OSHA & EPA Consultant
Thomas W. Eynon
B & R Compliance Associates LLC
24 Bay Point Road
Merritt, NC 28556
(252) 745-7391
Fax: (610) 868-7185
tom.eynon@
brcompliance.com
Tom's career started with Kaiser Aluminum & Chemical Corporation in operations, later moving into their Safety Organization. Tom held a number of management positions of increasing responsibility for safety and protective services at different plant locations and divisions. Before leaving Kaiser he had responsibility for safety program management at the largest Kaiser Aluminum site in the world. Tom joined BOC as the Regional Safety Manager with responsibilities for safety and loss control program management in the NE. Tom was subsequently appointed Manager of Process Safety and oversaw BOC's risk engineering and process safety programs in North America. Tom developed and implemented BOC's PSM and RMP programs in compliance with the OSHA and EPA requirements. Since leaving BOC, Tom has consulted with major companies on process safety, loss control, safety training, and safety auditing for projects in the US and South Africa. During his career Tom has been active with professional organizations such as ASSE, NSC, and DNV as well as industry associations such as CGA, and GAWDA. He is the holder of numerous professional certifications.
Tom is available to provide a wide range of programs and services for OSHA and EPA compliance including program development, employee training, customer training, auditing and compliance gap assessments.
Spring 2008
Internet Reporting Now Available for All Facilities Reporting TRI Data
For the first time since Toxics Release Inventory (TRI) inception, all facilities that are required to submit data to TRI will be able to do so over the Internet, using the TRI-ME software. Companies will no longer have to mail reports on compact disks or paper to EPA. Companies are required to submit calendar year 2007 data to TRI by July 1, 2008. Facilities will be able to use the Internet to send information directly to EPA through their Central Data Exchange.
TRI-Me Software
OSHA Issues Enforcement Procedures Directive for New Hexavalent Chromium Standards
If the hexavalent chromium (Cr(VI) standard that was published in the Federal Register on February 28, 2006 applies to your company, you need to be aware of the new OSHA compliance directive on this standard. The directive, OSHA Instruction CPL 02-02-074, Inspection Procedures for the Chromium (VI) Standards, was effective January 24, 2008.
The new directive provides guidance for enforcement and compliance of the final rule.
January – March 2008
Posting OSHA Form 300A
Don’t forget, you must post the OSHA 300A Summary of Work-Related Injuries and Illnesses by February 1, 2008 for calendar year 2007. A company executive must certify the form as being accurate, and it must be posted from February 1 through April 30, 2008, at each location that is required to comply with the OSHA record-keeping requirements.
Emergency Planning and Community Right-to-Know Act (EPCRA)
An owner of bulk installations at a customer site has a duty under EPA regulations (Section 312) to notify the customer of their obligation to file Tier Form reports for each hazardous chemical that meets or exceeds the threshold planning quantities. The reminder must be mailed to an appropriate customer representative by February 15, 2008. The supplier must document its efforts to notify its customers of these requirements.
SARA Title III (EPCRA) Reporting
March 1 is the filing deadline for your Hazardous Chemical Inventory Report. This report usually is submitted on a Tier I or Tier II Form. Keep in mind that your state may require one of these forms be used over the other or even have its own special form. Your state may even have different reporting quantities. Check with your State Emergency Response Commission (SERC) if you have questions regarding what form to use or other possible state requirements. If you submitted this report last year, use it as a guide. The report(s) must be submitted to your Local Emergency Planning Committee (LEPC), your SERC and the local fire department with jurisdiction over the facility. EPA has a web site for Tier ll electronic reporting for each State: http://yosemite.epa.gov/oswer/ceppoweb.nsf/webprintview/statetier2.htm The EPCRA hotline for free help is 800-424-9346. Additional information related to SARA Title III can be found in the GAWDA EPA Manual in sections 5, 6, 7 and 8.
Winter 2007
Fall 2007 National Preparedness Month Observed During Sept.
