Newsletters

The Safety Net is a newsletter published by NETC. The following articles were from the Winter 1999 edition.

By: Robert Ziegler

By: Robyn Hescock, IH

Protecting and improving the environment has recently become a major concern. Although global warming, ozone depletion, contamination of water and air quality were identified as serious pollution issues by “tree hugger’s” 30 years ago, only recently has the general population begun to understand the significance of industrial activity on the environment and the implications to future life on this planet. Today more than ever, business is under increasing pressure to operate clean, environmentally friendly operations and the EPA and DEP have created a multitude of regulations and permitting requirements to assure just that. Below is a list of some of the more common permits that may apply to your business. This listing is only a guide and is not intended to be all-inclusive:

Air emissions

·         Boilers, furnaces, heaters and incinerators - Operating permits, annual pre-season inspections;

·         Process equipment - Operating permits for major sources of air emissions.

·         Underground storage tank vents

·         Emergency generators

·         Dust collectors/baghouses - Particulate emissions from dust collectors or bag filter operations may require a state operating permit identifying PM10 emissions.

·         Fugitive dust - Formal written plans identifying control measures  to minimize fugitive dust emissions from parking lots, dirt roads, storage piles, etc.

·         SARA Form R Emission Reports - Facilities with aggregate annual air emissions greater than specified limits for identified chemicals are required to submit emissions data to numerous agencies by July 1 of each year.

·         Annual emissions reports - Annual emission summaries to the regulating agency to demonstrate compliance;

Storage tanks

·         Registration

·         Financial responsibility documentation

·         Flammable liquid storage licenses

Facilities/building operations

·         Construction/building permits - Local building or construction permits are required for many remodeling or new-construction activities involving electrical, plumbing, HVAC, or sprinkler protection systems.

·         Flammable liquid storage permits

·         Passenger/freight elevators, dock levelers and dumb waiters.

·         Pressure vessels/water heaters - Annual certificates of inspection for any pressure vessel, such as water heaters, compressed air receivers and water expansion tanks.

·         Food preparation/service - Occupancy permits for areas serving food.

Sewer discharges

·         Discharges - Reporting, waste characterization and volume estimates for use in calculating annual user charges, discharge limitations.

·         Pretreatment operating licensing - Requirement to install pretreatment processes to prevent their introduction into the wastewater stream.

·         Stormwater sewer discharges - Permit and written stormwater pollution prevention plan (SPPP);

·         NPDES discharges - Point-source discharges into public waterways (rivers, streams or lakes) are regulated by the Clean Water Act, which requires that formal permits be obtained approving such discharges.

·         Spill prevention and control and countermeasure plan - Plan my be required for unintentional release of oil or a hazardous material.

Municipal/solid waste disposal

·         Solid waste disposal permits

·         Hazardous waste generator identification numbers

Miscellaneous

·         PCB transformer registration and testing

·         Asbestos/Non-asbestos certifications - Insulation and acoustical building materials installed before 1980 must be tested prior to any disruption or removal activities. Asbestos-containing materials must be disposed of in licensed “special waste landfills” in accordance with all state and local regulations.

·         Annual SARA Title III Tier 2 Reports - Facilities storing specified hazardous chemicals in excess of certain quantity limitations must prepare and submit Emergency and Hazardous Chemical Inventory reports to state and local agencies identifying chemical names, storage quantities and location, and emergency contacts.

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By: Dave Lundquist, RN

An OSHA local emphasis program (LEP) for the New England Region is focusing on enforcement and outreach efforts for fall protection. The directive asks compliance officers to observe for fall hazards during routine travels. On the spot inspections may be opened when compliance officers observe apparent fall protection hazards. This LEP was instituted to reduce the increased number of fatal falls occurring in our region. Remember that fall protection is required under both the Construction and General Industry Standards.

