OSHA Rule On Beryllium Effective September 30, 2020

OSHA is amending its existing construction and shipyard standards for occupational exposure to beryllium and beryllium compounds to clarify certain provisions and simplify or improve compliance. These changes are designed to accomplish three goals: to more appropriately tailor the requirements of the construction and shipyards standards to the particular exposures in these industries in light of partial overlap between the beryllium standards' requirements and other OSHA standards; to aid compliance and enforcement across the beryllium standards by avoiding inconsistency, where appropriate, between the shipyards and construction standards and recent revisions to the general industry standard; and to clarify certain requirements with respect to materials containing only trace amounts of beryllium. This final rule does not affect the general industry beryllium standard. https://www.calthacompany.com/uncategorized/new-osha-rule-on-berylium-effective-september-30/ Caltha LLP provides specialized expertise to clients in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Is A Gap Analysis Required Under ISO?

For many organizations considering developing a formal Environmental Management System (EMS) or Safety Management System (SMS) or becoming registered under ISO 14001 or now ISO 45001, two questions asked early on are:

1. What will it cost? and,
2. How long will it take?

To answer these questions, many organizations will conduct a quick assessment of their current status, called a Gap Analysis. The Gap Analysis is a low cost assessment which can usually be completed in one to two days. The Gap Analysis produces an inventory of existing programs which could be used in developing the EMS/SMS. The Gap Analysis evaluates these programs to determine if changes will need to be made, and to what extent, in order to conform to the ISO 14001 or ISO 45001 standard.



Flammable Liquid and Ignitable Hazardous Waste Storage Room



The Gap Analysis is typically formatted as a checklist of questions addressing the various elements of the ISO 14001 / 45001 standard. Based on the results of the Gap Analysis, the organization will understand the areas where improvement will need to be made, and can then do basic resource planning to determine the optimum strategy to move forward, including cost and schedule.


Hazardous Waste Storage Drum In Flammable Cabinet



Caltha LLP provides expert technical support to organizations wanting to improve their EMS or SMS or to become registered under ISO 14001 or ISO 45001. One of Caltha’s key services is help organizations conduct their Gap Analysis and resource planning. For more information go to ISO 14001 and Environmental and Safety Management Systems Services page.

 

Caltha LLP | Your EH&S Compliance, 

Auditing and EMS/SMS Partner

Risk Management Plan Requirements Delayed

In January 2017, EPA published amendments to the Risk Management Program (RMP) Rule 40 CFR Part 68. The amendments included requirements for:

• Root cause analysis as part of an incident investigation;
• Independent third-party compliance audits following a release event reportable under RMP or when an agency requires it based on site conditions;
• Inclusion of a safer technology and alternatives analysis as part of the process hazard analysis for processes in North American Industry Classification System (NAICS) codes 322, 324, and 325 (manufacturing of Paper, Petroleum and Coal Products, and Chemicals);
• Emergency response enhancements such as annual coordination with local emergency response agencies, annual testing of emergency notification procedures, and full field exercises at least every 10 years for responding facilities; and
• Measures to increase availability of chemical hazard information to the public.

Aboveground Product Vessels



Following publication of the amendments, EPA received several petitions for reconsideration and request for stay of the amendments. On June 9, 2017, the EPA Administrator signed a final rule to delay the effective date of the RMP rule amendments until February 19, 2019.





Caltha LLP | Your Safety and Health Compliance
Management Partner

Revised 2018 Flammable and Combustible Liquids Code Released

The National Fire Protection Association (NFPA) has released a revised 2018 edition of NFPA 30 Flammable and Combustible Liquids Code. This version replaces the prior edition published in 2015. NFPA 30 is referenced in numerous OSHA, emergency prevention and pollution prevention regulatory programs and becomes enforceable under OSHA and many state and local regulations, NFPA 30 provides safeguards to reduce the hazards associated with the storage, handling, and use of flammable and combustible liquids.

