OSHA's New National Emphasis Program: Safeguarding Workers in High-Risk Industries from Warehouse Injuries and Heat Hazards
OSHA recently launched an NEP focused on preventing injuries in warehouses, processing facilities, distribution centers, and high-risk retail establishments. Learn more.
National Emphasis Programs, also known as NEPs, are “temporary programs that focus OSHA's resources on particular hazards and high-hazard industries,”(OSHA 2023). On July 11th, 2023, OSHA launched a NEP focused on preventing injuries in warehouses, processing facilities, distribution centers, and high-risk retail establishments. This NEP decision was made based on ten years of injury history in these workplaces. According to the OSHA national news release, warehouses and distribution centers currently employ 1.9 million people, and the injury and illness rate is higher than the overall private industry.
The NEP will last three years and will consist of inspections focused on hazards related to powered industrial vehicle operations, material handling and storage, walking and working surfaces, means of egress, and fire protection. These safety focuses would be considered high-risk, which means if an injury occurs then there is a higher chance it will result in a serious injury or fatality.
The NEP also focuses on other safety topics that are not considered high-risk but attributed to the high injury rate: heat and ergonomic hazards. Additionally, OSHA may expand an inspection’s scope when evidence shows that violations may exist in other areas of the establishment. Overall, these are great areas of focus within these industries. Throughout my five years of being in the warehouse and distribution center sector, sprains and strains have been the most frequently occurring injury type and contributed to around half of all injuries I encountered. OSHA inspections related to ergonomics should look at packaging and loading workstations. The workforce in warehouse and distribution centers tend to be diverse, and one employee’s size and height could be completely different from another. Workstations, however, will be fixed. Heat-related illnesses vary throughout the United States, but states like Arizona tend to have 40-50 work-related fatalities due to heat stress.
For more information, visit: https://www.osha.gov/news/newsreleases/national/07132023#:~:text=%22This%20emphasis%20program%20allows%20OSHA,ensure%20worker%20health%20and%20safety.%22
Tyler Sandy is a Health and Safety Specialist and consults with clients in the area of worker safety. Tyler's experience includes industrial hygiene services, safety training, RCRA as well as OSHA and EPA compliance. His experience includes working with the packaging industry, railroad, welding, warehouse, food and medical waste, chemical manufacturing, and casting.
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Go Wild! The Benefits of Native Landscaping
Learn about the advantages of turning your yard into a space that supports native plants, animals, and habitats.
The summer heat has taken hold, and you’re probably struggling to keep that lawn at your home or business alive and green. What better time to learn about the advantages of turning all or a portion of that area back into a space that supports native plants, animals, and habitats? Traditional lawns require significant investments of time and resources while providing little in return.
Pollinators, for one, depend on native habitats for survival. According to the USDA, “Three-fourths of the world’s flowering plants and about 35 percent of the world’s food crops depend on animal pollinators to reproduce”. Native flowers in a former lawn space can support insect and bird pollinators with nectar and pollen as a much-needed food source, allowing them to complete their critical pollinating roles.
Once established, native habitats also require significantly less watering and eliminate the need for harsh chemicals and fertilizers. National Audubon Society experts estimate, “the traditional suburban lawn on average has ten times more chemical pesticides per acre than farmland”. Natural areas reduce groundwater penetrating chemicals and conserve our most precious resource, water.
Natural spaces also provide the reward of connecting on a personal level with the outdoors. Researchers at the Mental Health Foundation have observed that “people who are more connected with nature are happier and more likely to report feeling their lives worthwhile.” What better way to promote positive mental health than to create and enjoy a biodiverse area?
Lastly, we see more and more habitat loss and migration spaces being eliminated due to human sprawl and development. To put this in perspective, there are currently more than 63,000 square miles in the US of turfgrass. That’s larger than the state of Georgia (LawntoWildflowers.org). Rewilding even a portion of this massive space would provide much-needed resources for birds, insects, and other living creatures that depend on natural land.