Fall protection is much more then supplying employees with personal fall arresting (PFA) equipment. The improper use of this equipment constitutes a hazard in and of itself. Fall protection training must include the use of guardrails, safety nets and personal fall protection equipment as it is used in your organization. Hazard recognition and training must include electrical, covers, ramps, excavations, falling objects, inspection and maintenance of PFA equipment and other issues related to your operations. Fall protection training is also required with elevating lifts (articulating / extensible booms, scissors lifts, etc.), scaffolding and ladders. Workers exposed to overhead fall hazards (falling objects) also need training. This is an important Standard for employee safety that is frequently overlooked by general industry and commercial residential contractors. An excellent book titled Introduction to Fall Protection by J. Nigel Ellis (3rd edition due out soon) serves as a reference and is available through the American Society of Safety Engineers (847) 699-2929. Call one of our Safety Specialists if you require information or assistance with implementing or reviewing your fall protection program.

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By: Dave Lundquist, RN

OSHA has released a revised directive to guide compliance officers when evaluating facilities for Bloodborne Pathogen compliance. OSHA has received nearly 400 comments from health care facilities, workers and others that emphasized the wider use of safe medical devices to reduce employee exposure. Highlights of this directive include the following:

- The annual review of your exposure control plan must include the consideration and use of safer medical devices.

- Employers must rely on relevant evidence in addition to FDA approval to ensure the effectiveness of devices to prevent Bloodborne Pathogen exposure.

- Effective training through the use of interactive training sessions verses video training to allow for discussion with a qualified trainer.

- Guidelines from the Center for Disease Control are added for vaccinations against Hepatitis B virus and for post exposure evaluations for HIV and Hepatitis C virus.

The full version text of this directive should be consulted for detail compliance information. See osha.gov for compliance directive CPL 2-2.44D.

The current standard is further clarified through written interpretations. These interpretations provide valuable information to the intent and enforcement of the standard. A recent letter clarifies the recordability of the Hepatitis B booster administered after an exposure incident. This booster shot is considered as a recordable medical treatment on the OSHA 200 Log.

Don’t forget the CDC latex allergy alert and how this effects your Personal Protection Equipment program.

For clarifications or answers to your questions, call one of our Safety Specialists at (860) 342-4382 to assist you in your Bloodborne Pathogen program.

Looking for a Speaker for your next safety meeting or management meeting?

NETC offers compelling and knowledgeable speakers who are experts in their fields.  You’ll get a dynamic and educational presentation, and your group will benefit from

the unique perspectives, experiences and insights of our experts.    For more information, give us a call.

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NETC is available to assist with implementing the NEW Respiratory Protection Standard for medical clearances, fit testing or in-servicing of employees.

Any questions or concerns potential airborne exposures to chemicals, NETC can assist you in evaluating your processes for potential employee exposures.

Don’t forget also that NETC is a fully accredited National Safety Council - First Aid Institute Training Facility.  We also provide complete regulatory compliance and training for facility Defibrillation programs.  We can offer courses for your employees either at your facility or at ours.  Give us a call for additional details.

New England Training & Consulting also provides workshops on many Human Resources related topics as well as Workplace Violence.  If you would like a workshop for your facility, or would like to have a security assessment and workplace violence policy / procedure developed, call any one of our Safety Specialists.

You can find all of our capabilities on our Website.

On January 13th and 14th NETC will once again hold its annual 10 hour OSHA Compliance Certification Course.  Sponsored by the Middlesex County Chamber of Commerce, you can register by calling them at 347-6924 and ask for Johanna Bond.

Tentatively scheduled for February 9, 10, 11, 12 & 13th, NETC will be providing an EMT refresher course in Portland at the Portland Fire Department.  For further information and registration, give NETC a call.

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Both Bob & Robyn recently completed a week long safety certification course in Seattle, Washington.  From which, both are now certified as Registered Safety Officers at the Master Level, and Robyn also received certification as a Registered Environ- mental Officer at the Master Level.  Both of their certifications are from the International Board of Environmental Health & Safety in Seattle.  We have also learned that Bob & Robyn are the only two registered Safety Professionals in CT.   NETC is now working on becoming one of only 10 registered training facilities to be established throughout the US.