September is National Preparedness Month designed designed to increase public awareness about the importance of preparing for emergencies and to encourage individuals to take action. OSHA is alerting employers about emergencies that can
be the result of man-made or natural causes, including hurricanes, floods, tornadoes, explosions, civil disturbances, fires, toxic gas releases, chemical spills, radiological accidents, workplace violence, and terrorism. All too often, people are forced to evacuate their workplace without warning and when least expected. Few people can think clearly and logically in a crisis, and that is why it is so important to prepare for an emergency before it happens. The best way to protect yourself, those you work with, or your business, is to expect the unexpected and develop an emergency action plan to guide you when immediate action is necessary. While OSHA does not require all establishments to have an emergency action plan, the agency certainly encourages all businesses to have one OSHA's interactive, Web-based Evacuation Plans and Procedures eTool is a resource to help employers prevent severe employee injuries during emergencies.
Summer 2007 – Atlantic Hurricane Season
June 1st officially marks the beginning of the 2007 Atlantic Hurricane Season. Experts at the National Oceanic and Atmospheric Administration's Climate Prediction Center forecast a 75-percent likelihood of 13 to 17 named storms. Some immediate tips for employers and employees to prepare for the season include:
Have a plan in place for protecting yourself in the event of a hurricane.
- Consider making provisions for family members who cannot plan for themselves.
- Have available food, water, extra personal medications, and other emergency supplies.
- Follow the instructions of officials concerning emergency actions including evacuations.
OSHA's Hurricane eMatrix is just one the many resources available on the agency's Hurricane Recovery Web page for staying safe during this hurricane season and preventing workplace injuries and illnesses during cleanup and recovery.
April 2007 - Supplement document to the 2nd Quarter
GAWDA Welding & Gases Today article entitled “First Aid Requirements – Are You In Compliance?
OSHA Releases New "It's The Law" Poster – March 2007
The Department of Labor's Occupational Safety and Health Administration (OSHA) announced publication of its new "It's The Law" poster.
The OSHA poster, also known as the OSHA notice of employee rights, is required to be displayed in every workplace in America. The current edition of the OSHA poster is still valid; employers are not required to replace their existing poster with the new version. The poster informs employers and employees of their rights and responsibilities for a safe and healthful workplace.
The OSHA poster, which is free and available in both English and Spanish, may be downloaded from OSHA's Web site at www.osha.gov. The poster may also be obtained from any OSHA regional or area office, or by writing to the OSHA Publications Office, room N3101, 200 Constitution Ave. NW, Washington, D.C 20210, phone (202) 693-1888.
Posting OSHA Form 300A - January/February 2007
Don’t forget, you must post the OSHA 300A Summary of Work-Related Injuries and Illnesses by February 1, 2007 for calendar year 2006. A company executive must certify the form as being accurate, and it must be posted from February 1 through April 30, 2007, at each location that is required to comply with the OSHA record-keeping requirements.
An owner of bulk installations at a customer site has a duty under EPA regulations (Section 312) to notify the customer of their obligation to file Tier Form reports for each hazardous chemical that meets or exceeds the threshold planning quantities. The reminder must be mailed to an appropriate customer representative by February 15, 2007. The supplier must document its efforts to notify its customers of these requirements.
SARA Title III (EPCRA) Reporting
March 1 is the filing deadline for your Hazardous Chemical Inventory Report. This report usually is submitted on a Tier I or Tier II Form. Keep in mind that your state may require one of these forms be used over the other or even have its own special form. Your state may even have different reporting quantities. Check with your State Emergency Response Commission (SERC) if you have questions regarding what form to use or other possible state requirements. If you submitted this report last year, use it as a guide. The report(s) must be submitted to your Local Emergency Planning Committee (LEPC), your SERC and the local fire department with jurisdiction over the facility. EPA has a web site for Tier ll electronic reporting at: http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/tier2.htm and links to State SARA Title lll information. The EPCRA hotline for free help is 800-424-9346. Additional information related to SARA Title III can be found in the GAWDA EPA Manual in sections 5, 6, 7 and 8.
