May in Indianapolis! Indy 500 Environmental Improvements
If you’ve never experienced May in Indianapolis, it’s an experience like no other. It’s much like celebrating your birthday month… only on steroids! Events celebrating the tradition of the Indy 500 actually start the end of April with the IU Little 500 and Purdue Grand Prix. There is an organized evening of collective porch parties, a fundraising gala at the Motor Speedway, a Festival parade, Carb Day etc. The month is filled with celebration for this time-honored racing tradition! (find a complete list of events here).
Having been a central Indiana resident for 86% of my life, the race and events leading up to it have simply been part of my ‘normal.’ It wasn’t until a few years ago when I watched the release of 1000s of balloons prior to the race that I considered the environmental impact of the Greatest Spectacle in Racing.
While I’m sure there are plenty of areas, we could look at to highlight the impact of Race Day alone, I’ve bulleted a few below that immediately came to mind:
Trash. Speedway officials estimated approximately 50,000 lbs. of trash was left behind after the race in 2013.
Balloons. The release of thousands of balloons was formerly a pre-race tradition. Balloon launches has been paused indefinitely as of April 2022due to impacts on the environment and wildlife.
Spectator traffic. A very conservative estimate from the IndyStar in 2018 reported that spectator traffic at the 500 on race day would produce nearly 20 million pounds of carbon dioxide. By comparison, the EPA reports that the average passenger vehicle emits roughly 10,000 lbs. of carbon dioxide…over the course of an entire YEAR. Calculations were based on using the most popular vehicle in the United States, the Ford F-150.
Fuel consumption. Indy cars use about 115 gallons of fuel on race day alone (roughly five miles to the gallon). Several years ago, IndyCar made the switch to 85% ethanol which does burn more cleanly. Unfortunately, while the air pollutants that affect human health are lower, the fuel still releases carbon dioxide and water vapor into the air which traps heat on Earth
Change is coming.
Last year (2021), the Indy 500 earned the silver level Responsible Sport Certification from the Oregon-based Council for Responsible Sport. The Indianapolis Motor Speedway stated in April 2021 that the 2021 race successfully implemented all mandatory standards of the council, as well as nearly 40 of the recommended social and environmental impact considerations. The Indianapolis Motor Speedway stated in August 2021 that the 2021 race successfully implemented all mandatory standards of the council, as well as nearly 40 of the recommended social and environmental impact considerations.
While I couldn’t readily find confirmation that the Race has earned this distinction again for the 106th running of the Greatest Spectacle in Racing, the Indianapolis Motor Speedway announced the next phase of sustainability initiatives including:
a new race tire made with sustainable natural rubber;
increased waste diversion efforts throughout the facility with expanded recycling and food recovery programs; and
the official IMS retail partner, will open a fully sustainable store inside an electric truck. All items sold in the truck will be reusable or designed from recycled plastic bottles.
So that’s progress.
We hope we can continue cataloging the changes made to the Race and celebrations to decrease the environmental Sasquatchian-sized (it’s a word, I’m sure) footprint. In the meantime, check out my sources and more information on race festivities and efforts below:
https://www.indianapolismotorspeedway.com/planyourvisit/season-schedule
https://cbs4indy.com/news/this-is-who-cleans-up-all-the-trash-left-behind-at-ims-after-indy-500/
https://www.indystar.com/story/news/2018/05/21/indy-500-has-trash-problem/607042002/
#Sustainability #GreenhouseGas #GHG #Indy500
Recent Posts
Controlling Occupational Exposures
The role of an industrial hygienist is to recognize potential exposure hazards, evaluate exposures, provide input for the development of controls, and finally evaluate control methods for effectiveness in reducing exposures.
When controls are warranted, the process begins with a risk assessment to characterize the problem. The hygienist can provide assistance in identifying and characterizing the hazard, the emissions and sources, worker involvement with the sources and how air movement occurs.