Hopefully, these benefits have shown you why this summer could be the perfect time to convert your lawn into a native and rewarding landscape.
Resources:
Why Native Plants Matter | Audubon
Nature: How connecting with nature benefits our mental health | Mental Health Foundation
Bringing your lawn back to life by converting turfgrass to native wildflowers — Lawn to Wildflowers
Travis Clark is a Cornerstone Account Manager with a focus on business development. He manages corporate clients primarily in the industrial sector with a focus on manufacturing and logistics. He counsels clients in the areas of EPA and OSHA regulatory compliance management, quality certifications, and sustainability. He works closely with these operations to provide guidance on minimizing risk and implementation of cost-saving initiatives.
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The Sackett Case: How the Supreme Court's Wetlands Decision Alters Environmental Regulations
The U.S. Supreme Court recently issued a ruling that narrowed the definition of water in the Clean Water Act. Learn more.
In late May, the U.S. Supreme Court issued a ruling that narrowed the definition of water in the Clean Water Act. This is the second recent court decision that significantly affects the regulatory authority of the Environmental Protection Agency. Less than 11 months earlier, a Supreme Court ruling curbed the EPA’s authority to limit coal plant emissions.
The May 2023 decision affecting the Clean Water Act pertains to wetlands. Michael and Chantell Sackett own a parcel of land about 300 feet from Priest Lake, one of Idaho’s largest lakes. The Sacketts want to build a house on their land, but the property has been considered part of a large wetland complex that, like all wetlands, requires a permit for any type of development. A government agency denied a Sackett petition for developing their land, and the case eventually reached the Supreme Court. A majority of the Supreme Court ruled in favor of the family.
At the heart of the Sackett family case was the definition of wetlands, which have long been protected under the Clean Water Act enacted in 1972. Wetlands have generally been defined as areas that are wet for all or part of a year, such as bogs, marshes, swamps, and fens. Development has not been allowed on wetlands that are adjacent to a body of water, even if a levee or other barrier separates the two. The definition of water has been vague in the Clean Water Act, however. In its recent ruling, the court determined that wetlands must have a continuous surface connection to a navigable body of water. Accordingly, the ruling specifies that wetlands must directly adjoin rivers, lakes, and other bodies of water.
Proponents of the decision indicate that there is now a clear, workable standard for regulators to utilize in implementing the Clean Water Act. Organizations focused on property rights applaud the decision as a clarification of the freedoms of landowners, including water. Critics of the decision maintain that scaling back the scope of the EPA’s authority could have devastating effects on water quality, including a possible increase in pollution, disruption of ecosystems, and harm to wildlife. They note that wetlands often serve as a buffer that will disappear with additional development, thereby increasing the risk of contaminated water runoff and related issues.
For over seven years, Rachel Powell has worked as a Chemical Data Management Specialist at Cornerstone. She assists clients in setting up and maintaining their Safety Data Sheet FOUNDATION System and facilitates new user training monthly. Additionally, each year, she files Tier II Emergency and Chemical Reports on behalf of our clients.
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Biochar for Environmental Remediation
For thousands of years, innovative farmers have added a charcoal-like substance—biochar—to the soil to improve crop productivity. But what is biochar?
For thousands of years, innovative farmers have added a charcoal-like substance—biochar—to the soil to improve crop productivity. Between 450 BCE and 950 CE, native farming communities of the Amazon basin successfully converted low-fertility, tropical soils to agricultural soils through the amendment of biochar, compost, manure, and other waste. Unknown to these farmers, the physical and chemical properties of the biochar in these terra preta soils (“black soil” in Portuguese) were helping to retain soil nutrients that otherwise would have been leached away during the tropical precipitation. In recent decades, interest in biochar has experienced a resurgence as insightful scientists have looked to those same properties that helped biochar mitigate nutrient leaching for utility in environmental remediation endeavors.
