Register for Training

Conduct a Gap Analysis

When was the last time you conducted a gap analysis of your EHS program, either by using an outside consultant or an internal resource? If you have never conducted a gap analysis or if it has been some time since the last one, consider investing in this invaluable process.

A gap analysis should start with a thorough review of your EHS needs and an evaluation of the regulatory standards that are applicable to your site and the work being conducted. This should include taking a deep dive into the hazardous materials present and how they are being stored, manipulated, and disposed of. When reviewing compliance with permit and license requirements, consider any permits or licenses that may have been overlooked due to changing needs.

Gap analyses almost always produce a list of action items. Even when an EHS program is well run and well documented, there are usually areas for improvement. Nice to […]

Celebrate Nanotechnology!

Celebrate National Nanotechnology Day next Monday, October 9, 2017! This second annual event is intended to raise awareness around nanotechnology, including the challenges and opportunities it presents.

The American Chemical Society (ACS) and other organizations have arranged community-led events, webinars, lab tours, and additional events to celebrate this day. Consider checking out the planned events, available resources, and see how you can learn more about nanotechnology. You can even particulate in the 100 Billion Nanometer Dash, and earn your very own Certificate of Achievement!

Be Sure to Establish a Compliant Bloodborne Pathogen Program

OSHA’s Bloodborne Pathogen Standard, 29 CFR 1910.1030, needs to be reviewed in detail when establishing a bloodborne pathogen protection program. This standard applies to all occupational exposure to human blood, human blood components, products made from human blood, and other potentially infectious material as defined in the standard.

There are many elements to consider when establishing compliance with this standard. Among other requirements, an Exposure Control Plan needs to be written and implemented to eliminate or minimize employee exposure to bloodborne pathogens. An exposure determination detailing the job classifications, tasks, and procedures that are covered needs to be conducted and documented. Other topics to cover include required PPE, hazard identification, safer sharps options, waste disposal practices, and proper work practices. All affected employees must be offered a hepatitis B vaccine, and post-exposure evaluation and follow-up consultation. Employees must be trained on the topics stipulated in the standard upon assignment to tasks with occupational […]

Calculate Your Estimated Annual Radiation Dose

The United States Nuclear Regulatory Commission (NRC) publishes a personal annual radiation dose calculator, which can be used to estimate an individual’s average annual radiation dose based on risk factors. If you have not used this calculator before, it may be interesting to see what your projected annual dose is from natural and man-made sources of ionizing radiation. When people hear about the possibility of radioactive materials being brought on-site, some can become a bit nervous, not realizing that their occupational dose will likely be much less than their dose from natural sources of radiation.

The main natural sources of radiation are cosmic radiation, terrestrial radiation, and internal radiation. The total U.S. average natural background dose is estimated to be 310 mRem/year, which exceeds most exposures in research and development laboratories. In addition to natural sources, man-made sources of radiation include medical, commercial, and industrial sources. According to the National Council […]

Remember 2017 is a Renewal Year for Certified Wastewater Operators

Certified wastewater operators in MA are required to renew their certification every two years, with renewals due by December 31st of odd-numbered years. Active operators are required to obtain twenty training contact hours (TCHs) over the two-year renewal period. If you are like many other operators, you might be scrambling to complete your TCH criteria by the end of the year.

For the past few years, half of the TCHs have been required to be related to wastewater, rather than safety related. New England Interstate Water Pollution Control Commission (NEIWPCC) coordinates many training courses, along with the examination and renewals. Several other organizations are involved in the development of the training program, with MA DEP and the Board of Certification having regulatory jurisdiction. If you take courses outside of NEIWPCC, be sure to keep the certificate with the TCH approval number to submit with your renewal application.

Time is quickly running out for […]

Consider Contractor Safety

Almost every facility utilizes contractors in some capacity, whether it is on a routine basis or a sporadic agreement for a specific project. Whenever you hire contractors, be sure to consider the contractor safety program that needs to be implemented.

Key areas for consideration include safety training the individuals working at your facility receive, where they would go in the event of an accident requiring medical attention, incident recordkeeping, and other occupational health matters. From a regulatory perspective, the responsibility of providing training and injury recordkeeping mainly depends on which employer supervises the daily activities of the contractor. Some contract employers provide excellent training to their staff and others provide very limited training. In either case, you want to be sure that all contractors are trained on the hazards present at your workplace.

Establishing clear emergency response procedures is critical so both contractors and employees know what to do in the event of […]

Determine Applicability of OSHA’s Injury Tracking Application

OSHA is launching their Injury Tracking Application (ITA) for employers to electronically submit injury and illness data in compliance with the final rule to improve tracking of workplace injuries and illnesses. Every facility should determine the applicability of 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses, to their facility.

One of the major motivations behind OSHA issuing this rule update is the expectation that having injury and illness data publicly available will encourage employers to focus more on safety. Under this rule, certain employers that are already required to record injury and illness data will be required to electronically submit this data to OSHA in compliance with the established dates.

Various resources are available on OSHA’s website that can be used to determine applicability of this final rule to your facility. Be sure to review this information in detail, and take advantage of the opportunity to review your injury and […]

Recognize EHS Program Resources

Many people do not realize the extent of the resources that should be dedicated to an EHS program in order to make is successful. Implementing a comprehensive EHS program takes significant investment in both time and money. Be sure that there are enough resources available at your facility to implement a full spectrum program from waste consolidation and checking emergency equipment, to maintaining permits and license, to conducting risk assessments and job safety analyses.

Scientists that serve on safety committees or fulfill safety officer positions such as a Chemical Hygiene Officer, Biosafety Officer, or Radiation Safety Officer are integral to implementing a robust program. These individuals sometimes discover that they have a passion for safety and decide to make a career transition into an EHS role. When EHS departments are short staffed or a company does not have a dedicated safety officer, the safety program can struggle from the beginning. Be sure […]

Review EPA’s Guidance on New Nanotechnology Reporting and Recordkeeping Rule

EPA’s Nanotechnology Reporting and Recordkeeping Requirements Rule became effective on August 14, 2017. Manufacturers and processors of certain chemical substances are subject to reporting and recordkeeping requirements pursuant to Section 8(a) of the Toxic Substances Control Act (TSCA). In an effort to clarify the requirements for nanomaterials, EPA has issued a Working Guidance on EPA’s Section 8(a) Information Gathering Rule on Nanomaterials in Commerce.

This guidance document is a compilation of questions and answers developed based on input received from the draft guidance earlier this year. It is intended to be a work in progress with updates being published as necessary. If your facility works with nanomaterials, taking the time to review this rule guidance would be beneficial. If further clarification is still necessary after reviewing this guidance, EPA is urging individuals to reach out to the EPA directly to have their specific questions answered directly.

Maintain a Sealed Source Inventory

If your facility is licensed to work with radioactive materials, there are more than likely sealed sources at your facility that need to be accounted for. Depending on when and how your radioactive material license was completed, they may be included on your license. They may also be covered under a separate general license with the MA Department of Public Health Radiation Control Program (RCP). Either way, the sealed sources need to be accounted for and maintaining an inventory of the sealed sources present will help ensure that all sources are covered as necessary.

The sources found in liquid scintillation counters generally need to be registered with RCP, and some require leak testing on a regular basis. Check sources for G-M survey meters should be accounted for on the inventory even if they do not require registration with RCP. Maintaining an accurate inventory of all sealed sources present will help ensure compliance […]