Risk Assessment: The Starting Point of Health and Safety Management Systems
Starting at the Beginning
Over the past couple of years, the focus on a systematic approach to worker health and safety has never been greater. Whether due to unprecedented illness records due to the pandemic or a greater focus on how their workers’ health impacts a company’s sustainability, it is something that is gaining momentum. A key first step in creating the basis for an occupational health and safety management system is to assess the risks that a company faces. This assessment is the starting point to controlling risks and keeping workers healthy and safe.
Tackle the Most Important Things First
One of the key advantages of a risk-based approach is that the most important and risky things are worked on first. Every organization has a limit to their available resources. Allocation of these resources is critical. Traditional job hazard analysis does not provide as distinct of a list of priorities as using a risk-based approach. Hazards are simply identified for control with little or no explicit ranking of needed action. Incorporating risk analysis into job hazard analysis is the key to prioritizing controls to best utilize resources.
Take Advantage of Worker Participation
Cornerstone begins the task of evaluating worker health and safety hazards and their risks with a risk-based workplace hazard assessment. This is a cooperative practice with the workers who face the hazards. Along with HSE managers and supervisors in the work areas, each job and its tasks are assessed to determine the hazards present. The team then determines 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 risk and the product of those gives us a risk level for each hazard.
Control the Risks
We determine an acceptable risk level with the team and anything that exceeds that level requires action. Our staff will then determine required or recommended controls for each hazard. We use the US OSHA (Occupational Safety and Health Administration) Hierarchy of Controls to guide this part of the assessment. In the end, Cornerstone Health and Safety evaluators produce a prioritized list of needed controls. Those hazards with a higher risk level demand more urgent action. This action is designed to reduce the risk level. Either through eliminating the hazard, minimizing the severity, or decreasing the probability, the list of hazards and their risk level shifts as controls are implemented. This automatically shuffles the priorities so that, again, the highest risks are controlled first.
Whether done to conform to an ISO Standard, for ESG (Environmental, Social and Governance) efforts, or simply to improve as a corporate citizen, the development of a formal occupational health and safety management system is more and more commonplace. Nearly all formal standards rely on a risk-based analysis of hazards as a starting point for the system. These analyses help organizations identify all the hazards, determine the level of risk they present, and prioritize them for action. Talk to Cornerstone more about how we can help you in your efforts to continually improve your occupational health and safety management system.
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West Virginia v EPA
On June 30, 2022, the Supreme Court’s decision in West Virginia v. Environmental Protection Agency was filed. In a 6-3 opinion, the Court ruled that Congress did not grant the Environmental Protection Agency (EPA) in the Clean Air Act (CAA) the authority to devise emission caps on carbon emissions. Headlines swept the nation ranging from disappointment to outright misinformation.
How Did We Get Here?
The Clean Air Act was passed in 1970 as a comprehensive federal law that regulates air emissions from stationary and mobile sources. The CAA covers a wide scope of air topics including the National Ambient Air Quality Standards (NAAQS), State Implementation Plans (SIPs), and lays the groundwork for Major Source thresholds (a.k.a. the Title V Program). The CAA has been used by the EPA for decades to regulate sources of air pollution and create environmental programs, even if the CAA does not expressly mention the pollutant or program.
As society advanced and technology furthered our ability to evaluate sources of air pollution, many environmental leaders and researchers began to address carbon emissions throughout the country. Did you know that coal-fired power plants are the single-largest source of carbon emissions in the United States? In 2015, as a response to the growing need for regulations to curb carbon emissions, the EPA created the Clean Power Plan (CPP) in order to address carbon dioxide emissions from existing coal and natural gas-fired power plants. The EPA cited Section 111 of the Clean Air Act as the basis for the CPP. Although Section 111 promulgates New Source Performance Standards, certain pollutants from existing sources were regulated under Section 111(d). Under this section, individual states set the actual enforceable rules surrounding an environmental program, while the EPA set the emission limit with which the entity must comply. Interestingly, this section of the CAA has only been cited a handful of times since the CAA’s enactment in 1970. The CPP set emission limits based on three different criteria, most of which encouraged a shift in energy production from high-emitting sources to low-emitting sources (i.e., a change from coal to renewable energy).