The NFPA 30 code applies to the storage, handling, and use of flammable and combustible liquids, including waste liquids. It is intended to "reduce the hazard to a degree consistent with reasonable public safety, without undue interference with public convenience and necessity, of operations that require the use of flammable and combustible liquids." Compliance with the code does not eliminate all hazards in the use of flammable and combustible liquids.

Improper Storage And Labeling of Flammable 

Waste Observed During Audit

The NFPA 30 code does not apply to:

• Any liquid that has a melting point of 100°F (37.8°C) or greater
•  Any cryogenic fluid or liquefied gas
• Any liquid that does not have a flash point, but which is capable of burning under certain conditions
• Mixtures of flammable or combustible liquids and halogenated hydrocarbons either do not exhibit a flash point using the standard closed-cup test methods or will exhibit elevated flash points.
• Any aerosol product, which are addressed in NFPA 30B, Code for the Manufacture and Storage of Aerosol Products.
• Any mist, spray, or foam
• Transportation of flammable and combustible liquids as governed by the U.S. Department of Transportation, which are addressed in NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, and in the U.S. Department of Transportation’s Hazardous Materials Regulations, Title 49, Code of Federal Regulations, Parts 100–199.
• Storage, handling, and use of fuel oil tanks and containers connected with oil-burning equipment, which are addressed in NFPA 31, Standard for the Installation of Oil- Burning Equipment.
• Use and installation of alcohol-based hand rub (ABHR) Dispensers, which are addressed in NFPA1, Fire Code, and NFPA101, Life Safety Code.

Caltha LLP | Your Safety and Health Compliance Management Partner

Hazardous Waste Management Training In Minnesota

Minnesota-based Environmental, Health & Safety Trainer

Caltha LLP, a Minnesota headquartered EH&S training and consulting company, provides training to facility employees that is required to meet State and Federal regulations, and needed to ensure sustainability, safety and liability management goals are achieved.

Training is provided in a number of flexible formats, including in-person sessions at your site, web-based "live" training, and preparation of customized training modules used by your employees at their convenience.

We provide a wide range of training programs for facilities across Minnesota, including:

SWPPP training	Annual SPCC training	HazCom training
Safety data sheet training	PPE training	Hazardous waste training -LQG
Hazardous waste training -SQG	Environmental awareness	ISO 14001 Awareness
ISO 18001 Awareness	Universal waste training	AWAIR training
HazMat DOT training	Hazard Communication	Workplace spill training

Improper Storage and Labeling of a Flammable Hazardous Waste 

Identified During Waste Audit 

Providing EH&S Training To Facilities Across Minnesota

Caltha provides training to facilities located in all parts of Minnesota and routinely leads training sessions in:

Minneapolis	St. Paul	Rochester	Duluth	Bloomington
Brooklyn Park	Plymouth	Woodbury	Eagan	Maple Grove
Coon Rapids	Blaine	Eden Prairie	Burnsville	Bemidji
St. Cloud	Marshall	Minnetonka	Edina	St. Louis Park
Moorhead	Mankato	Maplewood	Shakopee	Cottage Grove

Minnesota-based Consultant With MPCA, MnOSHA and Local Agency Knowledge

Caltha LLP maintains close ties with the key State and local agencies that oversee environmental and safety compliance programs,  including the Minnesota Pollution Control Agency, Minnesota OSHA, The Metropolitan Council, who regulates wastewater in the Minneapolis- Saint Paul area, and the seven Metro area Counties (Hennepin, Ramsey, Anoka, Washington, Dakota, Carver, Scott) who regulate hazardous wastes.

Click here for more information or to request a quote on Caltha's EHS training services, including Hazardous Waste and DOT Hazardous Material certification training for hazardous waste generators.

2016 OSHA Silica Rule Upheld By Federal Court

On December 22 the U.S. Court of Appeals for the District of Columbia upheld the OSHA crystalline silica rule, rejecting all objections raised by industry groups. In 2016, OSHA published a final rule regulating workplace exposure to silica, Occupational Exposure to Respirable Crystalline Silica (29 CFR 1910, 1915 and 1926).

