Environmental Services Jonathon Lewis Environmental Services Jonathon Lewis

The History of Earth Day

After celebrating the 53rd Earth Day this past weekend, it seems like an opportune time to look back at the history of Earth Day.

After celebrating the 53rd Earth Day this past weekend, it seems like an opportune time to look back at the history of Earth Day as many of the rules and regulations Cornerstone works with now came about because of Earth Day.

A Wisconsin Senator by the name of Gaylord Nelson was the one behind getting the very first Earth Day started. He was worried about the shape of the environment in the U.S and, after taking notice of the energy behind the anti-war protests by students, decided that something similar could be done to raise public awareness about air and water pollution. The original plan for Earth Day, before it was even given the catchy moniker, was for a teach-in on various college campuses to the national media on April 22nd; however, that all changed when a young activist named Denis Hayes, who was in charge of organizing the event, decided to promote it across the country. His efforts helped gather a number of individuals, groups, and organizations together and it was decided to change the name of the event to “Earth Day”. 

The first Earth Day took place on April 22nd, 1970 and the response from the American people was overwhelming. Over 20 million people went out to protest, rally, and demonstrate across the nation to bring attention to the environment and its importance. For anyone curious, the population of the United States of America in 1970 was over 200 million people; meaning that about 10% of all Americans turned out for Earth Day and supporting the environment (Census Bureau, 2021). Earth Day was so effective that by the end of the year, Congress approved and the President signed the Clean Air Act into effect as well as the creation of the Environmental Protection Agency; both of which are just as, if not more, effective and relevant today at defending our environment. It could be said that this helped get the ball rolling for other key environmental legislation to be passed, such as the Clean Water Act, Safe Drinking Water Act, Resource Conservation and Recovery Act (RCRA), and Toxic Substances Control Act (TSCA).

Earth Day later went on to become recognized around the world, with groups from a wide variety of countries taking part in the efforts to raise awareness about the importance of protecting the environment. Earth Day has even taken on the effort to raise awareness about the need to address the growing issue of climate change. Even after 50 years, Earth Day is still observed by about 1 billion people across the Earth.

Some people participate in Earth Day through more political means by joining marches, protests, letter-writing campaigns and other public demonstrations to raise awareness and show support for the environment. Others volunteer for various environmental projects, cleaning up trash from their local beach or park, planting trees and/or other native plants, cutting down invasive species, and even educating others in their local community about the importance of the environment. You don’t have to solve the climate crisis to take part in Earth Day.


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Environmental Services Chris Marshall Environmental Services Chris Marshall

Setting Yourself Up for Success: Air Compliance Inspections

Picture this…. it’s a beautiful April day, and it’s the first warm day of the year. You walk into work feeling refreshed and energized, confident of the great day that lies ahead. You begin your morning routine… maybe you scroll through your email or daily schedule, or perhaps you enjoy a cup of coffee or tea and chat with a coworker. When out of nowhere, your phone rings. It’s security. There’s a state inspector is at your gate for a surprise air audit. Suddenly, you’re a little less confident in the great day that lies ahead and a lot more stressed out.

Sound familiar? Whether you call this an air audit or an air inspection, any EHS manager knows this exact scenario, as we have all been through it before. No matter what you call it, these unexpected visits from any regulatory agency can be a hassle. I worked as an environmental manager in industry for several years; however, prior to that, I worked as a state inspector. By seeing both sides of air inspections, I learned a lot… some of which I would like to pass along to you by offering advice on how to not only make air inspections go quicker, but also give the inspector exactly what they need.

1. Read your permit!

Although this may seem obvious, there are many managers who have either only partially read their permit or haven’t read it at all. Knowing what information an inspector will request and what machines they want to see will ensure a speedy inspection.

2. Ensure you are familiar with past inspection reports and corrective actions.

Before an inspector shows up at your door, review past inspection reports and ensure that corrective action has been taken from previous violations. This shows the inspector that you and your company take environmental compliance seriously. The state typically takes more aggressive action on violations that occur more than once.

3. Make yourself aware of regulations that are not contained in your permit.

Not knowing that you were applicable to regulations is not an excuse for non-compliance. Although most states do a sufficient job of including all applicable federal regulations in their air permits, what about the regulations that are passed between your facility’s permit cycles? The most common federal regulations affecting industrial sources are those concerning boilers and stationary generators. If you need assistance in determining your applicability to federal air regulations, Cornerstone offers a NESHAP and NSPS applicability determination to ensure your facility is in full compliance with all applicable air regulations.