As a result of both lobbying efforts and administration changes, the CPP was stayed by the Court in 2016 and underwent a cycle of repeals and rebranding for several years. The EPA reevaluated the regulatory authority of the plan (specifically the use of Section 111(d)) and replaced the CPP with the Affordable Clean Energy (ACE) rule, based on a different Section 111 citation than before. With the promulgation of ACE, many states and industry leaders petitioned the courts on the legality of the EPA’s regulatory reach.
This issue was finally brought to the Supreme Court in West Virginia v. Environmental Protection Agency. In a 6-3 opinion, SCOTUS invoked explicitly for the first time in court history the “major questions doctrine”. The major questions doctrine requires that Congress speak clearly when authorizing agency action in certain extraordinary cases to strike down an agency rule. In summary, the court ruled that because the CAA did not explicitly address carbon emissions, the EPA could not use the CAA to do so. In the future, Congress would have to either amend the CAA to explicitly include carbon emissions or pass an entirely new act.
This leads us to June 30, 2022. The SCOTUS opinion was handed down, and the news took the public by storm. Headlines ranged from “Supreme Court Limits EPA’s Power to Curb Emissions” (Harvard School of Public Health) to “US Supreme Court Deals Blow to Climate Action” (Human Rights Watch). I saw countless posts across social media platforms claiming that SCOTUS had taken away the government’s right to regulate any air pollutants, as well as concern for the future of global warming and carbon emissions. In light of the sensationalism that surrounded this court ruling, it is important to know the facts and how they may impact the future of our legal system, as well as the EHS (Environmental, Health and Safety) industry.
What did the court do?
SCOTUS ruled that Congress must pass explicit legislation giving the EPA authority to regulate carbon emissions from coal and natural gas-fired power plants.
What did the court NOT do?
West Virginia v. EPA did not limit the EPA’s power to regulate and control criteria air pollutants (carbon monoxide, ground-level ozone, lead, nitrogen oxides, particulate matter, and sulfur dioxide) and hazardous air pollutants.
What does this mean for me?
If your organization isn't a coal or natural gas-fired power plant, this regulation does not directly affect your operations or current regulatory requirements.
What does this mean for the future of the EPA?
The court’s precedent of the major questions doctrine will put all agency regulations under a microscope of scrutiny. Any agency regulation (whether it be the EPA, DHS, DOT (Department of Transportation), FCC, etc.) that does not derive from an explicit act of Congress will most likely not receive interpretive deference from the courts.
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The Legacy of the Bhopal Gas Tragedy
As we wrapped up the Toxic Release Inventory (Form R) reporting for the year, curiosity got me as to how this program came about. So, I decided to refresh my memory and dive back into my college years during which I studied Environmental Management at Indiana University.
The Environmental Protection Agency (EPA) has a great website filled with amazing resources and content. However, in looking for detailed information on the history of a specific regulation, they tend to provide only a summary -- presumably to allow space for more current resources.
This is the EPA version of how TRI came to be:
On December 2, 1984, a cloud of extremely toxic methyl isocyanate gas escaped from a Union Carbide Chemical plant in Bhopal, India. Thousands of people died that night in what is widely considered to be the worst industrial disaster in history. Thousands more died later as a result of their exposure, and survivors continue to suffer from permanent disabilities.
The incident raised public concern about toxic chemical storage, releases, and emergency response. It led to the passage of the Emergency Planning and Community Right-to-Know Act (EPCRA) under the 1986 Superfund Amendments and Reauthorization Act. Section 313 of EPCRA established the Toxics Release Inventory.
Boom! There you have it…explained, right? Yeah, not so much.
