C8 is basically an eight carbon chain chemical structure that includes Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS), which are long-chain PFAS. C8 is super stable and hardy and literally takes forever to break down. OH!! and it’s really good at attaching to soils and migrating into aquifers. So, in 1956, a study at Stanford University found that PFAS binds to the proteins in human blood, and five years later an in-house DuPont toxicologist deemed C8 to be toxic and should be handled with extreme care. Around this same time, it is known that DuPont buried as many as 200 drums of C8 on the banks of the Ohio River near the plant. SPOILER ALERT: This was not a well-thought-out plan.
Alright so that’s the backstory blip as it pertains to DuPont, but please note I’ve left out A LOT about 3M (Minnesota Mining and Manufacturing Company), the Oakdale Dump, PFAS in firefighting foams, Wolverine, and just general poor handling of a potentially toxic substance since way back.
Fast forward to 1998 when Robert Bilott with Taft, Stettinius & Hollister LLP (a Cincinnati based attorney) took the case to represent Wilbur ‘Earl’ Tennant. Tennant was a farmer in Parkersburg, West Virginia, who blamed DuPont’s Washington Works facility for his cattle dying. Ok, so that sentence doesn’t even do it justice. Over 250 of Tennant’s cattle died of a ‘mysterious wasting disease.’ While the cause of death was never conclusively linked with the chemical contamination from DuPont, the company quietly settled with the Tennant family for an undisclosed amount. Sidenote: This farmer did dissections on his own cows in attempts to determine and document cause of death because area veterinarians didn’t want to get involved. He recorded and documented his findings on video including “blackened teeth, liver, heart, stomachs, kidneys and gall bladder; unusual discolorations — some dark, some green — and textures; cows with stringy tails, malformed hooves, giant lesions protruding from their hides and red, receded eyes; cows suffering constant diarrhea, slobbering white slime the consistency of toothpaste, staggering bowlegged like drunks.”
The Tennant family purchased 68 acres along West Virginia Route 68 in 1968 but in 1984 they sold a portion of their adjoining land to Dupont. This land was to become the Dry Run Landfill. The Tennant family claims that there was noticeable difference in the land within a year of the property sale. Cattle began to die, deer carcasses were found, and “there were no minnows in the streams.”
In 1999, Bilott filed a federal suit in the Southern District of West Virginia on behalf of Wilbur Tennant against DuPont. A report commissioned by the EPA and DuPont and authored by six veterinarians (three chosen by the EPA and the others by DuPont) found that Tennant's cattle had died because of Tennant's "poor husbandry," which included "poor nutrition, inadequate veterinary care and lack of fly control."
While performing research during the suit, Bilott found an article identifying a surfactant called perfluorooctanoic acid (PFOA aka C8) in Dry Run Creek. So, in 2000 he requested more information through a court order to DuPont. DuPont was ordered to submit 110,000 pages of documents dating back to the 1950s. A year later (2001), DuPont settled out of court with Tennant for an undisclosed sum. Shortly after which, Bilott made a substantial submission to the EPA and US Attorney General demanding that "immediate action be taken to regulate PFOA and provide clean water to those living near."
While Tennant settled, Bilott filed a class action suit against DuPont in August 2001. According to a 2004 report by ChemRisk, an industry risk assessor hired by DuPont, “Dupont's Parkersburg, West Virginia-based Washington Works plant had dumped, poured and released over 1.7 million pounds of C8 or perfluorooctanoic acid (PFOA) into the environment between 1951 and 2003.”
In 2017, DuPont agreed to pay $671 million to settle with approximately 3,550 personal injury claims involving the leak of PFOAs used to make Teflon in Parkersburg, West Virginia. DuPoint denied any wrongdoing.
Obviously, this is a seriously brief snapshot and by no means an exhaustive history of DuPont’s use and handling of PFAS or use in other applications. Find more information and actions to address public health at https://www.epa.gov/pfas.