The industry groups had petitioned for review of several issues:

• Whether substantial evidence supports OSHA’s finding that limiting workers’ silica exposure to the level set by the rule reduces a significant risk of material health impairment.
• Whether substantial evidence supports OSHA’s finding that the rule is technologically and economically feasible
• Whether OSHA had complied with the Administrative Procedure Act (APA) in promulgating the rule, and
• Whether substantial evidence supports two provisions of the rule, which allow workers who undergo medical examinations to keep the results confidential from their employers and prohibiting employers from using dry cleaning methods unless doing so is infeasible.

Unions had requested review of parts of the rule requiring that medical surveillance for construction workers be provided only if the employee has to wear a respirator for 30 days for one employer in a one-year period and the absence of medical removal protections (MRP).

The Court rejected the unions’ challenge to the construction standard’s 30-day trigger for medical surveillance, however the Court did find that OSHA was arbitrary and capricious in declining to require MRP for some period when a medical professional recommends permanent removal, when a medical professional recommends temporary removal to alleviate COPD symptoms, and when a medical professional recommends temporary removal pending a specialist’s determination. The Court concluded that OSHA failed to adequately explain its decision to omit medical removal protections from the rule and remanded that portion of the rule back to OSHA for further consideration.

Certified Environmental and Safety Audit in Raleigh

Caltha LLP Project Summary

Project: Multimedia EH&S Compliance Audit
Client: National Corporation
Location(s): Raleigh-Durham Region, North Carolina

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, hazard communication

Overview: Caltha staff conducted a multimedia environmental, health and safety audit of this industrial facility located in Raleigh-Durham Region. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management- 15A NCAC 13B
• Current NC Air Permit
• NC Air Pollution Control Rule – NCAC 15A-2D
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.


Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in North Carolina and NC regulatory updates.

ISO 45001 Safety Management Standard Draft Published

The International Organization for Standardization (ISO) has release a final draft of it proposed International Standard for Occupational Health and Safety Management Systems, designated ISO 45001. Publication of the final standard is likely to be in the first half of 2018.

The standard is being developed by a committee of occupational health and safety experts, and will follow other generic management system approaches such as ISO 14001 and ISO 9001. It will take into account other International Standards in this area such as OHSAS 18001, the International Labour Organization's ILO-OSH Guidelines, various national standards and the ILO's international labor standards and conventions.

For those organizations that have already developed safety and health programs under OHSAS 18001, the publication of ISO 45001 will be particularly significant. OHSAS 18001 will be withdrawn on publication of ISO 45001 and organizations currently certified to OHSAS 18001 will have a three year period to migrate to ISO 45001.

Click here for examples of Caltha projects related to management systems and specifically on health and safety.

Beryllium Worker Exposure Rule Deadlines

OSHA has issued a final rule limiting worker exposure to beryllium and beryllium compounds. The rule contains standards for general industry, construction, and shipyards which take effect on May 20, 2017. Employers must comply with most elements of the rule starting March 12, 2018.


The key provisions of the rule are:

• Reduces the permissible exposure limit (PEL) for beryllium to 0.2 micrograms per cubic meter of air, averaged over 8-hours.
• Establishes a new short term exposure limit for beryllium of 2.0 micrograms per cubic meter of air, over a 15-minute sampling period.
• Requires employers to: use engineering and work practice controls (such as ventilation or enclosure) to limit worker exposure to beryllium; provide respirators when controls cannot adequately limit exposure; limit worker access to high-exposure areas; develop a written exposure control plan; and train workers on beryllium hazards.
• Requires employers to make available medical exams to monitor exposed workers and provides medical removal protection benefits to workers identified with a beryllium-related disease.

Click here for more details on the safety, health and emergency preparedness services Caltha provides.


Click here to review a sampling of our past safety related projects.

Safety And Health Consultant Services In Minnesota

The development of cost effective safety programs to manage risks and to comply with OSHA regulations is a core service provided by Caltha LLP. Caltha also provides expert professional & technical support in developing safety management systems and in OHSAS 18001 registration. Caltha also supports our clients’ liability management programs by providing both systems and compliance auditing services.