Here’s the more detailed -- but not too wordy -- version of what happened… But, before I get into the aftermath of this catastrophic event, let’s discuss what led to it.
When the facility was built in Bhopal (in the 1970s), the site was zoned for light industrial and commercial use, not for the hazardous industry, as the plant was approved only for the formulation of pesticides. MIC was only to be imported in small quantities. However, pressure from competitors in the chemical industry led to the manufacture of raw materials and intermediate products for the formulation of the final product. This was inherently a more hazardous process.
By the early 1980s, the plant had significantly reduced production due to a decrease in demand for pesticides. Local managers of the UCIL plant were instructed to close the plant in preparation for sale in the summer of 1984. When no buyer was found, UCIL made plans to dismantle key production units. All the while, “the facility continued to operate with safety equipment and procedures far below the standards found in its sister plant in Institute, West Virginia.” It seems the local government was aware of the safety issues but hesitant to place burdens on the struggling industry at risk of losing the economic gains afforded by such a large employer
“The vent-gas scrubber, a safety device designed to neutralize toxic discharge from the MIC system, had been turned off three weeks prior. Apparently, a faulty valve had allowed one ton of water for cleaning internal pipes to mix with forty tons of MIC. A 30-ton refrigeration unit that normally served as a safety component to cool the MIC storage tank had been drained of its coolant for use in another part of the plant. Pressure and heat from the vigorous exothermic reaction in the tank continued to build. The gas flare safety system was out of action and had been for three months.”
On Sunday, December 2, the 100 workers on the late shift at the Union Carbide India Limited (UCIL) facility in Bhopal, India were in the process of making the pesticide Sevin. This involved mixing carbon tetrachloride, methyl isocyanate (MIC), and alpha-naphthol.
While most of the one million residents of Bhopal slept, at 11:00 p.m. a plant operator noticed a small leak of MIC gas and increasing pressure inside a storage tank.
Around 1:00 a.m. on December 3, 1984, more than 40 tons of methyl isocyanate gas leaked from the pesticide plant. Within hours, an estimated 3,800 people perished, and the final death toll is estimated to be between 15,000 and 20,000 which includes premature deaths reported during the two decades following the disaster.
In a settlement mediated by the Indian Supreme Court, Union Carbide Corporation accepted moral responsibility and agreed to pay $470 million to the Indian government to be distributed to claimants as a full and final settlement. By the end of October 2014, according to the Bhopal Gas Tragedy Relief and Rehabilitation Department, compensation (~$486,101,760) had been awarded to 574,366 people (dependents of the deceased, seriously injured, permanently disabled, cancer and kidney patients, and temporally disabled people). This averages out to approximately $846.33 per person.
This disaster cast a spotlight on the urgent need for enforceable international standards for environmental safety, preventative strategies to avoid similar accidents, and help ensure industrial disaster preparedness.
Enter the Emergency Planning and Community Right to Know Act (EPCRA) and Toxic Release Inventory (TRI).
TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. U.S. facilities in different industry sectors must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery, and treatment. (A "release" of a chemical means that it is emitted to the air or water, or placed in some type of land disposal.)
https://www.britannica.com/event/Bhopal-disaster
https://www.epa.gov/toxics-release-inventory-tri-program/what-toxics-release-inventory
https://ehjournal.biomedcentral.com/articles/10.1186/1476-069X-4-6
https://www.history.com/this-day-in-history/explosion-kills-2000-at-pesticide-plant
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Stormwater "Red Flags"
Many years ago, I interned for the local County Health Department and assisted them with water quality monitoring. The department monitored the water quality from twelve points along the rivers and streams in the county. Rain or shine, I headed out every Wednesday morning to collect samples. At each location, I pulled on the hip waders and walked a few meters from the shore to measure oxygen levels and collect a sample for the lab. Every week I plated petri dishes and counted E. coli colonies. Some days the water quality of the river was excellent and other days the bacteria levels (E. coli) in the river were dangerously high. What spiked the levels of bacteria levels in a body of water that moved over 30,000 cubic feet per minute? Rainfall, or more accurately: the pollution that the rainfall carried.