What is biochar? Analysis of the name likely draws up images of a burned forest, perhaps a biological experiment involving fire, or a new product riding today’s wave of environmental interest. In summary, when any carbon biomass (e.g., wood waste, plants, or even animal waste) is exposed to high heat in an oxygen-free environment, this biomass converts to a solid, charcoal-like product known as biochar. In this form, the carbon is resistant to decomposition and is chemically stable. Macroscopically, biochar appears as dusty, black charcoal pieces with grains of generally 0.1 centimeters or smaller. But it’s the microscopic properties of biochar that make it unique. Consider a cross-section of a plant under a microscope with all the plant’s xylem, stoma, cells, and other tissues shown in detail. Then, imagine removing all liquid components and leaving only this skeletal framework behind. This solid, carbon-based matrix makes up biochar and instills it with tremendous surface area. This surface area and its generally negative surface charge are the basis for biochar’s environmental applications.
The high surface area and negative surface charge of biochar enable it to adsorb various substances and chemicals. Within the terra preta soils, nitrogen and other nutrients from manure and other wastes would adhere to the biochar’s surface rather than be leached away during rainfall. This maintained nutrient availability to the crops grown by the Amazonian farmers. Similarly, pollutants (particularly those with a positive charge) cling to biochar and can include organic compounds and heavy metals. Pollutants adhering to biochar are immobilized and prevented from entering the water supply—much as a charcoal filter will screen particles from drinking water. Adding biochar has been shown to help stabilize heavy metals in soil and thus may make it a valuable tool in mine reclamation and the treatment of industrial spills.
In addition to stabilizing metals and chemicals, research suggests that the simultaneous adsorption of organic compounds and microorganisms to biochar facilitates metabolic interaction and expedites the degradation of these pollutants. Bioremediation, the use of microbes to clean up contaminated soil and groundwater, may be enhanced with biochar. One method of bioremediation—bioaugmentation—involves the introduction of a concentrated culture of microbes to the contaminated site. The physical application of these microbes requires mixing them with a carrier medium and amending the area of treatment with this mixture. A slurry containing biochar not only acts as an effective carrier but also provides a protective habitat for the microbes within the pores and rough surface of biochar. As aforementioned, biochar’s affinity for adsorbing organic pollutants helps to bring both the organic pollutants and the microbes into association, thus accelerating the breakdown of these toxins. One study found enhanced bioremediation of polycyclic aromatic hydrocarbons when using biochar as a carrier. Other studies have found similar success when using biochar in bioremediation.
Biochar may also be used to control ongoing pollution from agriculture and large-scale industrial processes. Wetlands and biofilters (engineered filtration systems composed of soil, sand, gravel, and plants) are often constructed to treat agriculture and industrial wastewater naturally. Biochar has demonstrated promise in augmenting contaminant removal of wetlands and biofilters when included among the substrates. Simply put, biochar's unique but consistent properties make it transferrable to various remediation methods.
Thousands of years ago, the Amazonian farmers understood little of biochar, except that adding it to soils improved the success of their harvests. Today, we know the properties of biochar and learn how it can be used in other applications. As our technology advances and our environmental standards improve, our environmental needs will evolve. Meeting these needs will require viewing old technology with a fresh perspective. There is no single solution to our environmental dilemmas. However, the investigation of novel ideas, such as biochar for remediation, can help us along the way.
Dan Smith is an Environmental Specialist for Cornerstone Environmental, Health and Safety out of our Zionsville office. His seven years in environmental consulting include experience in environmental compliance, site assessments, monitoring, remediation, and health and safety. When not at work, he can be found hiking, biking, or engaging in other outdoor activities.
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A.C.T- Assess Control, Train
Read Part I of our IV part series: A simple pathway to Health and Safety Management
Part I of IV: A simple pathway to Health and Safety Management
No matter which framework an organization uses to develop its Health and Safety System, three critical steps remain the basis for keeping workers healthy and safe. Cornerstone has simplified those into the acronym A.C.T. for Assess, Control, Train.