Control measures can be grouped into three categories: administrative, engineered, and personal protective equipment. When considering controls, there are five fundamental assumptions to bear in mind:
All hazards can be controlled (to some degree).
There are different approaches for control.
Sometimes, more than one control method is needed.
Some control methods are more cost-effective than others.
Controls may not always be completely effective in limiting the exposure hazard.
Administrative controls place part of the burden of control on the worker and are often not completely effective when used as a single approach. Examples of administrative controls include rotating workers, providing best practice training for performing job tasks, improving personal hygiene, and implementing housekeeping programs.
When considering options, it is necessary to evaluate the sources of exposure, the way in which it can affect the worker, and the route of entry. Typical routes may include unprotected exposure to noise, skin contact or inhalation of vapors and aerosols. The controls considered should be matched with the employee, the process or task, and be cost-effective. In some cases, there are regulatory requirements for controls such as the OSHA (Occupational Safety and Health Administration) requirement for exhaust ventilation for abrasive blasting (1910.94).
Worker rotation is frequently used to reduce the amount of time a worker is exposed to a hazard. A common example is rotating workers performing jobs in high-noise areas. Another example is to move workers every few hours who perform highly repetitive job tasks to reduce musculoskeletal strain.
Training in good work practices can significantly reduce exposures. For example, coaching proper body postures such as how to stand and position the head while welding or reinforcing the need to face forward to work and pivot feet instead of twisting the body.
Good housekeeping and personal hygiene are also important components of administratively controlling exposures. Settled dust becomes a secondary source of exposure with increased air movement, traffic activity and vibration produced by equipment. Frequent cleaning helps to prevent dust accumulating on surfaces.
Training and reinforcing the need for personal hygiene, such as frequently washing hands and avoiding hand to mouth contact while working can reduce the risk of exposure by ingestion. Several standards contained in OSHA 1910 Subpart Z for toxic and hazardous substances mandate personal hygiene practices. Administrative controls are usually used in conjunction with engineered controls.
Although they are more expensive to implement, engineered controls are the most effective since they offer greater cost savings over time. Examples of engineered controls include source modification, substitution, process change, isolation, and ventilation. The development and installation of engineering controls is usually the responsibility of a facilities engineering department and maintenance staff.
Source modification refers to changing an emission source to make it less hazardous. An example of source modification is wetting dust particles released in a foundry shakeout operation to reduce dispersion. Another example may be to reduce temperatures to lower the level of chemical off-gassing and vaporization.
Modifying a process to reduce the hazard is another type of engineered control. An example of this would be to dip rather than to spray paint parts. Automation would also be an example of changing the process. A good example is robotic welding to replace manual welding.
Substitution refers to changing to a different material, type of equipment, or process to reduce the hazard. Examples include substituting a solvent having a low occupational exposure limit (OEL) and higher vapor pressure to a different solvent having no established OEL, or a lower OEL and less volatility.
Isolation refers to separating employees from hazardous processes, equipment, or environments. Isolation can be achieved by placing barriers around equipment or materials, such as the use of ventilated flammable cabinets or placing enclosures around high-noise sources. Isolation separates employees from hazards. Examples are control rooms, isolation booths and supplied air islands.
Ventilation is frequently used as a method to control emissions near the source or to dilute emissions to levels that are acceptable. Local exhaust ventilation (LEV) attempts to eliminate emissions to the work room air. LEV controls are designed to capture, control, or eliminate emissions using control structures such as hoods, exhausted enclosures, ductwork, air cleaners, fans, and exhaust stacks.
General exhaust ventilation relies on fresh air dilution, either by open doors, windows or make-up air provided by air intakes and ventilation systems. For constant emission sources, effective dilution relies on good air mixing and constant air flow.
In addition to engineered solutions, regular and preventative maintenance is an important part of preventing uncontrolled and unexpected exposures. Insufficient maintenance could result in a catastrophic failure such as a rupture failure, increasing leaks from flanges, seals, access doors, and breakdowns of equipment.