4. Always have a hard copy of your most recent air permit somewhere that is easily accessible.

The inspector will most likely have their own hard copy with them when they request a tour of your facility. They will ask questions related to identifying the emissions units and operations listed in the permit. Having your own copy of the permit in front of you to field questions will make the tour go much more quickly and smoothly.

5. Know the terminology in your permit.

If you call a certain emission unit “Axle Refurbishment Booth” and IDEM calls it “Paint Booth #5” in your permit, it’s going to take both yourself and the inspector several minutes trying to match up emissions units to what is at your facility. Although this problem is easily resolved during permitting activity, it is of no help to you during a surprise inspection.

6. Keep all of your air recordkeeping in one place.

If you prefer to retain hard copies, keep all permit-required records (as well as the permit itself) in a labeled binder or file that is easily accessible. If you retain records digitally, ensure that all records are kept in one file that is easily accessible, regardless of internet availability. Storing all air recordkeeping in one place not only speeds up the inspection itself but also serves as a security blanket if you are on vacation when the inspector shows up and your second-in-command has to conduct the inspection.

7. Use the exact phrasing in your records as the permit.

This allows the inspector to quickly and easily skim your documents for compliance. Ensure that your units of measure match the units of measure in the permit limits and audit your own records to ensure that all permit-required information is reflected in the records. It is a good practice to highlight the “final” data such as tons of pollutants per year to draw the inspector to the most important information.

8. Regularly communicate with other departments about recordkeeping needs.

If the permit-required recordkeeping involves information from other departments in your company such as purchasing, don’t wait until the day of an inspection to request those records. On a monthly basis, send out a request for information (i.e., purchase records, usage information, etc.) to the necessary departments. This will ensure that you can provide an inspector with information in a timely manner.

9. Make note of any non-operational dates.

If you have daily records such as pressure drop readings, it is necessary to note which days your units were not in operation. If an inspector reviews records and sees days with nothing noted, they will assume that this is a missed record. A good rule of thumb to operate under is that it doesn’t count if it’s not written down.

10. It is important to speak with discretion during an audit.

Although it is important to be kind, allow the inspector to ask questions before providing technical answers. Air compliance is full of acronyms and jargon. If you accidentally say the wrong term, the inspector’s interest could pique and open a can of worms you did not mean to open.

During the peak of COVID lockdowns, most state agencies turned to alternative inspection protocols such as requesting records virtually and performing outdoor-only inspections. As we enter 2023, Cornerstone sees a mix of states who have maintained COVID protocols, states which have created hybrid in-person and virtual inspections, and some states that have gone back to full on-site unannounced inspections. It’s important to be prepared for any of these possibilities and respect the timeline that your inspector has provided.

Air inspections can be intimidating, but by setting yourself up for success and following audit best management practices, you can ensure that all future air inspections are quick and hiccup-free.


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Environmental Services Jonathon Lewis Environmental Services Jonathon Lewis

Sustainability and the Increasing Demand for ESG Reporting in Business

A growing number of investment groups, businesses, employees, and other relevant stakeholders are starting to ask companies about their sustainability and ESG (Environmental Social Governance) metrics. Some companies are even receiving requests to disclose their sustainability performance through various ESG reporting frameworks. Many companies find themselves unprepared to respond to such questions.

To better understand this trend, it is important to understand what sustainability and ESG are. Why should companies care about these concepts? Why are stakeholders asking about sustainability programs and requesting ESG disclosures through reporting frameworks? What are these ESG reporting frameworks? All these questions and more will be answered here.

What is sustainability and ESG?

Sustainability is commonly defined as the ability to meet the needs of the present without jeopardizing the ability of the future to meet its own needs (United Nations Brundtland Commission). While sustainability is usually associated with the environment and topics such as climate change, renewable energy/energy use, and water use, this is only one-third of what makes up sustainability. The other two parts of sustainability consist of the economy and society. These three parts, often referred to as the three pillars or spheres of sustainability, are interconnected. Doing something in one sphere can affect (for better or worse) the other two spheres. The idea of sustainability is to affect all three areas in a positive way.