I later found out that some of the sampling locations were near animal farms, hence the E. coli. Water is often called the ‘universal solvent’ because more substances dissolve in water than in any other liquid. The Clean Water Act defines the term “pollutant” broadly.
“[A pollutant] includes any type of industrial, municipal, and agricultural waste discharged into water. Some examples are dredged soil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt and industrial, municipal, and agricultural waste.”
The Environmental Protection Agency and state governments work hard to protect waters through the implementation of the National Pollutant Discharge Elimination System (NPDES) permit program. Many industries obtain NPDES general stormwater permit coverage if they discharge into water of the United States. Sampling from a site’s discharge point(s) is an important part of the general NPDES permit. The data is compared with benchmark thresholds as an indicator of the effectiveness of the permit and stormwater control measures. Unlike an air permit, a stormwater sample result that exceeds one of the benchmark thresholds is often considered a “red flag” as opposed to a violation.
No one wants to have a “red flag” when they submit their stormwater results, but it may point to a problem with an exposed pollutant source at your site or a stormwater control measure that is not working correctly. Stormwater regulations protect our waters and, ultimately, protect our drinking water and health. As cliché as this sounds, our actions upstream impact our water downstream. Whether it’s general housekeeping at your facility or making sure a driver safely transfers material from your site, every action matters. Monitoring the exterior of your facility weekly is a great activity to ensure your site is not unintentionally polluting. Atypical events such as a leak or spill that was not cleaned up can be caught in time before the rainfall.
Remember that rivers, despite their size and capacity, can be significantly impacted by our actions. Let’s minimize the pollution the rain carries to keep the rivers healthy.
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Indiana Facilities: Additional Filing Step for Tier II Required
Submission of Tier II form is required under Section 312 of the Emergency Planning and Community
Right-to-Know Act of 1986 (EPCRA) is due annually by March 1st. The purpose of the form is to provide State, local officials, and the public with specific information on potential hazards including the locations and amount, of hazardous chemicals present at facilities during the previous calendar year.
For Indiana facilities that report at least one extremely hazardous substance (EHS), an additional step in the filing process will be implemented for reporting year 2022. The EHS list identifies chemicals that could cause serious irreversible health effects from accidental release. To assist the Local Emergency Planning Committees (LEPCs) in development of their hazardous materials response plans, facilities will be asked[CL1] to complete six required inquiries on the Tier II.
Type(s) of common transportation routes for EHS chemicals to and from facility.
Process for Shelter in Place and/or Evacuation of Onsite and Off-Site populations
Process for Alerting/Warning the Public and Special Facilities
How many individuals trained in emergency response and what are their respective training levels/capabilities?
List the equipment or resources available for hazardous materials response at the facility
Provide the name, title and contact information for the individual(s) who has the authority to commit the facility’s resources in time of emergency.
Facilities reporting a pure or a mixture EHS (i.e., lead acid batteries) will be asked to provide response to each question per the Indiana Department of Homeland Security.
If your Indiana facility is contracted with Cornerstone to file Tier II reports, you would have received an email in mid-May with the questionnaire in preparation for these new requirements to be applied to Reporting Year 2022.
If you’re ready to make Cornerstone your Tier II partner, contact us at info@corner-enviro.com
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Environmental History: DOCUMERICA
From what I’ve been told, I’m right on the cusp of being either a Gen Xer or a Millennial -- a Xennial as it were (that weird micro generation born between 1977 and 1985). I tell you this because it’s important to note that cell phones weren’t in existence during my youth and disposable cameras didn’t become widely affordable until my teens. My dad took his ‘good’ Nikon everywhere and fancied himself an amateur photographer. He was good at it too (still is), especially outdoor photography. He’d have the film developed on slides which filled countless carousels. Then, he would pull out a wall-sized, retractable screen to entertain viewers with family slideshows.