From the Center for Disease Control’s website:
“In the Fourth National Report on Human Exposure to Environmental Chemicals (Fourth Report), CDC scientists measured PFOA in the serum (a clear part of blood) of 2094 participants aged 12 years and older who took part in the National Health and Nutrition Examination Survey (NHANES) during 2003–2004. Serum PFOA levels generally reflect exposure that has occurred over several years. By measuring PFOA in serum, scientists can estimate the amount of PFOA that has entered people’s bodies.
CDC scientists found PFOA in the serum of nearly all the people tested, indicating that PFOA exposure is widespread in the U.S. population.”
In summary, some guy accidentally invented a chemical that has been around since the late 1930s and is now being phased out because it has been shown to cause increased cholesterol levels, low infant birth weights, effects on the immune system, cancer (for PFOA), and thyroid hormone disruption (for PFOS)...oh and it will definitely mess up your livestock if they drink from a contaminated water source!
Time to go buy a cast iron skillet!
Recent Posts
The Value of Ergonomics for your Business
By Mary Dunlap, CIH Ergonomics, defined simply, is fitting a job to a person to reduce the risk of strains and injury to muscles, tendons, and ligaments, also known as musculoskeletal disorders (MSDs). The human costs are the best reason for preventing MSDs, but the financial burden to businesses cannot be underestimated. A 2018 survey of days away from work from the U.S. Bureau of Labor Statistics determined that 30 percent of cases were due to MSDs and that MSD cases require 38 percent more lost time days than typical injuries and illnesses. The direct costs associated with a sprain, strain, or hernia type injury can cost a business between $28,000 and $32,000 for medical treatment to resolve the injury. However, the medical costs are only part of the story and do not include indirect costs such as work stoppage, overtime, training of new employees, legal costs, and increased insurance premiums.
What are the benefits of ergonomics programs?
In addition to keeping workers healthy, there are many added benefits to implementing an ergonomics program that ultimately can make a business more profitable and attractive to potential business partners, highly qualified new employees, and outside investors, including:
Reduced costs associated with treating MSDs
Reduction in lost workdays and the length of long-term absences
Lower employee turnover and costs associated with replacing an employee
Higher employee engagement and focus on work quality
Increased productivity and efficiency
Reduced costs for correcting defects
Creating a safety record that is attractive to lenders and outside investors
When ergonomics is regarded as an important part of the operational process, employee engagement is enhanced, as is productivity and work quality. When an employer places value on the ability to perform the job comfortably and efficiently, employees feel respected. From this respect, workers are much more likely to be engaged in their work. With this engagement, comes regard for the quality of work they produce and a willingness to participate in improving processes and performing the work more efficiently. It has been estimated that even a simple improvement can result in a one-percent increase in quality and a five-percent increase in productivity. As attention to detail increases, the defect rate goes down and, with that, the costs for correcting the defects. Safety and sustainability have become very important aspects of how companies operate and are key environmental, social, and governance (ESG) indicators that lenders and investors consider when assessing business performance, assigning corporate credit ratings, and considering new investment opportunities. It is common practice for investors and lenders to request disclosure of injury rates. The top 29 companies that have earned safety culture awards have been found to consistently outperform the S&P 500 stock index.
What are the risks of workplace injuries?
The major risk factors for musculoskeletal disorders are:
forceful exertions involving with lifting, lowering, carrying, pushing, and pulling
repetitive movements, encountered when job cycles are less than 30 seconds long and when the cycle is repeated two or more times in a minute
awkward postures that result from poor equipment or the workspace design, not having the right tool to perform a job, and lack of worker awareness of how to properly move and position their body when performing a task.