Developing safety management programs that are easy to implement, document & track is an important service Caltha provides to our clients. This includes integrating compliance management with other risk management, quality improvement and cost control initiatives that our clients may already have. Caltha will train your staff to successfully implement the safety management programs in the future.

Caltha can also provide "as needed" technical support in preparing and maintaining OSHA compliance records, and to conduct incident investigations to support a root cause analysis. Caltha staff have led multi-disciplinary teams to develop corrective action plans arising from variety of incidence, including injuries, accidents, spills and fires.

Click here for more details on the safety, health and emergency preparedness services Caltha provides.

Click here to review a sampling of our past safety related projects.

Silica Rule Is Enforced Starting September 2017; General Industry Rule in 2018

US OSHA began enforcing the respirable crystalline silica rule for the construction industry on September 23, 2017. The rule had been set to go into effect in June; however, the Department of Labor and OSHA delayed enforcement of the rule by 90 days. The delay was intended to provide DOL and OSHA additional time to issue guidance to industry regarding compliance. The construction silica rule is a companion to OSHA’s general industry silica rule that is scheduled to be enforceable beginning June 23, 2018.

The rule lowers the permissible exposure limit (PEL) for respirable silica dust in the construction industry, to 50 microgram per cubic meter exposure limit, calculated as an eight-hour time-weighted average (TWA). Employers subject to the construction rule may comply by implementing required engineering and work practice controls and respiratory protection , or by completing exposure assessments  of employees above the action level of 25 micrograms per cubic meter.

Under the rule, employers must:

• Make medical screening available to employees who are required to use a respirator more than 30 or more days per year;
• Develop a written exposure control plan;
• Maintain certain records; and
• Comply with certain limitations on housekeeping practices, such as using wet sweeping, HEPA-filtered vacuuming, or other methods designed to reduce employee exposure when feasible.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Chicago Multimedia Compliance Audit For Manufacturing Plant

Caltha LLP Project Summary

Project: HSE Compliance Audit
Client: High Tech Manufacturer
Location(s): Chicago, Illinois

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, PPE assessment, hazard communication


Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this manufacturing facility located in Cook County. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management
• Current IEPA Air Permit
• Cook County Air Emission Ordinance
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

For more information on Caltha LLP services, go to the Caltha Contact Page

PPE Assessment and Employee Exposure Review For Minnesota Manufacturer

Caltha LLP Project Summary

Project: PPE Assessment
Client: Chemical Formulating Facility
Location(s): Minnesota

Key Elements: PPE assessment, OSHA hazard communication, employee training, safety data sheet, employee exposure control

Overview: Caltha LLP was retained by this chemical processing facility to conduct a PPE assessment for specific processing areas, including dry mixing, blending, wet mixing, and packaging. Caltha staff reviewed raw material and finished product safety data sheets, as well as specific tasks being conducted in each area. For each area, a standard set of employee PPE was prescribed; specific materials which require additional or other types of PPE were then identified. Employees were provided training, including visual reminders at each work station, to alert them when PPE beyond the standard was required.

For more information on Caltha LLP services, go to the Caltha Contact Page

OSHA Recordkeeping Rule On Recordable Injuries Nullified After Congressional Review

On March 22, the US Senate voted to nullify OSHA’s rule “Clarification of Employer’s Continuing Obligation to Make and Maintain Accurate Records of Each Recordable Injury and Illness,” commonly referred to as the “Volks” rule. The “Volks” rule made recordkeeping requirements a continuing obligation for five years. The rule gave OSHA the ability to issue citations to employers for failing to record work-related injuries and illnesses during a 5-year retention period, compared to the six-month statute of limitations. The final rule was in response to a 2012 U.S. Court of Appeals decision that held that OSHA could not issue citations for failing to record an injury or illness beyond the six-month statute of limitations set out in the statute.

OSHA issued the proposed rule in July 2015, which was finalized in December 2016 and became effective in January 2017. According to OSHA, the rule was meant to “clarify that the duty to make and maintain an accurate record of an injury or illness continues for as long as the employer must keep and make available records for the year in which the injury or illness occurred. The duty does not expire if the employer fails to create the necessary records when first required to do so.”