ESG falls under the umbrella of sustainability and is very similar. So much so that, for all intents and purposes, the terms could be used interchangeably. The difference, however, is that rather than looking at the economic side of things, ESG looks at the governance of an organization through scopes such as data management, anti-corruption, and other policies and procedures. ESG is mostly used in business settings and functions as a more quantifiable type of sustainability, with ESG metrics providing an easy way to measure and compare sustainability performance. ESG disclosure refers to the process of publicly reporting an organization’s sustainability and ESG performance. Organizations tend to either: 1) release a Corporate Social Responsibility report detailing their sustainability performance over the past year, or 2) disclose the relevant information in accordance with one or more ESG reporting frameworks.

Why should companies/organizations care about sustainability and ESG?

Aside from the benefits to the environment and society, sustainability can also benefit the business itself. Many sustainability and ESG-related initiatives are aligned with business goals, at the same time, just as many business-related initiatives can be aligned with sustainability and ESG. The difference lies in the intent behind the initiative. The following are real-world examples of initiatives that address both sustainability and business goals:

  • Reducing the number of natural resources needed (or wasted) to manufacture a certain product can benefit the environment by conserving those resources but it also benefits the company by reducing overall costs.

  • Diversity, Equity, and Inclusion initiatives address the governance side of ESG but can also benefit the company itself. As a result of such inclusivity, existing employees may decide to stay and prospective employees may decide to join, thus improving talent acquisition and retention.

  • Assisting the local community through a food drive or community service event addresses the social side of ESG while also benefiting the company through a positive brand image, possibly helping to cultivate beneficial community connections.

Many environmental regulations are aligned with sustainability to some degree. Therefore, by pursuing certain sustainability initiatives in these areas of regulation companies can be better prepared for any stricter regulations if they come. Furthermore, there is the potential for these companies to qualify for some financial or tax incentives based on different ESG metrics or for implementing different sustainability initiatives.

ESG metrics are important for any organization or business to consider. Various ESG metrics can help identify areas of improvement in a company as well as potential problems before they become serious. ESG metrics are also helpful for tracking progress in a company's sustainability performance. Disclosing ESG metrics and sustainability performance is important for improving transparency, something a greater number of stakeholder groups are looking for in a company.

Sustainability efforts and ESG can also trickle down (or, rather, up) from clients to companies, from companies to their suppliers, and vice versa. If a company or supplier can’t meet their clients’ needs for sustainability, they may lose those clients to another firm that can. Overall, businesses that disclose their ESG performance and/or make efforts to improve their sustainability gain an advantage over their competitors.

What are ESG reporting frameworks?

ESG reporting frameworks help stakeholder groups understand how sustainable a company is by providing measurable and quantitative metrics; thereby enabling comparisons to be made between similar companies as well as displaying measurable improvements to a company’s sustainability efforts.

There are several major ESG reporting frameworks currently being used: GRI Standards, SASB Standards, CDP, and TCFD. Although there are other reporting frameworks out there, those listed above are perhaps the most common.

GRI (Global Reporting Initiative) Standards were some of the first ESG reporting standards to be developed and GRI remains one of the most prevalent ESG frameworks. There are about 32 reporting standards from three sections: environment, economy, and people (though not all of these standards need to be addressed or reported on). Organizations that are reporting in accordance with the GRI standards need only prioritize reporting on their material topics; topics that represent an organization’s most significant impacts on the environment, the economy, and people and their human rights.

SASB (Sustainability Accounting Standards Board) Standards consist of 77 standards for various industries, all of which are focused on the ESG issues most relevant to the financial performance and enterprise value of an organization.

TCFD (Taskforce on Climate-related Financial Disclosures) does not have any standards but rather recommendations for climate-related disclosures around four key company areas: Governance, Strategy, Risk Management, and Metrics and Targets.

CDP (formerly known as Carbon Disclosure Project but now just CDP) consists of three questionnaires for ESG reporting: Climate Change, Water Security, and Forests. An organization can report through one questionnaire or all of them. When completed, organizations are provided a letter grade based on the quantity and quality of questions answered. CDP reporting is completed annually and, in order to qualify for a grade, must be submitted mid-year.

While many of these frameworks differ in the level of detail and information required, they also tend to overlap, working together to achieve their common goal of improved transparency. For example, the climate-change questionnaire for CDP actually addresses all the recommendations from TCFD. This allows organizations to report through CDP while also reporting in line with the TCFD recommendations.