ASSESS
OSHA’s “Safety and Health Programs Step-by-Step Guide” (https://www.osha.gov/safety-management/step-by-step-guide) has ten steps, including one for Hazard Identification and Control. While the OSHA tried-and-true Job Hazard Analysis (JHA) approach is similar to ours, we focus on evaluating risk as a guide to everything we do. OSHA’s method also has a risk analysis element; however, it results in an alphanumeric risk level which we have found to be less intuitive than the method we use. Cornerstone expands risk ranking by using an approach that assigns a rating for the Severity and Probability (1 through 4, with the lower rating corresponding to lower severity and probability) to each hazard identified. The product of multiplying these two ratings results in a numerical ranking of hazard controls needed. We work on the highest risks first. The risk levels correspond to a priority for controls.
Cornerstone uses the OSHA Hierarchy of Controls in this next step. This requires an organization first to eliminate, substitute, or isolate (engineer) hazards. Administrative controls, including procedures, plans, and training, are then considered, and, as a last resort, PPE is used to shield workers from the hazard.
The controls often include the development of administrative policies, procedures, and programs. Cornerstone works hard to develop these along with stakeholders at every level of the company. The information gathered in the previous steps guides how this is done. Controls can range from something as simple as wearing protective gloves all the way to Injury and Illness Prevention Plans and the establishment and facilitation of Health and Safety Committees.
TRAIN
Worker Health and Safety training and coaching are integral to making the controls come to life. If workers do not understand the controls, they will not use them. This is particularly important for Administrative and PPE controls where workers have a direct impact on the success of the control. Examples include how to wear PPE such as hearing protectors effectively and properly, Energy Control (aka Lockout/Tagout or LOTO) Procedures, and Ergonomic coaching. Classes can be set up for a subset of affected employees all the way up to organization-wide Health and Safety Orientation and Awareness training. Cornerstone works with its clients to make classes and scheduling effective and efficient. Our team of trainers has decades of experience in industry, education, logistics, and regulatory agencies.
TRAIN
Worker Health and Safety training and coaching are integral to making the controls come to life. If workers do not understand the controls, they will not use them. This is particularly important for Administrative and PPE controls where workers have a direct impact on the success of the control. Examples include how to wear PPE such as hearing protectors effectively and properly, Energy Control (aka Lockout/Tagout or LOTO) Procedures, and Ergonomic coaching. Classes can be set up for a subset of affected employees all the way up to organization-wide Health and Safety Orientation and Awareness training. Cornerstone works with its clients to make classes and scheduling effective and efficient. Our team of trainers has decades of experience in industry, education, logistics, and regulatory agencies.
Conclusion
Cornerstone’s A.C.T approach to health and safety management leverages industry best practices, broad experience, and a mind toward efficient action that maximizes our client’s resources and minimizes risks to workers.
Come back next month for a deeper dive into our risk-based hazard assessment service. We will demonstrate how it is conducted with a series of examples and case studies and discuss further some of the philosophies behind why we do what we do.
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 nationwide to ensure compliance with EHS regulations and evaluate opportunities to go above and beyond compliance.
#OSHA #Safety #InjuryandIllness #OSHA-300-A
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Recent Changes to the SARA Title III TRI (Toxic Release Inventory)
Think you are ready to file your Toxic Release Inventory (TRI), aka Form R, reports just the same as you did last year? Hold on a minute. While you might not have an issue doing this, make sure to check the TRI Chemical List for any changes before you press submit. The Environmental Protection Agency (EPA) is making major changes to the list over the next two years.
The EPA makes changes to the TRI chemical list on a periodic basis though EPA-initiated review and the chemical petitions process.
Recent TRI Chemical List ChangesUnder the automatic listing provisions of the 2020 National Defense Authorization Act: Four PFAS were added for reporting year 2022. Reporting forms on these chemicals are due July 1, 2023, for 2022 data if TRI reporting thresholds are met. Nine PFAS were added for reporting year 2023. Reporting forms on these chemicals are due July 1, 2024, for 2023 data if TRI reporting thresholds are met. See Addition of Certain PFAS to the TRI by the National Defense Authorization Act for more information. In November 2022, EPA added 12 chemicals in response to a petition submitted under Section 313(e) of EPCRA. Reporting forms on these chemicals are due July 1, 2024, for 2023 data if TRI reporting thresholds are met.