Gas shortage 6/1973
As you might guess, imagery and the art of photography became ingrained on me. I have always adored old photographs. Black and white, sepia, vintage, full color…I just love it. I think “Why? Why this shot?” “What compelled the photographer to shoot this?” “Did this scene or these people mean something to them?” “What was it?” And, photos of people are even more intriguing to me! Just the same, when I came across the DOCUMERICA Project, I was absorbed! (and, I think you will be too…
For the DOCUMERICA Project (1971-1977), the Environmental Protection Agency (EPA) hired (at $150/day + film and expenses) freelance photographers to “photographically document subjects of environmental concern”, EPA activities, and everyday life across the United States in the 1970s.
The collection reports over 22,000 photographs in the U.S. National Archives and they’ve digitized more than 15,000 photographs from the series Documerica (Local ID 412-DA) and included them in an online catalog.
I encourage you to visit the catalog linked above. It’s an addictive time capsule of imagery. The visuals are haunting, beautiful, and compelling.
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OSHA Form 300A Compliance
Form 300A is the summary of work-related injuries and illnesses occurring at your facility during the previous year. Employers are required to post this information at their location from February 1 through April 30 of the following year.
Just like Tier II compliance, summaries are required for each individual plant or facility under your management. Separate logs and summaries should be maintained at each site.
One of the more recent developments, however, is that summary information must be submitted to OSHA through their online portal if your facility meets certain size and industry requirements. For more information regarding requirements for industry, you can use OSHA’s FAQ website here: https://www.osha.gov/injuryreporting .
The rule requiring establishments with over 250 employees to submit the entire 300 Log and not just the summary was amended and is no longer required; however, facilities must continue to maintain those records and are required to provide them to an inspector upon request.
So, how can Cornerstone help?
Our Incident Management program will not only help you accurately collect and maintain incident information, but it can also provide customization and control well beyond OSHA’s generic spreadsheets and manual collection. It will also keep backup archives so this information can never be lost.
All facilities are required to submit information through the OSHA Injury Tracking Application (ITA) website. Cornerstone can help by automatically generating files in “.csv” format to upload to the OSHA ITA program to save you time entering the summary data for every single facility. Even for a single facility, it is much more efficient to upload the csv file rather than manually entering the data.
In addition to proving a summary to comply with reporting requirements, the program will automatically generate the “.pdf” files necessary for display at the facility. Again, this is not a reporting requirement, but is required for compliance.
This is just a fraction of the benefits an incident management system can provide. Most importantly, it can help drive a healthier and safer workforce while also easily keeping you in compliance with electronic recordkeeping requirements.
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Proposed Changes to CWA Discharge Planning
In late March, the Environmental Protection Agency (EPA) proposed the “Clean Water Act Hazardous Substance Worst Case Discharge Planning Regulations.” The proposed rule will require all non-transportation related onshore facilities that store hazardous substances with potential to cause substantial environmental harm above Clean Water Act (CWA) threshold amounts to prepare and submit a Facility Response Plan (FRP) to the EPA. The response plans will address potential worst-case discharges into or on navigable waters or conveyances to navigable water under adverse weather conditions.
The rule will apply to facilities meeting the following criteria:
Capacity to store certain substances: facilities with a maximum capacity above 10,000 times the Reportable Quantity (RQ) of CWA hazardous chemical such as sulfuric acid, ammonia, benzene, sodium hydroxide, hydrochloric acid, etc.
Location: facilities within a half mile of navigable waters or conveyances to navigable waters.
Potential harm (based on past chemical releases or modeled worst case discharges): facilities which meet the first two criteria will have to evaluate whether a discharge could cause harm to public water system receptors or to fish, wildlife, and sensitive environments. A facility will also be required to submit an FRP if they have met the capacity and location criteria and have had a reportable discharge of a CWA hazardous substance within the last five years.