Of these factors, the Occupational Safety and Health Administration (OSHA) has estimated that 25 percent of non-fatal occupational injuries result from forceful exertions primarily associated with material handling. The costs associated with treating MSDs can be significant when an injury occurs. Such injuries often result in multiple trips to a doctor or clinic, physical therapy appointments, and even surgery. In addition to treating the injury, lost workdays and sometimes long-term absences create staffing issues which increase overtime costs and losses in production. Additionally, job duties sometimes require modification to accommodate an employee who has been injured. When job tasks remain at risk for injury, there are not only lost workdays directly related to injuries but often there is also an increase in “casual absenteeism”. When strains or injuries are common, workers simply do not want to do the job. As dissatisfaction increases, so does the rate of employee turnover and the costs for replacing an employee. On average, it costs a business 20-50 percent of an employee’s salary to find and train a new employee replacement.
What is included in an ergonomics program?
Ergonomics programs and tools can make a big difference in the comfort, safety, and well-being of workers as well as add money to your bottom line? Actions can range from the simple to the complex and may include:
Implementing a daily stretching program for employees
Frequently rotating workers that perform repetitive jobs during a shift
Providing work surfaces that are the right height for the job
Reducing reach distances for parts or tools
Providing the right tools and equipment such as lift assist devices
Designing new workstations and equipment to best fit workers and their job tasks.
Coach and train employees how to properly position their bodies when lifting and performing tasks to avoid strains and injuries.
Further information
Cornerstone’s Health and Safety department can perform a Worksite Analysis to observe operations, job tasks, and work practices for ergonomic safety. As a Certified Industrial Hygienist, I can provide reports of risks, prioritize areas for changes, and recommend control measures. Contact Cornerstone at info@corner-enviro.com or on our website for more information. Mary Dunlap, CIH, is a Senior Industrial Health and Safety Specialist and Certified Industrial Hygienist. She works with Cornerstone’s clients to develop exposure assessment strategies tailored for their work environments. She regularly performs ergonomic assessments using a variety of OSHA and NIOSH tools to rate severity of risk for work related to musculoskeletal disorders.
Recent Posts
Update SDS Regularly for Better Work Safety
Safety Data Sheets inform employees about the hazards of the chemicals in their workplace, how to obtain information on chemicals, and what to do if a spill or accident occurs with those chemicals in order to provide a safe, secure workplace. The information contained on each SDS also enables organizations to better understand the chemicals they use and how those substances impact the environment. Constant communication of SDS updates to staff is a vital way to promote a positive safety culture in any company. It creates a safer, more informed environment for employees. Changes to SDS can impact the handling or transport of material, as well as disposal methods, and the potential health hazards to employees.
What OSHA regulations require SDS?
The OSHA Hazard Communication Standard (OSHA, 29 CFR 1910.1200(g) and Appendix D) requires manufacturers and importers of a new hazardous chemical to obtain or develop safety data sheets. From there, the manufacturers, suppliers, and distributors are responsible for passing that information along as the product moves through the supply chain. Those entities also are required to update existing SDS as new information becomes available regarding identification, handling, and spill response of hazardous chemicals. This applies to every hazardous chemical they produce or import. The HCS requires that SDSs be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential. The downstream or end users are responsible for the use and maintenance of SDSs, including accessibility to the most recent version of SDSs for all employees. Users can request updated SDS information from the original supplier or manufacturer. All along the supply chain, employers must provide training to employees regarding how to access an SDS and communicate changes to employees in a timely manner.
What other mandates require SDS?
The U.S. EPA also has regulations that address SDSs. These documents were a requirement under the Clean Water Act of 1970 and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980. Subsequently, these were reaffirmed under the Superfund Amendments and Reauthorization Act (SARA) section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), which is also known as Title III. Many state and local environmental and safety agencies have a number of regulations that may redundantly require SDSs. Most corporate safety and environmental protection programs also rely on SDSs to educate and inform workers about dangers in the workplace.
What are the dangers of an outdated SDS?
If a manufacturer chooses not to maintain up-to-date SDS documents on file, they are denying their staff valuable information about specific chemicals substances and how to safely handle them. This puts employees at risk and could lead to workplace incidents and injuries or environmental damage. In addition, OSHA or EPA inspectors have the authority to issue violations and assess fines for non-compliance with SDS-related regulations.