*from epa.gov
For the Cliff’s Notes version from our technical expert (and skip the clicking)…Or easier still…just call us to help!
For the 2022 reporting year, due by July 1, 2023, the EPA has added four Per- and Polyfluorinated Substances (PFAS) to the EPCRA Section 313 reportable chemical list:
CAS RN Chemical name
375-73-5 Perfluorobutane sulfonic acid (de minimis 0.1%)
29420-49-3 Potassium perfluorobutane sulfonate
65104-45-2 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10- heptadecafluorodecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,14- pentacosafluorotetradecyl 2-methyl-2-propenoate and 3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl 2-methyl-2-propenoate
203743-03-7 2- Propenoic acid, 2-methyl-, hexadecyl ester, polymers with 2-hydroxyethyl methacrylate, γ-ω-perfluoro-C10-16-alkyl acrylate and stearyl methacrylate
Note that the de minimis value for each of these PFAS is 1% unless otherwise noted above. The manufacturing, processing, and otherwise use reporting threshold is 100 pounds for each of the PFAS listed above.
Please also note that the PFAS chemical names and CasRNs are listed on separate tables from the remainder of reportable chemicals on the List of Lists.
For the 2023 reporting year, due by July 1, 2024, the EPA automatically added in 9 PFAS to the EPCRA Section 313 reportable chemical list:
375-22-4. Perfluorobutanoic acid
2218-54-4 Sodium perfluorobutanoate
2966-54-3 Potassium heptafluorobutanoate
10495-86-0 Ammonium perfluorobutanoate
45048-62-2. Perfluorobutanoate
2728655-42-1 Alcohols, C8-16, γ-ω-perfluoro, reaction products with 1,6-diisocyanatohexane, glycidol and stearyl alc.
2738952-61-7 Acetamide, N-[3-(dimethylamino)propyl]-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs.
2742694-36-4 Acetamide, N-(2-aminoethyl)-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., polymers with N1,N1-dimethyl-1,3-propanediamine, epichlorohydrin and ethylenediamine, oxidized
2744262-09-5 Acetic acid, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., 2-hydroxypropyl esters
The EPA has also added the following 12 chemicals to the EPCRA Section 313 list beginning reporting year 2023, in response to a petition filed by the Toxics Use Reduction Institute:
683-18-1dibutyltin dichloride
96-23-11,3-dichloro-2-propanol75-12-7formamide
1222-05-51,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran;*111-41-1n-hydroxyethylethylenediamine
5064-31-3nitrilotriacetic acid trisodium salt140-66-9p-(1,1,3,3-Tetramethylbutyl) phenol87-61-61,2,3-trichlorobenzene
2451-62-9triglycidyl isocyanurate115-96-8tris(2-chloroethyl) phosphate13674-87-8tris(1,3-dichloro-2-propyl) phosphate
25155-23-1tris(dimethylphenol) phosphate
*classified as a Persistent Bioaccumulative, and Toxic (PBT) chemical with a 100 pound reporting threshold
This Month in Environmental History: The Ozone Hole
In May 1985, a group of scientists from a British Antarctic Survey discovered a hole in the (Antarctic) Ozone. Learn more.
While my childhood is mostly gaps or memories created from thumbing through yearbooks or my dad’s slides, I do have solid memories of my first pair of high-top Air Jordans in the fifth grade and the time I peed my pants taking a standardized test in the first grade. I vaguely remember learning that littering was bad for the environment and, later, in middle school, understanding that my can of hairspray might also be bad somehow and looking for the ‘no CFCs*’ labels on bottles at the drugstore.