Why are stakeholders asking about sustainability and requesting ESG disclosures through ESG reporting frameworks?

As sustainability has grown in demand, investors, businesses, and other stakeholder groups have started taking it into account when making business decisions. People are becoming more environmentally and socially conscious if only to protect their bottom line. As a result, companies and businesses unable to keep up may lose out on valuable investors, clients, or even employees to competitors that are more sustainable (or at least transparent with their ESG metrics). Companies wanting an extensive sustainability report may request relevant ESG metrics or a complete ESG report from each of their suppliers and distributors in order to determine the full extent of their environmental and social impact. Recently, major automotive companies have requested that their suppliers disclose annual greenhouse gas emissions through an ESG framework or other reporting forum.

Automotive manufacturers, however, aren’t the only ones requesting their suppliers conduct ESG audits. In November, the White House administration proposed a new rule that could roll out in 2023: the Federal Supplier Climate Risks and Resilience Rule. This rule would require federal contractors receiving more than $50 million dollars in annual contracts from the U.S. Federal Government to report their greenhouse gas emissions and assess their climate risks through CDP. Federal contractors with annual contracts between $7.5 and $50 million dollars would only be required to report on their scope 1 and 2 greenhouse gas emissions. On top of this, there is a proposed ruling from the U.S. Securities and Exchange Commission (SEC) about requiring ESG-related metrics in company disclosures.

In general, sustainability and ESG are likely something that companies and organizations will be seeing more of soon, regardless of regulations. Sustainability isn't just about social and environmental impacts, but also about bettering the economy and business as a whole.


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Health and Safety Services Tyler Sandy Health and Safety Services Tyler Sandy

Occupational Exposure to Crystalline Silica: Possible Revisions

There are 2.3 million people in the U.S. alone that are exposed to silica at their workplace. Silica can be found in materials like sand, stone, concrete, and mortar which are in products such as glass, pottery, ceramics, brick, and artificial stone. High exposure to silica can result in diseases like Silicosis, lung cancer, chronic obstructive pulmonary disease, and kidney disease. The action level OSHA established is 25 µg/m3 and the permissible exposure limit is 50 µg/m3.

On March 25, 2016, OSHA made a final decision regarding occupational exposure to respirable crystalline silica. The standard established much needed action levels and permissible exposure limits which are calculated based on an eight-hour time-weighted average. The standard, however, did not establish a medical removal provision and only established medical surveillance provisions. Medical removal provisions are important for OSHA recordkeeping because if an employee meets or exceeds the limits during their medical surveillance, the employee must be removed from work. When an employee is removed from work for a medical condition or after surveillance, it is considered a recordable injury/illness due to an employee accumulating days away from work or restricted work. As of January 2023, there is not an established medical removal provision for crystalline silica, but there is a strong possibility this may change this year.

In the Spring of 2022, the U.S. Court of Appeals for the District of Columbia Circuit concluded that OSHA failed to explain why a medical removal provision was not included in the 2016 decision. As a result, a meeting to discuss further consideration was created and deliberation is currently scheduled for May 2023. If the change is made, it would have a major impact on industries across the country.

The importance of adding a medical removal provision, from an OSHA recordkeeping and employee health standpoint, is apparent but this doesn’t include a company’s financial and employee and employer relations point of view. Hypothetically, let’s assume that a company’s grinding operation exposes a dozen associates to a level where they are required to be medically removed from work. The grinding operation would need to be halted completely until certain controls have been made to reduce exposure for associates to continue working. Depending on the severity of the exposure, this could take months or even years to install equipment or create a respiratory protection program that reduces or eliminates exposure. This same company would also have to communicate this information to their employees, who may choose to leave due to unhealthy working conditions.

This potential change is one of many examples of why air sampling monitoring is vital to maintain a safe work environment. Silica monitoring should be completed at least on an annual basis or whenever there are process changes that may affect employees’ level of exposure to silica. In most cases, air sampling monitoring for silica can be completed in a single day with results coming back within the same month. Lastly, whether a medical removal provision is added or not in May 2023, there is a strong likelihood one will be established in the future, so getting a head start on monitoring and, if necessary, creating exposure controls will help long term.