Personal protective equipment (PPE) should always be used as the last option for control when other methods of control are not feasible or effective enough to reduce exposure to safe levels. Relying solely on earplugs or respirators places the burden of control on the worker and the protection is only as good as how properly the PPE is fit, worn, and maintained.
There are many different options to help keep workers safety, contact us to evaluate exposure concerns in your facility.
Mary Dunlap is a Certified Industrial Hygienist and has been with Cornerstone Environmental, Health and Safety since 2016. When she is not working, you can find Mary enjoying the outdoors.
Source: Case Studies: Sixty Practical Approaches of OH&S Control Principals. D. Jeff Burton, MS, PE (former CIH (Certified Industrial Hygienist), CSP)
Recent Posts
Making the P2 Connection with the FOUNDATION Product Approval Module
Passage of the Pollution Prevention Act by Congress in 1990 was intended to focus industry as well as the U.S. public on efforts to reduce the amount of pollution being generated across the country.
The law gave the United States Environmental Protection Agency (U.S. EPA) the responsibility and the authority to develop and implement a source reduction strategy. As a result, EPA worked to integrate Pollution Prevention (P2) practices into general industry and reduce pollution “at the source” and not at the tailpipe, outfall, or landfill. The Act also required that EPA collect and disseminate information related to P2 to the public.
After passage of EPA’s mandate, each state then implemented its own P2 program which the federal law required to be as or more stringent than the program implemented by EPA. In the early 1990s, Indiana, for instance, adopted a very narrow definition whereby true Pollution Prevention could only be achieved through process change, in-process closed-loop recycling, or input substitution.
Using Indiana’s model as an example, the state’s goal was to reduce pollution through improved efficiency, recycling/reusing waste before it could be sent to a landfill, and by making changes to the raw materials used in the manufacturing process (input substitution). By focusing on the raw materials used in, or incidental to, production, a facility could identify less toxic materials to facilitate more environmentally safe production processes.
How can Cornerstone help your facility improve its P2 performance?
In the early 1990s, Cornerstone developed a chemical inventory system to analyze and track the chemical composition of materials used in production and manufacturing. Over time, Cornerstone’s chemical inventory system was further developed by adding SDS management to create the current FOUNDATION SDS Management and Chemical Inventory System. In addition, FOUNDATION determines the applicability of substances to the Emergency Planning and Community Right-to-Know Act (EPCRA), Clean Air Act, and OSHA regulations to help ensure continuous compliance.
While working with IDEM (the Indiana Department of Environmental Management) during the development of its P2 program, Cornerstone introduced me to the methodology of using a chemical inventory system to assist with Input Substitution. It seemed like the perfect tool to support P2 efforts through the identification of materials that could be substituted thereby protecting the environment (i.e., P2) and creating safer workplaces.
What can FOUNDATION’s Product Approval Module do?
The Product Approval Module in FOUNDATION enables users to fully evaluate and approve (or reject) materials to be used in their operation. The regulatory lists reviewed range from EPCRA, HAPs, Proposition 65 Chemicals, Carcinogens, Reach, ROHS, and can also incorporate customer-specific restrictions and chemicals of concern. Candidate lists are generated for each applicable regulation to which a chemical is subject. The Product Approval Module is also useful in compiling information for ESG (Environmental, Social and Governance) reporting related to customer requirements.
If a team of individuals is responsible for approving materials to be used in production, Cornerstone’s IT team works with the client to create a fully customized Product Approval system which enables mutual review, evaluation, and approval. A streamlined online approval process such as this eliminates delays in review and ensures a holistic approach product review.
Further Information
For more information or a webinar on our Product Approval system, please contact Cornerstone or your Sales Representative.