It was probably my middle school science class before a teacher mentioned the ozone layer and the subsequent havoc that the human population wreaked on the thin part of Earth’s atmosphere that absorbs a portion of the radiation from the sun.
In May 1985, a group of scientists from a British Antarctic Survey (Cambridge) published a ‘letter’ in the scientific journal Nature titled Large losses of total ozone in Antarctica reveal seasonal ClOx/NOx interaction. (Abstract below)
Translation: the discovery of the (Antarctic) Ozone Hole, thought to be one of the most striking indictors of ozone depletion. According to NASA, the depletion of the ozone layer is recognized as on the Earth’s most important environmental issues.
In October 1985, the area of the ozone hole was measured at 7.25 million square miles. Thirty-seven years later in October 2022, it measured 10.23 million square miles. For reference, the entire continent of North America is just over 9.5 million square miles.
Large losses of total ozone in Antarctica reveal seasonal ClOx/NOx interaction
Abstract: Recent attempts1,2 to consolidate assessments of the effect of human activities on stratospheric ozone (O3) using one-dimensional models for 30° N have suggested that perturbations of total O3 will remain small for at least the next decade. Results from such models are often accepted by default as global estimates3. The inadequacy of this approach is here made evident by observations that the spring values of total O3 in Antarctica have now fallen considerably. The circulation in the lower stratosphere is apparently unchanged, and possible chemical causes must be considered. We suggest that the very low temperatures which prevail from midwinter until several weeks after the spring equinox make the Antarctic stratosphere uniquely sensitive to growth of inorganic chlorine, ClX, primarily by the effect of this growth on the NO2/NO ratio. This, with the height distribution of UV irradiation peculiar to the polar stratosphere, could account for the O3 losses observed.
For more information on Federal (Clean Air Act) and International (Montreal Protocol et al) actions to address Ozone Depletion, visit this site.
*chlorofluorocarbons and other Ozone-Depleting Substances (ODS)
Sources: Farman, J., Gardiner, B. & Shanklin, J. Large losses of total ozone in Antarctica reveal seasonal ClOx/NOx interaction. Nature 315, 207–210 (1985). https://doi.org/10.1038/315207a0
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SEC Rule on Climate-related Disclosures
In January 2023, the Securities and Exchange Commission (SEC) cited April as the release date for a long-anticipated final action – a rule on companies' climate-related disclosures.
For reference:
Scope 1 emissions are considered direct greenhouse gas (GHG) emissions from sources that are controlled by a company such as emissions from energy to run equipment, heating and cooling, and company vehicles.
Scope 2 emissions are indirect GHG emissions created by the production of energy (electricity, steam, heat, or cooling) the organization buys.
Scope 3 emissions are indirect GHG emissions that are not owned or controlled by the reporting organization. This category is much more encompassing as it addresses emissions generated by customers who use the products and by suppliers making products the company uses. Addressing Scope 3 involves tracking emissions across the entire value chain from suppliers to end users.
Scope 1 and 2 emissions tend to be easier to track, measure, and, to an extent, control. Options, such as solar and other renewable energy sources and switching company vehicles to electric models, are a few examples. With regard to Scope 3 emissions, EPA suggests that an “organization may be able to influence its suppliers or choose which vendors to contract with based on their practices.” For other companies, the focus can be less on suppliers and more about their customers’ use of products.
The reality is the upcoming SEC final rule release will regulate publicly traded companies; however, these publicly traded companies will be obligated to heighten their demands on the private sector suppliers to the companies subject to the SEC rule. Private companies will very likely be affected by new vendor or customer requirements. Small and mid-market organizations may not have the capability to effectively manage in-house. For those organizations already addressing Scope 1 and 2, it will be critical to ensure the process is accurate. A periodic third-party audit will be prudent. While not anticipated to have a reporting date before 2025 (for FY 2024), if not yet addressed, a plan to identify, manage and measure Scope 3 should be considered.
