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e-Manifest User Fee Proposed Rule Signed

On June 27th, 2016, the EPA Administrator signed the e-Manifest User Fee Proposed Rule. The Hazardous Waste Electronic Manifest Establishment Act requires the EPA to create an electronic system to track hazardous waste shipments, so the implementation of a national e-manifest system is expected in the spring of 2018.

Review TSCA Amendments

You have probably heard that The Frank R. Lautenberg Chemical Safety for the 21st Century Act was signed into law on June 22, 2016. This law amends the Toxic Substance Control Act (TSCA) and is the first major update to an environmental statue in many years.

Treat Temporary Employees As Your Own Employees

When temporary employees are hired at your facility, remember that the host employer and the staffing agency are jointly responsible for ensuring a safe work environment for temporary employees.  In these situations, the temporary staffing agency and host employer share responsibility and control over the workers’ job duties.

Flammable Permits vs. Flammable License

Be careful not to confuse a flammable permit with a flammable license. These are two very different regulatory processes stipulated in 527 CMR 1.00, Massachusetts Comprehensive Fire Safety Code. When discussing flammable permitting, the terms permit and license should not be used interchangeably.

Substitute Plastic for Glass

When conducting risk assessments, job safety analyses, or evaluating the hazards associated with laboratory space, remember to think about the small hazards as well as the high hazards. One ‘small’ hazard that should be addressed is substituting plasticware for glassware whenever possible in order to reduce the risks associated with broken glass.

Encourage Injury, Illness, and Near Miss Reporting

OSHA has issued a Final Rule to Improve Tracking of Workplace Injuries and Illnesses which will take effect on August 10, 2016, with phased in requirements taking effect January 1, 2017. This rule is intended to improve workplace safety and prevent injuries and illnesses by modernizing injury data collection, and better informing workers and the public about workplace hazards.

Document Your Exposure Determination

Are there employees at your facility that work with human blood, blood products, or other potentially infectious materials? Is there a chance that employees at your facility will come into contact with human blood, blood products, or other potentially infectious materials as a result of conducting their job duties?

ASHRAE 110-2016

ASHRAE 110, Methods of Testing Performance of Laboratory Fume Hoods, has been updated to a 2016 version. This standard, which covers a quantitative test procedure for testing fume hood operation, was first developed in 1985 and last revised in 1995.

Audit Sink Logs

If your facility is licensed to work with radioactive material, at least one sink was designated for radioactive waste disposal when the license application was submitted. This sink should be posted and a log to track the radioactive material disposed of down the drain should be maintained.

Keep an Eye Open for Scale-Up

Scale-up can mean different things to different people in terms of actual quantities, but the scale-up of all laboratory work needs to be addressed. It is important for all lab workers to know about scale-up, and the steps that need to be followed when they are considering scaling up their work.