Recent Posts
Make Sure Your EHS Recordkeeping is "Turnover-Proof"
It happens all the time... an inspector from EPA or OSHA goes to a facility and asks for copies of required documentation and compliance records.
What happens if you are new to your position and are asked to produce those documents?
You're certain that the previous EHS Manager kept them ‘somewhere’, but you don’t know where. You fumble around at an unfamiliar desk, rifle through a couple of file cabinets, and frantically click files in your company’s shared hard drive. While you are doing that, the regulator is getting annoyed, looking around, and thinking of other questions he or she is now going to ask you.
If the information had been readily available, you could have had them out the door already but, instead, you’re scrambling to locate anyone who might know where the information is stored.
As the economy continues to return to normal and a demand for higher wages increases in many sectors, employee turnover has become one of the biggest issues manufacturing companies must address. It isn’t only hourly employees leaving for greener pastures. EHS personnel are finding new opportunities as well.
So, what happens when they leave and take all their knowledge with them?
Develop a Team to Manage EHS Recordkeeping
EHS recordkeeping requirements don’t stop just because you lose the expertise you’ve come to depend on. If your facility is still operating, you must continue to keep records as required by federal, state, and local regulations. One of the issues that I run into as an onsite environmental auditor is facility personnel not knowing where the records are kept. When longtime EHS personnel leave, many times you don’t know what you don’t know. So, you don’t know what to ask. In other words, when that employee is gone, so are years of institutional knowledge about who submits Tier II reports, who collects used oil bills of lading, who completes stormwater sampling, etc.
One way to prevent this is to create an internal storage system controlled by one person but accessible by many. Have your EHS Manager train two or three people on how to access information in your system. Have those two or three people assess the system and make changes based on their suggestions. One person controlling a recordkeeping system will almost always lead to confusion when someone else tries to use it. Use plain language in file descriptions and group things by media (air, water, hazardous waste, SDSs, HazCom, etc.) and by year.
Have your IT team create a file structure to store those records that is accessible by authorized personnel and regularly backed up to prevent file loss. Make sure that everyone who receives documents (EHS, purchasing, maintenance, quality) knows where those documents are stored. You could even use an outside vendor like Cornerstone and our electronic file cabinet system to help you maintain your documentation. Whatever method you choose to manage this information, ensure it is secure, regularly backed up and that multiple people understand how to access the system.
Turnover is inevitable but you don’t have to be caught scrambling when it happens. Plan for the future by creating redundancy and putting in place a system that can be handed down to the next person.
Recent Posts
The Role of ESG and EHS in Mergers and Acquisitions
To say the past two years have been difficult for manufacturers – big and small – would be a huge understatement! In addition to the unprecedented challenges presented by COVID-19 during 2020 and 2021, businesses must now deal with supply chain issues, labor shortages and surging inflation.
How can an organization balance all of these challenges? Throughout the business world, management teams are working and reworking their strategy to deliver shareholder value. Talk in boardrooms includes the need for additional capabilities, access to new markets, improved marketing of products and services as well as scalability. For smaller companies, business owners may be burnt out and start evaluating their next move. With all the uncertainty, owners are exploring mergers or selling. Step in Mergers and Acquisitions (M&A) specialists which could be comprised of banks or private equity groups (PEGs).
The primary goal of a Merger and Acquisition (M&A) specialist is to help companies grow. The M&A market had impressive increases in the number of transactions in 2021 as compared to 2020. Activity outpaced expectations with record-setting volume and value. Most banks and PEGs expect another strong year of deal-making since they are sitting on record amounts investment capital and cash.
One of the most compelling reasons for companies to consider M&A is the need for or to share technology and digital assets as well as other resources; however, companies merge for a variety of reasons such as entering new markets or to improve business efficiency as well as gain or maintain market position. Even more as of late, many mergers and acquisitions are stemming from the importance of technology in production processes.