It is and will be critical for organizations to publicly communicate accurate, complete, and reliable environmental data, which includes environmental risks, opportunities, and practices as well as GHG emissions that are useful in decision-making for stakeholders.
A recent article in Environment+Energy Leader reminds us that there is good news. “…the good news is that these new standards and requirements are aligning around a common core, giving the markets more comparable information, and giving companies clearer direction. Organizations must understand that C-suites and Boards of Directors will be held accountable for disclosures and data management. It will be critical to ensure that data is reliable.”
Important Notes:
The proposed SEC rule would provide a safe harbor for liability from Scope 3 emission disclosure and exemption from Scope 3 emissions disclosure requirement for smaller reporting companies.
The proposed disclosures are anticipated to be similar to currently accepted disclosure frameworks such as ISSB (IFRS) and CDP.
Sources:
https://www.epa.gov/climateleadership/ghg-inventory-development-process-and-guidance
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Industrial Stormwater Best Management Practices
Stormwater is the water that originates from precipitation such as heavy rain or meltwater from hail or snow. Many industrial facilities introduce materials to stormwater through the outdoor storage, handling, and transfer of product materials, by-products, and waste products. These industrial products often contain pollutants such as metals, oil, and grease which negatively impact stormwater runoff. Additionally, industrial activities can cause erosion and sediment problems that also impact stormwater runoff.
Best Management Practices (BMPs) are pollution control measures designed to prevent or reduce the effects of pollutants in stormwater runoff from industrial stormwater discharges. Some BMPs are specific and well-defined, while others are general in nature. Facilities determine which BMPs to use based on permit requirements, the facility’s specific industrial materials, and the facility’s specific activities.
BMPs should be considered as a system or series of activities that may include non-structural and structural BMPs.
Non-structural BMPs are management techniques implemented through simple daily duties. The facility identifies and implements site-specific BMPs which have a direct impact on the day-to-day operations. Some of the more common non-structural BMPs include good housekeeping, eliminating and reducing exposure, management of salt and/or industrial storage piles, management of runoff including soil and erosion prevention, and dust control.
Structural BMP options vary depending on the pollutants each can treat, efficiency, maintenance issues and limitations of controls. Structural BMPs are more technical in nature and advanced technical expertise is required to make informed decisions about implementing structural stormwater BMPs. It
is suggested to consult with a licensed professional engineer early in the decision process. Common structural BMPs include sedimentation systems (e.g. retention ponds), infiltration systems (e.g. stormwater trenches), filtration systems (e.g. vegetative filters), and proprietary systems (e.g. vortex separators).
Federal regulations require stormwater discharges associated with specific categories of industrial activity to be covered under a National Pollutant Discharge Elimination System (NPDES) permit. EPA has developed a fact sheet for each of the 29 industrial sectors regulated by the NPDES permits. Each fact sheet describes the types of facilities included in the sector, typical pollutants associated with the sector, and types of stormwater control measures used to minimize the discharge of the pollutants. These BMP fact sheets are a great starting point for determining the various pollutants which cause stormwater pollution at a facility and provide BMPs that are applicable to a specific industrial facility operation.
Regular inspections of a facility’s BMPs are required by the NPDES permits. These inspections are integral in determining if structural and nonstructural BMPs are properly functioning, require maintenance, or need to be changed. Inspections also determine the accuracy of the facility’s written stormwater plan, as all observations and any changes made as a result of the inspections must be documented in the written plan.
For more information on BMPs for stormwater, check out EPA.gov or reach out to your Cornerstone Team directly.
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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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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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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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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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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:
Aspects and Impacts – Conduct onsite evaluations and written findings.
Policies and Procedures – Drafting and oversight of policies and procedures.
Application Submittal – Completing and submitting applications for approval.
Audits – Conducted at specified intervals for program compliance by a third party.
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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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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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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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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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:
Forms 300, 300A, 301 and Instructions PDF Fillable Format
Forms 300, 300A, 301 Excel format (Forms ONLY) Requires Microsoft Excel or equivalent
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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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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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.