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Take Advantage of e-Manifest Resources

Be sure to take advantage of the available resources that provide guidance on the implementation of e-manifests. From what I have been seeing and hearing, there are many questions surrounding this topic. EPA has issued a very useful e-Manifest Frequently Asked Questions summary that provides guidance on the logistics of the e-manifest system. 

OSHA Enforcement of Beryllium Standard

OSHA recently announced that they will begin enforcing certain requirements of the beryllium final rule, including the permissible exposure limits, exposure assessment, respiratory protection, medical surveillance, and medical removal provisions. 

Evaluate USDA Permitting Applicability

The United States Department of Agriculture (USDA) regulates the transport of potentially invasive species, pests, and/or agricultural threats through their Animal and Plant Health Inspection Service (APHIS).

Launch of myRCRAid in Massachusetts

For anyone that has been following the e-manifest updates provided by the EPA, you know that the myRCRAid module within the RCRAInfo Industry Application system is not available in MA to date.

Be Prepared for Spring

It finally appears that spring is on its way and there will be no more snow! Be prepared for spring by thinking about your PPE policy and consider any spring cleaning that could happen in your labs.

Avoid Unknowns

Consider taking a walk through of your labs with the sole purpose of looking at labeling. Keep an eye out for compliance with labeling of chemical bottles, aspiration flasks, tubes, samples, etc. How many instances of encountering a potential ‘unknown’ would you come across?

Maintain SDSs for Approved Disinfectants

The Massachusetts State Sanitary Code, 105 CMR 480, requires generators of medical and biological waste to maintain a Medical/Biological Waste Record-keeping Log with various information related to the biological waste handling practices.

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.