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Share Hazard Assessments

There seem to be more and more facilities operating with shared laboratory space these days. Some facilities have very clearly defined and distinct lab space for each company, and some facilities offer the opportunity to share bench space and equipment.

Become Involved in Relocation Plans Early

As companies evolve, relocations seem almost inevitable for many facilities. Relocating an entire facility, expanding to additional space, and downsizing all require involvement from EHS personnel early in the process.

Start Preparing for e-Manifests Coming in June

The EPA is planning to launch their long anticipated Electronic Manifest System (e-Manifest) this June. There are a couple of tasks that regulated entities can do now in order to prepare for the roll out of this system.

Keep Emergency Planning Documents Up to Date

As we are experiencing the third Nor’easter in a short period of time, this should serve as a good reminder to keep emergency planning documents up to date. Various regulations stipulate requirements for emergency planning, including OSHA regulations, the Massachusetts Comprehensive Fire Safety Code, and hazardous waste regulations.

New Plumbing Board Policy Enacted

On February 7, 2018, the Plumbing Board enacted a policy that adopts the ANSI Z-358.1 Standard for Emergency Eyewashes and Shower Equipment. The MA Uniform State Plumbing Code, 248 CMR 10.00, ANSI Z-358.1 standard, and OSHA regulations present several inconsistencies with requirements for the installation, operation, and maintenance of emergency eyewashes and safety showers.

Document Annual Safer Sharps Evaluation

OSHA’s Bloodborne Pathogen Standard, 29 CFR 1910.1030, applies to all occupational exposure to blood or other potentially infections material as defined in the standard. Employers that have covered employees are required to develop and implement an Exposure Control Plan to minimize employee exposure.

Have You Conducted Your Annual Radiation Safety Program Audit?

In accordance with 105 CMR 120.210(C), facilities licensed to work with radioactive materials must review the radiation protection program content and implementation at intervals not to exceed 12 months. This should be a formal process that is documented to demonstrate compliance with this requirement.

File Biennial Reports Using RCRAInfo Industry Application

If you are registered with the MA DEP as a Large Quantity Generator (LQG) of hazardous waste, do not forget that 2018 is a year when biennial reports must be filed. A new electronic reporting system called RCRAInfo Industry Application (RIA) must be used to file.

OSHA is Encouraging Incident Prevention

OSHA is strongly encouraging employers to join the trend towards incident prevention by identifying and addressing hazards before they lead to injury or illness. While employers are reviewing their OSHA 300 logs, they are asking companies to use these logs as a road map to finding and fixing hazards.

Review Amendments to 527 CMR 1.00

The Massachusetts Comprehensive Fire Safety Code, 527 CMR 1.00, was revised as of January 1, 2018. The revisions mainly update this code by adopting the 2015 edition of NFPA 1, with amendments specific to Massachusetts. The previous version was based on the 2012 edition of NFPA 1.

Remember to Post OSHA Form 300A

As incidents, accidents, and illnesses are reported throughout the year, incidents that meet OSHA recordable criteria must be recorded on the OSHA 300 log. All employers that fall under Part 1904 are then responsible for posting the OSHA 300A form by February 1st of the following year.