Tyler Sandy is a Health and Safety Specialist and consults with clients in the area of worker safety. Tyler's experience includes industrial hygiene services, safety training, RCRA as well as OSHA and EPA compliance. His experience includes working with the packaging industry, railroad, welding, warehouse, food and medical waste, chemical manufacturing, and casting.


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Environmental Services Bill Hess Environmental Services Bill Hess

Is Your Environmental Program Getting the Recognition It Deserves?

Companies have made significant strides over the past decades to achieve regulatory compliance. As of late, more and more businesses have been highlighted in the media for going above what is asked of them in an effort to become stewards for environmental consciousness. One of the most effective means to accomplish this goal is to implement an Environmental Management System (EMS). An EMS provides the framework to develop your system for maintaining compliance with environmental regulations by establishing a set of policies and procedures to follow. The EMS reduces the guesswork and unwanted actions that sometimes occur in daily operations which can lead to non-compliance issues.

Many state agencies promote regulatory compliance through voluntary programs that provide instruction on how to implement an EMS and encourage participation in a range of recognition programs. For example, Indiana sponsors the Environmental Stewardship Program (ESP) and a Governor’s Award for Pollution Prevention. These are separate programs, but both are intended to recognize regulated entities that go above and beyond current environmental regulations.

Applications for these programs can be tedious and time-consuming and can get lost in the shuffle of your other daily routines and responsibilities. Cornerstone’s team can assist in exploring these state-specific recognition programs and, after working with your team to determine which program best fits your needs, scoping the project to keep it manageable. Additionally, we can assist in completing and submitting the application for a recognition program in your state.

Our Division of Quality Management Services has decades of experience in every aspect of developing an ISO 14001 EMS as well as other comparable programs. In addition to full-service implementation consulting, we offer the following services:

  1. Aspects and Impacts – Conduct onsite evaluations and written findings.

  2. Policies and Procedures – Drafting and oversight of policies and procedures.

  3. Application Submittal – Completing and submitting applications for approval.

  4. Audits – Conducted at specified intervals for program compliance by a third party.

  5. Projects – Sustainability projects with carbon footprints, energy audits, waste to energy, and solar.

Contact Cornerstone for support in meeting your Environmental Recognition Program and be the leader in your state.

Bill Hess is Cornerstone’s Manager of Business Development, Northern Midwest Region. He has been on a career path in Sustainability for more than 40 years and just celebrated 22 of those years with Cornerstone. He specializes in ensuring our clients have the resources they need for Environmental Management, Safety Culture Improvement, Loss Prevention, ISO Services, Safety Training, Industrial Hygiene Services, and SDS (MSDS) Management.


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Health and Safety Services Emily George Health and Safety Services Emily George

Safety Signs 101: Understanding the Basics

Improper hazard communication including failure to properly follow safety sign regulations is one of the top 10 workplace violations cited by OSHA and contributes to thousands of workplace accidents each year. OSHA standard 1926.200 indicates that appropriate signage must be visible when performing work in at-risk areas. OSHA regulation 1910.145 tackles the specifications for accident prevention signs and tags. It discusses the different categories, colors, wording, and tags of signs.

Regularly checking the accuracy and visibility of safety signage at your facility is one of the easiest and most effective ways to prevent workplace injury. In fact, studies indicate that well-placed safety signs can minimize workplace accidents by up to 80%. This article will review standard 1910.145 to help you stay in compliance.

Categories and Colors

Danger Signs

Danger signs indicate immediate danger and that special precautions are necessary. The colors of the sign are red, black, and white. The image below is outside a construction site where there is a danger of falling objects. Therefore, as a safety precaution, hard hats must be worn in that area.

 

Caution Signs

Caution signs warn against potential hazards as well as against unsafe practices. The sign should be yellow with black lettering. The example below is of the wet floor sign we often see placed on freshly mopped floors of businesses.

 

Safety Instruction Signs

Safety instruction signs are used where there is a need for general instructions and suggestions relative to safety measures. The background should be white with a green panel and white letters. Any letters used on the white background should be black. You’ll often see the green signs around eyewash stations, safety showers, and exits.

 

Slow Moving Vehicles

If you have ever traveled in the Midwest during planting or harvest season, there is a good chance you have gotten stuck driving behind farming equipment. You might have noticed a triangle emblem on the back. Vehicles with a speed of 25 mph or less on public roads are considered slow-moving and are therefore required to display the triangle emblem. To make the sign visible both during the day and at night, the emblem is fluorescent yellow-orange with a dark red reflective border.