The resolution passed the House of Representatives on March 1, 2017 and on March 22 the Senate adopted the resolution indicating that Congress believed OSHA had exceed its authority in issuing the final rule.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 
 

Amendment To OSHA Laboratory Practices Guidelines

The Occupational Safety and Health Administration (OSHA) has updated a non-mandatory appendix in OSHA's Occupational Exposure to Hazardous Chemicals in Laboratories Standard. This new revision addresses current laboratory practices, security, and emergency response, as well as promoting safe handling of highly toxic and explosive chemicals and their waste products. The non-mandatory appendix was revised to include the contents of the latest National Academy of Sciences publication entitled, "Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards," 2011 edition. The effective date of this technical amendment to the standard is January 22, 2013.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

OSHA Guidance On Protecting Workers During Crushing & Recycling Fluorescent Bulbs

OSHA has issued two new educational resources to help protect workers from mercury exposure while crushing and recycling fluorescent bulbs. Compact fluorescent bulbs are more efficient than incandescent bulbs, but the shift to energy-saving fluorescents, which contain mercury, calls for more attention to workers who handle, dispose of, and recycle used fluorescent bulbs.

An OSHA fact sheet explains how workers may be exposed, what kinds of engineering controls and personal protective equipment they need, and how to use these controls and equipment properly. In addition, a new OSHA Quick Card alerts employers and workers to the hazards of mercury and provides information on how to properly clean up accidentally broken fluorescent bulbs to minimize workers' exposures to mercury.

According to OSHA, fluorescent bulbs can release mercury and may expose workers when they are broken accidentally or crushed as part of the routine disposal or recycling process. Depending on the duration and level of exposure, mercury can cause nervous system disorders such as tremors, kidney problems, and damage to unborn children.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Chemical Safety Board (CSB) 2012 - 2016 Strategic Plan

The U.S. Chemical Safety Board (CSB) has released its 2012 - 2016 Strategic Plan. The new strategy updates the 2007 - 2012 CSB Strategic Plan, including the CSB's strategic goals, objectives, and associated measures for managing and evaluating agency operations.The final version of the plan features a "CSB Most Wanted Program" that serves to focus CSB outreach initiatives for key CSB recommendations.

The plan contains measurable objections and concentrates on three main goals:

1. Conduct incident investigations and safety studies concerning releases of hazardous chemical substances. This goal fulfills the core missions of the Board by ensuring that CSB selects and completes incident investigations that have the potential to generate recommendations with high preventative impact. It also directs the CSB to develop and complete safety studies with an emphasis on emerging safety issues.
2. Improve safety and environmental protection by ensuring that CSB recommendations are implemented and by broadly disseminating CSB findings through advocacy and outreach. CSB says its successful safety videos are an important component of its dissemination efforts.
3. Preserve the public trust by maintaining and improving organizational excellence. CSB endeavors to use best practice project management in all agency processes, including administration and service functions.

The CSB is an independent federal agency charged with investigating industrial chemical accidents. CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems. The Board also makes safety recommendations to plants, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

OSHA Alert On Silica Exposure During Fracing Operations

The Occupational Safety & Health Administration (OSHA) has issued a hazard alert regarding potential overexposure to silica as a health hazard to workers conducting hydraulic fracturing operations. As noted in the alert, respirable silica is a hazard common to many industries and industrial processes.

Since large quantities of silica sand are used during hydraulic fracturing, NIOSH began a cooperative effort in January 2010 to collect data regarding silica exposure at hydraulic fracturing operations. Working in cooperation with oil and gas industry partners to sample the air at 11 sites in five states where hydraulic fracturing operations were taking place, NIOSH identified seven primary sources of silica dust exposure during fracturing operations:

• Dust ejected from thief hatches (access ports) on top of the sand movers during refilling operations while the machines are running (hot loading).
• Dust ejected and pulsed through open side fill ports on the sand movers during refilling operations
• Dust generated by on-site vehicle traffic.
• Dust released from the transfer belt under the sand movers.
• Dust created as sand drops into, or is agitated in, the blender hopper and on transfer belts.
• Dust released from operations of transfer belts between the sand mover and the blender; and
• Dust released from the top of the end of the sand transfer belt (dragon's tail) on sand movers.