Whether your organization is considering acquiring or merging in the near term, or you are preparing your company for a future transaction, the selling as well as the buying side of M&A must be a strategic process that should include the assistance of subject-matter experts to provide guidance throughout the due diligence phase.
For both buyers and sellers, there is a roadmap that should be followed – a playbook of sorts. The roadmap helps establish clear roles and tasks for the team members involved. While there are multiple steps, the due diligence phase tends to be the most time-intensive and stressful. Due diligence consists of a thorough review of EVERY aspect of the entity, such as products, services, customer base, human resource records, financials and regulatory. For all intents and purposes, it is a process that provides information related to value, liabilities and risk.
One important aspect of due diligence are the topics of environmental, health and safety (EHS) and environmental, social and governance (ESG) which have traditionally been overlooked (or delayed to the 11th hour) by M&A “dealmakers”; however, most are now realizing its inevitable rise in prominence. After all, there is clear evidence that socially conscience investors use ESG criteria to screen investments. M&A groups are challenging their teams to ensure sellers and buyers are considering targets to advance an organization’s plan toward sustainability. Both ESG and EHS due diligence reveals information - track records of behaviors and insight into actions and the status of compliance or lack thereof. The resulting information is an aid to investors to identify material risk.
Looking at environmental and safety concerns, dealmakers are increasingly challenged to assess post-close risks associated with non-compliance, pending government inquiries, potential litigation, contamination/remediation and reputational concerns, which can extend to long term operational burdens. The process begins with evaluating risks and opportunities and, in many cases, ends with review of ESG disclosures. (ESG disclosures; how to measure and manage with no common standard is an important and challenging topic on its own!)
Whether you are contemplating M&A or strategizing on how to build value in your organization, it is prudent to ensure ESG and EHS is part of your strategy. Build a culture of competency, conduct due diligence by having a third-party, subject matter expert audit EHS compliance. After all, to make your way through ESG and set sustainability goals, an organization must start from a solid base of regulatory compliance. ESG is a framework to evaluate the overall health and resiliency of an organization – environmental, health and safety are defined by laws/regulations and are mandatory. Some components of the “E” and “S” involve judgement – making choices about conduct that reflect values. Both are essential for the longevity of business today.
Recent Posts
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
Recent Posts
SDS and Document Hosting
A few years ago, Cornerstone was approached by a client that needed to improve how they were delivering branded safety data sheets (SDSs) to users of their products after they determined their staff was spending an excessive amount of time responding to these requests. Having used our IT solutions in the past, they reached out for support to design an automated, efficient system to manage this process and thus our SDS (and document) hosting platform was born.
How does a hosting platform work?
A document hosting application allows customers to visit your web site, search for the document they need and download it immediately.
Let’s look at an example. You sell cleaning products. You have a customer who is looking for an SDS for your brand of stainless steel polish. The customer would visit your website and click on a link which would forward them to a page to begin an SDS search.
After typing in ‘stainless steel polish’, they would be presented with the SDSs that best match from the hundreds of products you sell. The customer then clicks on a link to the exact product they need which would be displayed a PDF of the SDS that can be downloaded or printed.
With Cornerstone’s hosting platform, not only can you deliver SDSs more efficiently, the system also allows for easy distribution of other documents for the products you sell such as technical data sheets, instructions, manuals, or diagrams.
Sounds like it could be expensive and time consuming to set up, right? That’s where Cornerstone’s SDS and Document Hosting solution comes in. Our team will get you up and running quickly, cost effectively and with minimal IT resources required on your part.
Depending on your specific needs, our hosting solution can be deployed as a standalone website or can be seamlessly integrated into your existing website.
Some of the additional features of our Professional plan level include:
User definable fields
Password protection at the site level and at the document level if needed
Multi-language site support
Multi-language document support
Automated document distribution
For more information about Cornerstone’s SDS and Document Hosting platform, contact Cornerstone at info@corner-enviro.com, on our website at https://www.cornerstone-ehs.com/contact-us/ or call (317) 733-2637.