 

Wording

The wording of all signs follows the same general rules. If there is text, it must be clear, simple to read, and easily understood. The language must also be accurate and make a positive suggestion. The word "biological hazard" or "biohazard" must only be used to refer to infectious pathogens that are a danger or potential risk to human health.

 

Accident Prevention Tags

A tag is a label typically made of cardstock, paper, pasteboard, plastic, or other material that is used to classify a hazardous condition. Tags consist of a signal word and a major message. A signal word is intended to catch the pedestrian’s attention and should be able to be read from at least five feet away. Signal words include "Danger," "Caution," "Biological Hazard," "BIOHAZARD," or the biological hazard symbol (see below). You might also see “Warning” which can be used if the hazard level is between “Caution” and “Danger.” A major message identifies the hazardous condition or instruction for the employee and can be in the form of written text, pictographs, or both. Examples are “High Voltage” or “Do Not Use.” A pictograph uses pictures to represent a hazardous condition. With the help of tags, hazardous situations can be recognized and a warning to workers can be issued.

Conclusion

While this is not intended to be an exhaustive list of all the regulations relating to safety signs, it is a good basic introduction to the OSHA standards for signs. For more information, the ANSI standards Z53.1-1967 and Z535.1-2006 provide additional details on the regulations as referenced in the OSHA standard. If you would like to learn more about sign regulations, additional OSHA regulations regarding signs are referenced below.

  • 1910.146 (c) – requiring signs for confined spaces

  • 1910.335 (b) – electrical hazard signs

  • 1910.37 (b) – signs for exits

  • 1915.16 – employee comprehension of signs and labels


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Health and Safety Services Roger Andrews Health and Safety Services Roger Andrews

Keep Pedestrians Safe from Forklift Accidents with OSHA Safety Training

It all begins with an idea. Maybe you want to launch a business. Maybe you want to turn a hobby into something more. Or maybe you have a creative project to share with the world. Whatever it is, the way you tell your story online can make all the difference.

Don’t worry about sounding professional. Sound like you. There are over 1.5 billion websites out there, but your story is what’s going to separate this one from the rest. If you read the words back and don’t hear your own voice in your head, that’s a good sign you still have more work to do.

Be clear, be confident and don’t overthink it. The beauty of your story is that it’s going to continue to evolve and your site can evolve with it. Your goal should be to make it feel right for right now. Later will take care of itself. It always does.


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Environmental Services Emily George Environmental Services Emily George

Back and Neck Pain: Is Your Posture To Blame?

Is it not uncommon to hear someone complain about a sore back or a stiff neck. While many people experience these discomforts, very few give their posture much thought. Your posture, however, has an impact on your life both inside and outside of the office. As a matter of fact, the cause of your discomfort may very well be due to poor posture. Here are some questions to keep in mind throughout the day to help evaluate your posture.

While sitting, ask yourself:

  • Are your shoulders back?

  • Is your back straight?

  • Is your head in line with your back?  

  • Are both your feet flat on the floor?

  • Are your knees at a 90-degree angle?

  • If using a keyboard or mouse, are your arms at a 90-degree angle with your wrists flat?

While standing, consider:

  • Are your shoulders back?

  • Is your back straight?

  • Is your head in line with your back and not titled to look at a screen?

  • Are your hips level?

  • Are your feet shoulder width apart?

  • Are you engaging your abdominal muscles?

If you answered no to any of those questions, that’s okay! Even I answered no to some questions. It does mean, though, that your posture could use some work.

Maintaining proper posture will help you avoid injuries and muscle pain that can prevent you from working or doing household chores. Your muscles work more efficiently with good posture.

Here are some tips to have better posture:

  • Take a wall test.

    • Stand with your heels roughly 4 – 6 inches from the wall with your shoulder blades and buttocks touching the wall. Measure the distance between your neck and the wall. Repeat with your lower back. Both measurements should be 2 inches or less.

    • If there is too much space between your back and the wall, engage your abdominal muscles a little more.

    • If there is not enough space or you have no space between you and the wall, arch your back enough so that you could fit your hand comfortably in the gap.

  • Create mental reminders to check your posture.

    • Every time you are stopped at a red light, think about your posture.

    • Put a sticky note on your monitor at work to remind you to sit correctly.

    • When you enter a new room, think about your standing posture.

