Thursday, December 28, 2017

Waters of the United States Redefinition Delayed

The EPA and U.S. Department of the Army have proposed to extend the effective date of the 2015 rule defining “waters of the United States.”  The agencies are proposing that the 2015 rule would not go into effect until two years after this action is finalized and published in the Federal Register. The rule, developed by the Obama’s administration, has been held up in 13 courts nationwide and faces a date in the U.S. Supreme Court.

This action follows the February 28, 2017, Presidential Executive Order on "Restoring the Rule of Law, Federalism, and Economic Growth by Reviewing the 'Waters of the United States' Rule." The February Order states that it is in the national interest to ensure that the Nation's navigable waters are kept free from pollution, while at the same time promoting economic growth, minimizing regulatory uncertainty, and showing due regard for the roles of Congress and the States under the Constitution.

The agencies’ proposal is separate from the two-step process the agencies propose to take to reconsider the 2015 rule. The comment period for the Step 1 rule closed in September and the agencies are currently working to review the comments received from the public. The agencies are also in the process of holding listening sessions with stakeholders as EPA and the Army Corps work to develop a proposed Step 2 rule that would revise the definition of “waters of the United States.”

The agencies will be collecting public comment on this proposal for 21 days after publication in the Federal Register and plan to move quickly to take final action in early 2018.

Additional information on this proposal and how to comment are available at this link: http://www.epa.gov/wotus-rule.

Wilmington, NC RCRA and DOT Training

Register for Hazardous Waste Management: The Complete Course and DOT Hazardous Materials Training: The Complete Course in Wilmington, DE, on December 5–7 and save $100. To take advantage of this offer, click here or call 800-537-2372.

Burbank RCRA and DOT Training

Register for California Hazardous Waste Management and DOT Hazardous Materials Training: The Complete Course in Burbank, CA, on December 5–7 and save $100. To take advantage of this offer, click here or call 800-537-2372.

Raleigh RCRA, DOT, IATA and SARA Training

Register for Hazardous Waste Management: The Complete Course and DOT Hazardous Materials Training: The Complete Course in Cary, NC, on January 8–10 and save $100. Learn how to comply with the regulations for dangerous goods by air at IATA: How to Ship Dangerous Goods by Air on January 11.  Ensure you understand your reporting obligations the SARA Title III (EPCRA) Workshop on January 12. To Register for these courses, click here or call 800-537-2372.


Post originally published on https://www.ercweb.com/tips/show/waters-of-the-unites-states-redefinition-delayed

Wednesday, October 25, 2017

Safety and Health Implications of Occupational

Increasing numbers of robots are entering the 21st century workplace, yet the benefits and potential risks of robots in the workplace aren’t fully known. To address the knowledge gap related to robotics and worker safety and health, the National Institute for Occupational Safety and Health (NIOSH) announces the launch of the Center for Occupational Robotics Research. The new Center will assess potential benefits and risks of robot workers and develop guidance for safe interactions between human and robot.

“Robots working collaboratively with humans present a new workplace risk profile that is not yet well understood,” said NIOSH Director John Howard, M.D. “Not only is this a new field for safety and health professionals, little government guidance or policy exists regarding the safe integration of robots into the workplace. NIOSH’s Center for Occupational Robotics Research will provide the scientific leadership needed to ensure human workers are protected.”

Robots are not new to the workplace. Advancements in sensing technology, however, have led to the evolution of the conventional industrial robot working in isolation to smarter, collaborative robots that work alongside, move amongst, or are worn by human workers.

NIOSH researchers have identified 61 robot-related workplace deaths between 1992 and 2015. The Center will continue to monitor trends in injuries associated with both traditional and emerging robotics technologies.

“We suspect fatalities will increase over time because of the growing number of industrial robots being used by companies in the U.S., and from the introduction of collaborative and co-existing robots, powered exoskeletons, and autonomous vehicles into the work environment,” said Dawn Castillo, M.P.H., director of NIOSH’s Division of Safety Research and the Center’s program manager. “NIOSH has a history of robotics research and through the Center for Occupational Robotics Research, we are poised to proactively address the safety of today’s and tomorrow’s workers who use, wear, or work near robots.”

NIOSH will work in partnership with partners in academia, industry, and government to establish risk profiles of robotic workplaces, identify research needs and conduct research to improve the safety, health, and wellbeing of humans working with robots and robotic technologies and support the development and adoption of consensus safety standards. The Center’s first formal partnership was established on October 5, 2017—an Alliance with the Occupational Safety and Health Administration and the Robotics Industry Association.

Post originally published on https://www.ercweb.com/tips/show/safety-and-health-implications-of-occupational-robots

Revised Hazard Communication Standard Enforcement Creates New Challenges

SHA recently issued instructions to compliance safety and health officers on how to ensure consistent enforcement of the revised Hazard Communication standard. OSHA revised the Hazard Communication standard in March 2012 to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals. The revised standard was designed to improve the quality, consistency, and clarity of chemical hazard information that workers receive.

Under the standard, employers were required to train workers on the new label elements and safety data sheets by December 1, 2013. Chemical manufacturers, importers, and distributors had to comply with revised safety data sheet requirements by June 1, 2015. Manufacturers and importers had to comply with new labeling provisions by June 1, 2015. Distributors have until December 1, 2015, to comply with labeling provisions as long as they are not relabeling materials or creating safety data sheets, in which case they must comply with the June 1 deadline.

OSHA’s new instruction outlines the revisions to the Hazard Communication Standard, such as the revised hazard classification of chemicals, standardizing label elements for containers of hazardous chemicals, and specifying the format and required content for safety data sheets. It explains how the revised standard is to be enforced during its transition period and after the standard is fully implemented on June 1, 2016.

The instruction explains how OSHA compliance officers are to enforce differences in the international regulations and the OSHA regulations. OSHA’s Hazard Communication Standard (HCS 2012) is based on the United Nations (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS Revision 3, 2009, also known as the Purple Book). Some manufacturers, importers, distributors, or employers may want to comply with more recent or future versions of GHS issued by the UN, such as Revision 4. However, using Revision 4 or a more recent version may result in non-compliance with HCS 2012 if it contradicts or casts doubt on OSHA required information.

A specific example of a major difference between Revision 3 and Revision 4 concerns aerosols. GHS Revision 4 changed “flammable aerosols” to “aerosols.” Revision 4 also introduced a new hazard category for aerosols: Category 3 (nonflammable). Under Revision 4 of the Purple Book, aerosols in Category 3 do not require a pictogram and are exempt from classification as a gas under pressure. OSHA’s HCS 2012 does not include Category 3 Aerosols, so if an aerosol meets the criteria for a gas under pressure, it would require appropriate label elements including the gas under pressure pictogram.

In this situation, OSHA’s guidance to its enforcement officers is to a serious citation for a Category 3 Aerosol whose label and SDS section 2 statements are in accordance with GHS Revision 4 (i.e., missing pictogram and being exempt from classification as gas under pressure).

Because other countries are adopting Revisions 4 and 5 of the Globally Harmonized System, US companies that export products internationally (as well as those that import foreign products labeled to meet other countries’ requirements) will need to carefully review each country’s requirements, and where appropriate, develop different product labels and Safety Data Sheets in order to maintain compliance with each country’s legislation. If you need consulting assistance to ensure that your labels and SDSs meet OSHA and international requirements, contact Environmental Resource Center at 800-537-2372.

This post was first published on https://www.ercweb.com/tips/show/osha-guidance-on-revised-hazard-communication-standard-enforcement-creates-new-challenges