Further Information
With Cornerstone’s Foundation SDS Management and Chemical Inventory System, our Chemical Management team do the work for our clients to ensure that their SDS are regularly updated. For a free demo, contact us.
Yabelin Batista has been with Cornerstone since 2019. She is a member of the Chemical Management department at Cornerstone, Environmental, Health and Safety. One of her main responsibilities consists of sourcing and updating current Safety Data Sheets (SDS) for a wide array of products in our Foundation SDS Management and Chemical Inventory System. Her efforts help ensure our customers have the latest documents available.
Recent Posts
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
Recent Posts
Fast Facts About Tier II
By Rachel Powell Tier II Emergency and Hazardous Chemical Inventory Reports, commonly referred to as “Tier II”, is due annually on March 1st. The following is a quick overview of reporting requirements.
What is EPCRA?
The Emergency Planning and Community Right-to-Know Act of 1986 was created to help communities plan for chemical emergencies. It also requires industry to report on the storage, use and releases of hazardous substances to federal, state and local governments. EPCRA has four major provisions and serves as the governing body for Tier II reporting.
What makes a chemical reportable under Tier II?
Any OSHA-hazardous chemical stored over the federal threshold quantity of 10,000 pounds or more and any extremely hazardous substance (EHS) stored in quantities of 500 pounds or its threshold planning quantity (TPQ), whichever is less. Individual states may have more stringent reporting requirements. Exceeding the threshold at any time during the reporting year triggers the reporting requirement.
What are EHS chemicals?
EPA has designated EHS chemicals as those which could cause serious irreversible health effects from accidental releases. A full list of EHS chemicals can be found on epa.gov.
What storage information is needed to file the Tier II?
Reporting requirements include a section that lists specific location(s) within a facility where reportable chemicals are stored. In addition, the type of container being utilized and exact maximum amount (usually measured in pounds) of hazardous chemicals present at a facility at any one time during the previous calendar year must be reported.
How do I know what reporting requirements exist for my state?
Although each state’s reporting system can vary, Tier II reports must be filed annually with the State, County (LEPC) and local Fire Department. Additional information regarding filing criteria by state, including what fees are associated, can be found at https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures.
How can I prepare for this next year?
Don’t let the March 1 annual Tier II reporting deadline sneak up. Since the spring deadline covers materials for the previous calendar year, it’s important to track all chemicals/products that enter and leave your facility on an ongoing basis. Maintaining on-site inventory throughout the year will allow for a smooth Tier II reporting season.For the past seven years Rachel Powell has served as a Chemical Data Management Specialist at Cornerstone. She assists clients in setting up and maintaining their Safety Data Sheet Foundation System. On a monthly basis she serves as a facilitator who trains new users. She serves as a Tier II Emergency and Chemical Report filer for our clients on an annual basis.
Recent Posts
Using Leading Indicators to Prevent Workplace Injuries
By Joshua Sampia All companies have an obligation to create a safe work environment that allows their employees to do their jobs with minimal risk of injury. Most business understand their obligation to report accidents and illnesses to government agencies at the federal, state, and local level. What if you could use modern technology and trends to not only create a safer work environment but also prevent injuries from ever happening? This would save you time and money from completing reports, medical billing, and insurance claims, as well as reduce lost work time hours.
What are leading indicators?
Leading indicators are data points that can help predict future events and trends. This is where having a proactive safety culture comes into play. Leading indicators can be used to assess workplace culture in order to develop safety plans to minimize risk and increase productivity. OSHA defines leading indicators as “proactive and preventive measures that can shed light about the effectiveness of safety and health activities and reveal potential problems in a safety and health program.” The cost of worker’s compensation claims can range from thousands to hundreds of thousands of dollars depending on the nature of the incident. Having a program in place that can help prevent even one of those claims will automatically pay for itself. There also are many other intangible benefits like reduced costs for worker’s compensation insurance or a reduction in the number of fines. As the saying goes, an ounce of prevention is worth a pound of cure.