    • On your phone or favorite device, add a daily digital reminder to correct your posture.

  • Replace standard equipment with products that have an ergonomic design.

    • Keyboards, computer mice, desks, footrests, gardening tools, and even snow shovels have an ergonomic option. Next time you go to purchase an object, see if there is an ergonomic option.

  • Strengthen your muscles

    • Do some yoga or Pilates to help strengthen your muscles and improve your posture.

It is never too late to improve your posture. It takes work and dedication to continually have good posture. Just taking a few minutes each day to remind yourself about your posture could make a big difference in your neck and back pain.


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Health and Safety Services David Blane Health and Safety Services David Blane

OSHA Injury and Illness Recordkeeping and Reporting Requirements

Preventing workplace injuries and illnesses is always the focus of any company’s health and safety program; however, despite best efforts to eliminate workplace hazards and reduce risk, workplace injuries and illnesses still happen.

In my current position in the private sector and as a former OSHA Compliance Officer, I have provided safety and health consultation to employers in a wide range of industries. In both roles, I have noticed that many employers are not aware of their worker safety compliance obligations. Typical requirements that may be overlooked include injury and illness recordkeeping and reporting, documenting those records with sufficient detail, or submitting required records in a timely manner.

OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation, 29 CFR 1904, provides the compliance obligations for employers for recordable workplace injuries and illnesses. Many employers with more than ten employees are required to keep a record of serious work-related injuries and illnesses. (Certain low-risk industries are exempted). Minor injuries requiring first aid only do not need to be recorded. Visit the following links for more information on these topics:

During my career, I have found that some employers do not record occupational injuries and illnesses altogether. The basic requirement for recording listed in 29 CFR 1904.7(a) states: The employer must record any work-related injury or illness meeting the general recording criteria. That is, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. Also, if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

OSHA Injury and Illness Recordkeeping Forms

Employers must use the required forms (or forms soliciting equivalent information). OSHA provides the following forms for injury and illness recordkeeping purposes:

Recording Details and Following Instructions Required by the Form

In my experience, when an employer has kept injury and illness records, the records lack the detail required and the instructions were not followed. There are numerous examples of this: not classifying the case correctly; entering the wrong information on number of days away from work or days of restricted work; incorrect tallying of injury and illness case totals; or lack of employer representative signature are a few examples commonly mentioned.

Maintaining and Posting Records

The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.

Severe Injury Reporting

Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.

Electronic Submission of Records

On many occasions, I’ve noted that an employer has failed to submit injury and illness records to OSHA in a timely manner or not at all. OSHA’s Injury Tracking Application (ITA) provides a secure website that offers three options for injury and illness data submissions. You can manually enter your data, upload a CSV file to add multiple establishments at the same time, or transmit data electronically via an API (application programming interface).

Who is covered by this reporting requirement?

Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to electronically report their information to OSHA. Remember, these criteria apply at the establishment level, not to the firm as a whole.

  • The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.

  • The establishment's industry is on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the size of the establishment.

  • The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is NOT on Appendix A to Subpart E of OSHA’s recordkeeping regulation.

What must covered establishments submit?

Covered establishments must electronically submit information from their OSHA Form 300A.

When must covered establishments submit their completed Form 300A?

  • Establishments must submit the required information by March 2 of the year after the calendar year covered by the forms (for example, by March 2, 2022 for the forms covering calendar year 2021).

  • If the submission due date of March 2 has passed, establishments that meet the reporting requirements and failed to do so must still report their Form 300A data through the ITA and can do so until December 31.

Does OSHA provide training for the general public on recordkeeping requirements?

Yes. Through its national network of OSHA Training Institute (OTI) Education Centers, OSHA offers the OSHA #7845 Recordkeeping Rule Seminar course. This half-day course covers the OSHA requirements for maintaining and posting records of occupational injuries and illnesses, and reporting specific cases to OSHA. Included in the course are hands-on activities associated with completing the OSHA Form 300 Log of Work-Related Injuries and Illnesses, OSHA Form 300A Summary of Work-Related Injuries and Illnesses, and the OSHA Form 301 Injury and Illness Incident Report. To search for specific course locations and dates, please visit the OTI Education Centers searchable schedule.