Even if a facility did not meet all three criteria, an EPA Regional Administrator could still require the facility to complete an FRP based on site-specific factors.
The response plans will include identification of qualified individuals and key response resources, hazard evaluations, drills and exercises, release detection, response actions, and communication plans with Local Emergency Planning Committees (LEPC).
EPA enacted regulations for worst case discharges of oil under 40 CFR Part 112, subpart D in 1994. It has not proposed any regulations for CWA hazardous substances until this rule, which could affect a variety of industries and manufacturers. The proposed rule considers the impact of climate change on increased discharge risks as well as impacts to communities with environmental justice concerns.
Recently, the EPA extended the comment time for the proposed rule to July 26, 2022. When the final rule is issued, facilities will be required to determine if they are subject, and if so, prepare and submit an FRP within twelve months of the effective date of the rule. Newly constructed facilities will be required to submit a FRP before starting operations. In addition, updates to the FRP will be required every 5 years or within 60 days of a change that impacts the facility’s potential to cause substantial harm to the environment.
Catherine Nies is a Chemical Data Management Specialist. Her responsibility focus on the output end of our Foundation system verifying the information and deciding what reports to produce, including Tier II, permit summaries, EPCRA reports, and any other high priority needs of our clients. A second responsibility for Catherine is tracking EPA, OSHA, CDC, state and local regulatory updates.
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1-bromoprane: Its Regulatory Evolution from Unregulated to a Hazardous Air Pollutant
Remember 10 to 12 years ago when solvent salesmen were touting a great “alternative” to Trichloroethylene or TCE. The alternative was 1-bromopropane (1-BP). It had several appealing selling points since it worked almost as well, it was unregulated and, thanks to the removal of “once in, always in”, the solvent swap could get sources out of the Halogenated Solvent Cleaning NESHAP (40 CFR 63, Subpart T). As a result, a large number of industrial users flocked to it. Yeah, it was more expensive, but what was the downside? There wasn’t one at the time (at least they thought).
It didn’t take long to figure out that 1-BP wasn’t some inert, benign chemical. In fact, the Department of Health and Human Services classified it as “reasonably anticipated to be a human carcinogen”. The US EPA then followed their standard protocol of first throwing it on a petition to add it to the hazardous air pollutant (HAP) list on February 6, 2015.
Later that year, 1-BP was added to the 313 Chemical list as it was to be tracked and potentially reported for sites that qualified for TRI 313 reporting beginning with RY 2016 by sources that clipped the usage of 10,000 pounds per year for Otherwise Used chemicals.
Fast forward almost 7 years later and finally, on December 22, 2021, the EPA signed the final rule adding 1-BP to the HAP list. The ruling was published in the January 5th Federal Register, and went effective February 4, 2022.
So, if your operation uses 1-BP in a vapor degreaser, aerosol solvent, or other form of degreaser, it would behoove you to react as quickly as you can. Depending on your operations, you may find you only require a minor modification to your air permit, or it could result in a change to your permitting level. Either way, jump on it or seek out a professional consultant with knowledge in this area (yes, I can help), whatever makes the most sense for you.
So, what’s going to happen down the line for 1-BP? It could find its way into a NESHAP. That would be kind of ironic since it became famous for getting sources out of a NESHAP. Go figure!!
Further Information
Cornerstone’s air experts follow the state permitting regulations that affect our clients very carefully. Contact us at info@corner-enviro.com to discuss your facility’s situation and how it may affect any new project plans.
Greg Towler is a Senior Air Quality Project Manager whose role is to oversee and perform air permitting and compliance-related projects and work directly with clients to achieve full compliance. He also performs compliance work in wastewater, stormwater, hazardous waste generation, EPCRA reporting and general environmental compliance.
#CleanAirAct #EPA #Sustainability
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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
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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.