Set Goals for Leading Indicators
Most companies have goals set for lagging indicators, such as a threshold for lost work time or number of injuries; however, your organization should also set goals for leading indicators, such as:
Attendance Rates
Safety Observations
Risk Assessments
Preventative Measures and Maintenance
The key to any good program is setting, identifying, and reaching quantifiable goals. For example, we work with a company that had historically relied on lagging indicators such as types of injuries, location, and work task to track injuries. Our team worked with them to implement a more observational approach focused on minimizing future occurrences. They formulated daily observation checklists of employees to determine if they were performing their tasks in an efficient and safe manner. That daily observation data was then aggregated and analyzed develop better safety and training programs. The change has helped reduce the number of injuries and accidents. Incidentally, productivity has also increased. Implementing this kind of process does not have to be a time-consuming process. The daily observations are short checklists of yes or no type questions that take approximately two minutes each day to complete. The checklist can be completed on mobile devices which most staff are currently using in their work tasks. The company also can share observations across multiple departments and shift supervisors to create a network of data for the entire business.
Technology and Software for Worker Safety
There are other examples of using modern data technology to help. Tracking employee training is a great way to ensure a good safety environment. Making sure employees are well-trained and that training is up to date is crucial to safety success. Another important aspect is that you must have a robust program in place to capture and analyze the data. A good system will:
let you easily capture all this information through multiple devices and portals
let you report the data back into multiple formats and reports
have a great dashboard to see a visual representation of the data
improve accountability
It is also critical to have traceability so it is clear who entered what data and when. This is extremely important when it comes to having a chain of evidence.
How can Cornerstone Help?
Cornerstone’s Incident Management and Training Tracking systems can capture all of this information as well a provide data reporting, visual representation, and more. Our applications have highly customizable systems that can adapt to literally any industry including automotive, manufacturing, medical, industrial as well as retail and warehousing. Each system is configured to each company’s specifications and requirements. This can also be accomplished at a cost-effective price point, especially when compared to the cost of having one accident on record. Contact us for details on how Cornerstone can help your facility establish an effective safety program using leading indicators and our industry-leading software systems.
Joshua Sampia is the Director of Product Development. He is responsible for the applications development team at Cornerstone, ranging from web based and mobile applications to device management for safety and environmental compliance and applicability.
Recent Posts
Where the S in ESG Intersects with the HS in EHS
By John Scifres Environmental, Social, and Governance (ESG) rating is all about the long game. Industry has learned if they are to stay in business and thrive in today’s world, they must be sustainable in all facets of their culture. For our Health and Safety Division, the “social” portion means offering our client’s the best tools to take care of their workers. Today, compliance with Environmental, Health and Safety (EHS) regulations is a given and employers are expected to go beyond compliance in their worker safety efforts. The links between employee health and safety, morale, loyalty, and retention are undeniable. Healthy, happy, loyal, and experienced workers make for a sustainable business. Today’s investors know this and demand it from the companies they want to back. Cornerstone helps to improve ESG metrics by maximizing worker health and safety with a stepwise approach from assessment to training.