Recent Posts
Go Beyond Recordkeeping with an Automated Employee Training Tracking System
Maintaining accurate training records is important for many reasons including compliance with federal, state, and local laws, conformance with quality standards, as well as improving worker safety and overall productivity. However, many companies continue to rely upon spreadsheets and cumbersome manual processes to track employee training. It is important to ensure a solid process is in place for tracking and maintaining training records. Without such a system, vital training may be missed, leaving employees either unsafe or unqualified for their positions. In addition, your organization may be cited for non-compliance if a regulatory agency performs an audit, and the required data cannot be retrieved.
Develop a Process for Tracking and Maintaining Records
We have been asked by clients numerous times how they should manage training information to help ensure their team is more productive, capable, and safe. The most effective way to track training is to use an automated system to manage the information and tasks involved in the process. A system such as this may be incorporated into a Quality and/or Worker Health and Safety Program to ensure all training requirements are met and the necessary data is captured to maintain certifications and/or OSHA compliance.
Typical Training Data to Track and Record
What should you keep track of, and what is the most effective process? Although organizations may have unique recordkeeping needs, training tracking systems commonly include the following information:
Training required for each role
Frequency of each training type
Completion and refresher dates of training
License and certification validity
Training course materials
Course assessments
Employee evaluations
What tasks can be automated?
Assignments of training based on an employee’s role
Rescheduling of refresher training, as needed, based on the frequency of requirements
Notifications to employees who require training
Easily accessible records of evidence in the event of an audit
Training class rosters
In addition to automating all of the required tasks for training tracking, metrics such as training effectiveness and course assessments can be accessed. Other performance indicators, like how often licenses or qualifications lapse, or the percentage of employees trained, can be used to evaluate the effectiveness of your training program.
Additional Benefits of an Effective Training Tracking System
In today’s business climate, one of the most important benefits of a training program is attracting, training, and retaining employees. You can leverage training tracking to see where employees are deficient and train them in the areas needed. Furthermore, if employees are not continually learning, it may prompt them to look elsewhere for opportunities that foster personal growth.
In short, using automated training tracking tools will help managers become more efficient with their training efforts, which promotes safety, increases job satisfaction, and creates a more educated, skillful, and productive workforce.
Further Information
Cornerstone offers Training Tracking software that helps users capture and retrieve the necessary information to remain current and compliant with applicable regulatory requirements. Our software automates the training process with features such as email reminders, mass scheduling, and monitoring the completion of courses. Contact us to discuss integrating this Training Tracking system into your operations.
Recent Posts
Do You Need a Confined Space Permit?
Many facility managers get understandably confused when they try to decide if they have to comply with the Occupational Safety and Health Administration (OSHA) standard on Confined Spaces (29 CFR 1910.146). OSHA requires all workplaces to evaluate the entire facility and determine if there are any permit-required confined spaces. This process has two steps.
Step 1: Does It Meet the Definition?
You first must evaluate any potential space to see if it meets the definition of a confined space. The OSHA definition of a confined space has three parts:
It is large enough and so configured that an employee can bodily enter and perform assigned work. This means the employee must fit his entire body into the space.
It has limited means of entry or exit. This could mean a single entry/exit or multiple entries/exits that are very small or hard to get through.
It is not designed for continuous employee occupancy. For example, it is not designed to have an employee inside while the system is in operation.
If any spaces meet all three of these parts, then it is a confined space. If it only meets one or two, it may still be a hazardous area, but it is not a confined space, and 29 CFR 1910.146 does not apply. As an example, a basement may meet the first and second parts but, as it is designed for employee occupancy, it would not be a confined space.
When it does meet all three of these parts, then the facility must determine if its employees will enter the space. If they will not enter the space, the facility still has requirements to secure the space to make entry difficult, install signage marking the hazard near the point of entry, and train employees where the spaces are and why they should not enter.