December 2006 - New Guidance Available on Hexavalent Chromium
OSHA announced the availability of a new guidance document this month to help small businesses comply with requirements of the agency's new hexavalent chromium standard. Small Entity Compliance Guide for the Hexavalent Chromium Standards describes steps employers are required to take to protect employees from hazards associated with exposure to the compound. Permissible Exposure Limits (PEL), exposure determination, respiratory protection and personal protective equipment, are just some of the topics included in the guide.
October – 2006 OSHA Revises Respiratory Protection Standards
New Assigned Protection Factors (APFs) for respiratory protection programs are being incorporated in OSHA's Respiratory Protection Standard. APFs are numbers that indicate the level of workplace respiratory protection that a respirator, or class of respirators, is expected to provide to employees when used as part of an effective respiratory protection program. The standard will now contain provisions necessary for a comprehensive respiratory protection program, including selection and use of respirators, training, medical evaluation, and fit testing. Details are in the Aug. 24 Federal Register.
September 2006 - Storage of Oxygen and Acetylene Cylinders
OSHA has clarified the storage of oxygen and acetylene cylinders for construction vs. general industry in this letter of interpretation. In general industry workplaces, oxygen and acetylene cylinders that are in use or are connected for use will not be considered to be in “storage” for purposes of the 1910.253 storage requirement. Therefore, in general industry, a welding/cutting unit, with an oxygen cylinder and an acetylene cylinder that is in use or connected for use with a properly functioning regulator can remain on an appropriate welding cart regardless of when gas will next be withdrawn from the unit.
August 2006 OSHA Provides Tips for Working in Hot Weather
To help employers and workers stay safe throughout the summer months, OSHA offers tips that can help prevent heat-related deaths, illnesses and injuries. Working Outdoors is an OSHA fact sheet that offers advice on ways to protect against exposure to ultraviolet radiation (UV), precautions to take if working in extreme heat, and how to protect against Lyme Disease and West Nile Virus. The fact sheet also offers information links for teenagers working at summer jobs. OSHA's Heat Stress Card offers a quick reference about heat-related injuries, including warning signs, symptoms and early treatment. Available in English and Spanish, this laminated fold-up card is free to employers to distribute to their workers. Protecting Yourself Against Harmful Sunlight is a pocket card that explains how to perform self-examinations to detect early stages of skin cancer. The card, available in English and Spanish, also describes common physical features of skin cancer that can be caused by exposure to the sun. The publications can be downloaded from OSHA's web site on the publications page or can be ordered by calling OSHA's publications office at (202) 693-1888.
July 2006 - ASSE Offers Disaster Safety Checklist
The American Society of Safety Engineers (ASSE) has offered a business disaster safety checklist at http://www.asse.org/press237.htm that can be used by you after a disaster, such as Hurricane Katrina. This checklist can serve as a safety and health aid to help ensure you are considering many of the thinks that need to be reviewed and verified, for the safety you and your employees, before resumption of business.
June 2006 - Hurricane Preparation
The Time to Prepare for Hurricane Season is now! The American Society of Safety Engineers offers a Web page devoted to links on hurricane preparation, including a workplace emergency checklist, mold clean up tips, a business resumption and disaster safety checklist, and an emergency preparedness quiz. Go to http://www.asse.org/asse_news_main_text.html.
Archived Documents, Regulations, etc
Featured in this month's SAFETY & TECHNOLOGY ORGANIZER:
GAWDA MONTHLY PUBLICATIONS
Safety Topics
Safety
Tips of the Month
Compliance Bulletins
Compliance Calendar
Medical Gas Issues
Medical Gas Directory
SAFETY and ENVIRONMENTAL ISSUES
(OSHA and EPA Notices and other publications)
U.S. Chemical Safety and Hazard Investigation Board (CSB) Release
CONSULTANT HOTLINE
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