Assessment
The first step in our Health and Safety Management System services is a baseline assessment of Compliance to get the feel for where a company is in the spectrum from Compliance to Sustainability. It is a Gap Analysis of sorts, but it gives our experienced evaluators a feel for what they have to work with. We present our clients with a detailed report of regulatory applicability including a finding of compliance or non-compliance for each element. For those areas that need work, a Findings and Corrective Actions Summary becomes a compliance punch list that can be attacked quickly and systematically to bring the site into compliance. We can couple a Compliance Assessment with a Culture Assessment to dive even further into needed actions to improve the “S” in ESG. Either along with or as a result of the assessment, Cornerstone then begins the task of evaluating worker health and safety hazards and their risks with a Risk-Based Workplace Hazard Assessment. The goal of this is to assess each job and its component tasks to determine the hazards present. Our evaluators determine the risk of negative outcomes from each task by judging the Severity and Probability of the negative outcome. They assign a numerical score to each and the product of those gives us a Risk Level for each hazard. Of special note is our Ergonomic focus. A critical part of workers’ health and safety is how they feel and move while accomplishing their jobs. Using the risk assessment data our ergonomics team monitors employees in each workstation to ensure a practical solution to complex ergonomic issues.
Control
Generally, we determine an acceptable risk level with the client and anything exceeding that level requires action. Our staff then determines required or recommended controls for each hazard. We use the U.S. OSHA Hierarchy of Controls to guide this part of the assessment. In the end, Cornerstone Health and Safety Evaluators produce a prioritized list of necessary controls. Those hazards with a higher risk level demand more urgent action. Controls often include the development of administrative policies, procedures, and programs. Cornerstone works hard to develop these along with stakeholders at every level of the company. The information gathered during previous steps guides this process. It can range from something as simple as protective gloves to Injury and Illness Prevention Plans and the establishment and facilitation of Health and Safety Committees. Worker Health and Safety training and coaching are integral to making these Administrative Controls come to life.
ESG Reporting
While the methods to arrive at an ESG rating differ, they all have the same end goal in mind; to identify those companies that consider their human resources as a long-term investment in their success. Data from government reports of compliance, worker injury audits, and worker experience of every sort regarding compliance and culture all play into ratings. Everything we do helps our clients prove to the world through ESG score that they are a sustainable business. This is never more evident than in our approach to worker health and safety. We carefully determine compliance gaps, rate the risk of everything done at a client’s operation, and then work closely with all levels of employees at the facility to ensure that compliance obligations are met, hazards are controlled, and workers go home at the end of their workday in the same condition that they arrived. And, we do this over time with the overall goal to continually improve all factors that play into an ESG rating.
Further Information
As ESG reporting becomes more vital and more publicly transparent, Cornerstone’s industrial health and safety experts can help ensure that your programs and data are ready for the spotlight. Contact us at info@corner-enviro.com or through our website.
Recent Posts
Permit Ownership Change is an Important Part of M&A Process
By Cassie Lee It may have been the economic uncertainty of 2020, the emotional rollercoaster of quarantine or too much time to think and reflect on business but I had many clients reach out in the first quarter of 2021 asking for support in changing the ownership on their environmental permits. Just like when you transfer the deed to a house or a title to a car, if a commercial property changes ownership or name, all applicable permits held on the property or facility must be transferred to the new entity. Federal and state environmental regulations and statutes may also apply to the property transfer or merger process. While many permits may be held for a property, the most common Cornerstone assists with transferring include:
Air Permits
Stormwater (NPDES) Permits
Process water Discharge Permits
Wastewater Discharge Permits
Hazardous Waste Identification Numbers
Timeline and Applicability
Many times, the owner entity or individual contact person can be changed during the next reporting period for certain compliance obligations. Unfortunately, since state and local forms and applications vary, there are no hard and fast universal instructions. While a Phase I Environmental Site Assessment and any necessary environmental due diligence assessments occur prior to an ownership transfer, permit transfers are completed after closing. Experienced real estate and environmental attorneys recommend completing these transfers promptly after closing, usually within 60 days.
More Information
Feel free to contact me at clee@corner-enviro.com or (317) 501-7060 to discuss your merger and acquisition environmental, health and safety documentation needs. Cassie Lee is has spent more than 10 years serving Environmental Health and Safety Managers, Human Resource professionals, company owners and presidents navigate environmental compliance and worker safety. Prior to account management, she was in the field executing and reporting for property transactions and building health in the realm of environmental due diligence and industrial hygiene.