If employees will enter the space, then you must conduct Step 2.
Step 2: What Is the Hazard Type?
You must evaluate each space to see what hazards may exist. OSHA has identified four potential hazards in a Permit-Required Confined Space
Atmospheric: It contains or has a potential to contain a hazardous atmosphere. Such spaces may lack oxygen, contain toxic gases, have flammable vapors, or hold combustible dust.
EH&S Managers should keep in mind that some spaces may only temporarily have hazardous atmospheres. Tanks and pits that do not normally present a risk could develop a hazard episodically or accidentally. An example could be a pit that fills with a heavy vapor from a nearby propane fueling area or vehicle fumes.
In order to determine if your space meets any of these conditions, the facility must use an air monitor; normally a three-gas meter that detects oxygen levels and, toxic and flammable gasses. In addition, you must train any employees who would enter the space to use the meter
Engulfment: Contains a material that has the potential for engulfing a person. This would include either liquids (water or chemicals) or solid materials (like dusts, grains or resins). If an worker sinks into particles up to his diaphragm, he has the potential to be asphyxiated before he can be rescued. Even if a space is temporarily empty, facility managers should remove the potential for the space to fill by locking out any pipe or valve systems that could fail and fill up a space while an employee inside.
Entrapment: The defined confined space has an internal configuration that can trap or asphyxiate an employee by inwardly converging walls, sloping floors, tapering spaces. Dust collection systems are examples of the inwardly converging walls, while ventilation systems may slope downward and taper at the ends.
Others: Any other recognized serious safety hazard. This covers a multitude of potential hazards such as electrical, thermal, corrosives, and mechanical hazards such as rotating parts, augers, or blades.
If the confined space has one or more of the above hazards, then it falls under the OSHA requirements of a Permit-Required Confined Space for entry. The employer must prepare a written program that details how the company will protect the employees who enter the space including preparing a permit, training employees, monitoring the space to ensure acceptable conditions are maintained, and emergency rescue equipment.
Exemptions
There are two potential exemptions to the regulation. Employers can install equipment to eliminate mechanical or electrical hazards from the exterior before entering the space or add a forced-air ventilation system to disperse atmospheric hazards. In each of these exemptions, OSHA requires clearly defined procedures and periodic testing to ensure worker safety.
Safety First
Dozens of workers are injured each year in confined spaces. It is the employer’s responsibility to ensure that any entry into a confined space must be according to the rules and be safe. It’s up to you to get your employee home safely at the end of every shift.
Cornerstone offers the most comprehensive hazard evaluation service in the industry, call us today to discuss your confined space program. www.corner-enviro.com
Recent Posts
Winter Weather Driving Safety Tips
The onset of winter weather brings to mind the obvious hazard of cold stress; however, workers also can be exposed to weather-related hazards while driving.
Winter Driving
Employers should encourage workers to implement safe driving behaviors. The first step should always be to assess the risk of driving in winter weather conditions. Crashes can be avoided if workers recognize the hazards of driving on snow-and ice-covered roads and train to drive safely in slick conditions. Employers should establish driver safety policies; monitor drivers’ safety performance; and enforce driving rules.
To ensure safety, employers must implement an effective maintenance program for all vehicles and equipment operated. A vehicle inspection to determine proper functioning should include:
Brakes: Brakes should provide even and balanced braking. Also check that brake fluid is at the proper level.
Gas Tank: keep the tank at least 1/2 full.
Cooling System: Ensure vehicle cooling systems have the proper level and mixture of antifreeze and water.
Electrical System: Check the ignition, battery, and alternator belt.
Engine: Inspect all engine systems.
Exhaust System: Check exhaust for leaks.
Tires: Check tread depth, signs of damage or uneven wear, proper tire inflation.
Oil: Check oil level.
Visibility Systems: Inspect all exterior lights, defrosters, and wipers. Install winter windshield wipers.