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Health and Safety Services Josh Sampia Health and Safety Services Josh Sampia

Proactive Steps That Can Prevent Workplace Incidents

Most people are familiar with the basic regulatory requirements facilities must meet under their respective reporting regimes. Many of these requirements involve documenting incidents AFTER they occur and then performing risk or root cause analysis to drive potential change in the workplace. There is no doubt these are important steps in creating a safer workplace culture, but what if you could have a safer workplace before waiting for something bad to happen?

This is where the concept of a behavior-based safety program comes into play. Programs like these are setup so that you can identify unsafe conditions and behaviors and perform risk analysis operations on them; thereby eliminating potential accidents before they ever occur.

What would this look like in practice?

  • Observations

Having a daily observation program in place to monitor workers during the day for five minutes can have a huge impact. A simple observational program can be easily formed and effortlessly repeatable. Those small observational data points can then be combined to provide trends to safety managers to see if there are changes necessary to the safety program.

  • Checklists

In this instance, employees are provided with a checklist of things to do to operate efficiently and safely in their environment. This can be anything from lockout/tagout procedures, work procedures and/or training manuals for specific equipment operation. Having clear-cut directions simplifies tasks and makes them much safer.

  • Goal Setting

Establishing identifiable safety goals to work towards can also make your workplace safer. Everyone is familiar with the typical “days without incident goal”, but there are many other achievable victories to be had. Reducing the number of days with PPE infractions is an example. Combining goals with small incentives will eventually save money by helping to reduce incident costs, lower insurance costs, and prevent the loss of productivity.

This may seem like a lot of work to prevent something that may not even happen, but I promise it is worth the time and effort to set up a system to automate these tasks. To help, Cornerstone has built systems that manage these elements and can provide templates and startups to get a new, more proactive safety management system off the ground quickly and easily.

Not only does Cornerstone have the applications to easily manage all this data, but we have the expertise and knowledge behind all our systems to provide insights, offer advice and guide our users in the right direction. All of this combined has saved our customers time, money, and lives. That’s the ultimate end goal of any safety system: to provide a productive work environment for employees and see them all go home at the end of each shift safely. We are proud to provide our clients with the tools and knowledge to help make that happen.

Joshua Sampia is the Director of Product Development. He is responsible for the applications development team at Cornerstone, ranging from web-based and mobile applications to device management for safety and environmental compliance and applicability.


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Electronic Services Yabelin Batista Electronic Services Yabelin Batista

What to Expect During FOUNDATION Training

Cornerstone offers different training modules depending on what type of electronic service a user has access to including FOUNDATION Training, File Cabinet, Calendar Compliance, and Vision Training.

Recently, I was asked to assist with training for the FOUNDATION (SDS Management) System. Although I often work with the FOUNDATION system internally at Cornerstone, learning to lead one of these training events introduced me to many new features of the system which can benefit all users.

In our FOUNDATION training, we cover:

  • How to use the provided submittal form to help with adding and removing Safety Data Sheets (SDS).

  • How to locate an SDS through simple and advanced search options by using any category or site-specific cross-reference set-up

  • How the advanced search can be customized to fit your needs.

    • Do you need to quickly find which chemicals have an EHS in the constituents?

    • Do you need to have the ability to identify which materials have the highest VOC to ensure continual Air Permit compliance?

  • How to print secondary container labels based on the GHS information on the SDS which is entered by Cornerstone’s Chemical Management Department.

  • Maintaining current Tier II reporting year inventory for each SDS or product.

  • How to access past reported Tier II reports.

Please join us for one of our monthly FOUNDATION training sessions to learn about the many things that your system has to offer.


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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/timeline-toxics-release-inventory-milestones

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.

  1. Type(s) of common transportation routes for EHS chemicals to and from facility.

  2. Process for Shelter in Place and/or Evacuation of Onsite and Off-Site populations

  3. Process for Alerting/Warning the Public and Special Facilities

  4. How many individuals trained in emergency response and what are their respective training levels/capabilities?

  5. List the equipment or resources available for hazardous materials response at the facility

  6. 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 Services Cassie Lee Environmental Services Cassie Lee

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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Health and Safety Services Josh Sampia Health and Safety Services Josh Sampia

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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Environmental Services Catherine Nies Environmental Services Catherine Nies

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:

  1. 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.

  2. Location: facilities within a half mile of navigable waters or conveyances to navigable waters.

  3. 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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Environmental Services Greg Towler Environmental Services Greg Towler

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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