It also found that workers downwind of sand mover and blender operations, especially during hot loading, had the highest silica exposures. Transporting, moving, and refilling silica sand into and through sand movers as well as along transfer belts and into blender hoppers, can also release dust into the air containing up to 99% silica that workers breathe.

The alert describes how a combination of engineering controls, work practices, protective equipment and product substitution, where feasible, along with worker training, can protect workers who are exposed to silica. According to OSHA, engineering controls and work practices provide the best protection for workers.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

OSHA To Discuss Requirements For OSHA-approved State Plans

OSHA has scheduled an informal stakeholder meeting for June 25, 2012 on establishing definitions and measures to determine whether OSHA-approved State Plans for occupational safety and health (State Plans) are at least as effective as the federal OSHA program. The purpose of this meeting is to provide a forum to gather information and ideas on key outcome and activity based indicators and how OSHA can use such indicators to assess the effectiveness of State Plans.

The specific issues to be discussed will include the following:

• OSHA's mission is "to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance."
• How would you define or describe the components that constitute an OSHA-approved State Plan that was "effective" in achieving this mission (e.g., funding, staffing, standards setting, strong enforcement program, strong consultation program, frequency of inspection, strong training and outreach programs, level of penalties etc.)?
• What outcome based measures would you use to determine whether OSHA-approved State Plans were achieving this mission (e.g., reductions in injury and illness rates, reductions in fatality rates, etc.)?
• What activity based measures would you use to determine whether OSHA-approved State Plans were achieving this mission (e.g., number of inspections conducted, number of violations issued, etc.)?
• Should there be a core set of effectiveness measures that both OSHA and State Plan programs must meet?
• What activity and outcome based measures would you use to assess effectiveness as it relates to the reduction of health hazards?
• What activity and outcome based measures would you use to assess the effectiveness of the whistleblower program under Section 11(c) of the Act?
• What indicators would you use to determine and monitor whether OSHA-approved State Plans are "at least as effective" as federal OSHA as outlined in Section 18(b) of the Act?

The stakeholder meeting is scheduled to take place on June 25, 2012 from 10 a.m. to 1 p.m. in Washington, DC. The deadline for registration to attend or participate in the meeting and to submit written comments is June 11, 2012.

Caltha LLP provides specialized expertise to clients nationwide in the Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

New Massachusetts Regulations On Hazardous Material Storage

The Chemical Safety and Hazard Investigation Board (CSB) has approved changes to Massachusetts regulations on hazardous materials storage and processing in the state, which includes monitoring of high risk facilities to ensure they are complying with key federal process safety and risk management programs.

The Massachusetts Department of Fire Services has satisfied a key recommendation made by the CSB in its 2008 final report on the 2006 explosion at an ink and paint products manufacturing facility in Danvers, MA. The CSB concluded that an unattended mixing tank overheated in an unventilated building causing the release of flammable vapors which subsequently ignited. The facility stored alcohols, heptanes, other solvents, pigments, resin and nitrocellulose; all of which were destroyed in the explosion. In addition, 24 houses and 6 businesses were destroyed.

An investigation found that the company had increased its quantities of flammable liquids over the years. The additional quantities went undetected by local authorities who had not inspected the facility for over 4 years prior to the time of the incident.

Massachusetts now requires companies storing and handling flammable materials to amend their license and re-register with state or local authorities when increasing their quantities of flammable materials; they must also verify compliance with local and state fire codes and hazardous chemical regulations. The Massachusetts regulations classify hazardous materials into five categories based on threshold quantities. Categories 1–4 must be in compliance with OSHA's Hazard Communication standard. Category 5, under which the ink and paint product manufacturing facility would have fallen, requires companies to certify compliance with the OSHA Process Safety Management standard and with the EPA Risk Management Program regulation.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website