Use Correct MA DEP Generator Registration Form

The MA DEP is now using a state version of the federal Notification of Hazardous Waste Activity form #8700-12. All generators of hazardous waste and waste oil must use this form going forward.

Prior to this form being rolled out, there were two separate forms for generators to use to notify the DEP of hazardous waste and waste oil generation depending on the volume of waste generated per calendar month. Very small quantity generators were required to use a separate form than small quantity generators and large quantity generators. The old forms are no longer being accepted and will be returned if they are submitted.

This is also a good time to remember to track monthly generation of hazardous waste to ensure the thresholds for generator status are not being exceeded.

Update Inspection Preparedness Guidance

What would happen if a regulator showed up at your doorstep this afternoon? Would personnel working at the entrance to your facility be prepared, know who to contact, and how to proceed in order to get the inspection started off on the right track?

It is a good idea to discuss how to handle unannounced regulatory inspections with key personnel, including the reception staff that will be the first to interact with regulators as well as the personnel that would be called upon to tour the facility with regulators. Walking through the documentation for various program elements is a critical step to take with all individuals that might be part of an unannounced regulatory inspection. Remember to have back up personnel informed as well as the primary contacts. If you implemented this practice three years ago, take the time to revisit the regulatory guidance you put into place at that time. As your […]

Remember Proper Lab Attire

The holiday season is here! If your company is participating in any kind of seasonal activities, remind employees to continue to comply with the established PPE policy. Hopefully the policy requires certain personal attire while working in the labs in addition to the use of personal protective equipment appropriate for the hazards present.

Closed toe shoes and full leg coverage should be required for all lab work, and there should be no exception to this rule. Clothing that is loose fitting can also present hazards while working in the labs. Running into the lab to talk to someone about the party tonight without proper PPE should not be permitted. Incidents can happen at any time.

It is a good idea to have a few pairs of scrubs available for use when individuals forget to wear proper personal attire. Having to wear scrubs once or twice might also encourage people to remember proper attire.

Stay focused […]

Be Curious

Safety Partners is celebrating our 25th Anniversary today, October 24, 2017! Having been with the company for over half of those years, this celebration makes me reflect on how important is it to be curious, creative, and practical when implementing EHS programs.

Curiosity can lead to the development of robust EHS programs with depth that could not be achieved otherwise. Asking the ‘what if’ questions can help look around the corner to prevent incident and accidents from occurring. Being inquisitive and having technical discussions with scientists will lead to the development of feasible work practices that will be followed by those scientists. When one suggested solution to an issue does not work out, being creative with alternative solutions to achieve the same goal demonstrates the desire to work together to keep everyone safe.

Even when conducting routine safety checks in the labs, keep an eye and ear out for changes or areas that may need more attention. Ask about new pieces of […]

Re-Evaluate Hazardous Material Processing

When was the last time you conducted a thorough review of the hazardous material processes occurring at your facility, in accordance with 527 CMR 60.8? This review should be conducted at least annually, and lab workers need to be reminded that they should keep EHS informed of changing processes.

If an initial assessment determined that all hazardous material processes fell into Category 1 due to being conducted in vessels less than two and a half gallons in capacity, no permit would be required with the local fire department. However, it is the responsibility of the company to keep an eye on the evolving processes, and document continuous review and assessment. If processes evolve to fall into one of the higher categories, a hazardous material process permit would need to be obtained from the local fire department. Remember to carefully consider the exemptions stipulated in the regulation when conducting the assessment.

When this regulation was first implemented, many companies spent a lot of […]

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 have or do items that fell off the radar […]

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 exposure and at least annually thereafter.

Be sure to […]

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 on Radiation Protection and Measurements (NCRP) Report No. 160 […]

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 obtaining TCHs. Do not wait any longer to register […]

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