Work Zone Traffic Safety
Workers can be struck by vehicles or mobile equipment in work zones. This leads to many injuries and fatalities annually. During snow and ice events, vehicles can skid causing drivers to lose control. It is important to properly set up work zones with traffic controls identified by signs, cones, barrels, and barriers, to protect workers. Workers also need to wear proper PPE such as high visibility vests, jackets, and pants when entering work zones.
Stranded in a Vehicle
If you are stranded in a vehicle, stay in the vehicle. Call for emergency assistance if needed, but be aware that due to severe weather, response time may be slow. You should also call someone, such as a family member or your employer, and notify them of your situation. Do not leave the vehicle to search for assistance unless help is visible within 100 yards. Signal distress by hanging a brightly colored cloth on the vehicle’s radio antenna and raising the hood.
To help keep warm, turn on the vehicle's engine for about 10 minutes each hour and run the heat. Also, turn on the vehicle's interior lights when the vehicle is running as an additional distress signal. However, you should beware of carbon monoxide poisoning. Keep the exhaust pipe clear of snow and open a downwind window slightly for ventilation.
Watch for signs of frostbite and hypothermia and maintain good blood circulation by doing minor exercises, such as clapping your hands and moving your arms and legs occasionally. Try not to stay in one position for too long. Staying awake is vital so that you will be less vulnerable to cold-related health problems. Use blankets, newspapers, maps, and even the removable car mats for added insulation. However, you should avoid overexertion since cold weather puts an added strain on the heart. Unaccustomed exercise such as shoveling snow or pushing a vehicle can bring on a heart attack or make other medical conditions worse.
Cornerstone's safety experts are ready to help you develop a world-class safety program and train your workers in the latest safety information. Contact us at info@corner-enviro.com for more information or view our website at www.corner-enviro.com
Recent Posts
Expedite the Sale of Industrial Property with a Limited Site Investigation
Cornerstone has recently seen an increase in client requests to prepare a limited site investigation report for commercial or industrial properties they are preparing to sell. Although it is the responsibility of the prospective purchaser to conduct a Phase I Environmental Site Assessment (ESA) compliant with ASTM E1527-21, when the seller has a limited site investigation in-hand, the process can be accelerated.
Why should a property owner conduct a Limited Site Investigation before selling property?
Companies selling a property often find that making the report available to potential buyers helps to address any obvious concerns an ESA would characterize as a Recognized Environmental Condition (REC), such as an open disclosure of subsurface conditions. When the prospective purchaser is made aware in advance of any potential cleanup requirements, they can estimate the associated costs and evaluate their risk, making the purchasing decision more transparent and faster.
What if the property is clean?
If the report indicates there is no soil, groundwater, or vapor sampling exceeding a regulatory threshold, the seller has an advantage over other potentially contaminated sites the purchaser may be considering. It is still the responsibility of the purchaser to complete a Phase I ESA in order to get the protection of the Comprehensive Environmental Response, Compensation and Liability Act’s (CERCLA) innocent land owner defense under All Appropriate Inquiries (AAI).
What if the report indicates areas of concern?
When the results indicate there may be a need for further site investigation into the nature and extent of an environmental condition, the buyer and seller can negotiate how to proceed and contact a qualified environmental professional for further examination.
Seller companies should note though, if the investigators finds certain levels of contamination in the subsurface, the investigator, the current owner, or the buyer may be required to report the findings to a state or federal agency. If this occurs, the company can consult with their attorney for specific legal guidance or to protect their interests.
Contact Cornerstone
If your company has decided to sell your commercial real estate, you may want to consider conducting a limited site investigation to help expedite the sale process. Contact Kevin Mallin at kmallin@corner-enviro.com or (317) 489-3249 with any questions concerning this topic or other Environmental Remediation concerns.
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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.
Recent Posts
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.
Recent Posts
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.
Recent Posts
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!