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The Importance of a Quality Fit Testing Program

One of the simplest things managers can do to prepare employees to succeed in a hazardous environment is to provide access to the proper personal protective equipment.   The right equipment is important, and knowing how to put on that equipment is critical for the health and safety of the staff.

A good fit testing program follows OSHA standard and guidelines. Due to the fact that fit testing can be life saving, there are strict rules in place that should be followed when teaching the proper “donning and doffing” technique. Here are some questions we thought might help you prepare your staff for this critical training.

What exactly is “fit testing”?

Fit Testing is the test of the actual skin to mask fit to make sure no particles or contaminants are getting through your respirator. The goal is to make it air tight so you are breathing clean air.

 

Is it a one time test?

No. Individuals need to be tested annually. Interestingly, facial features are constantly changing. Therefore, the mask that fit you a year ago might not be the right fit this year. This is why when fit testing occurs, you are not allowed to have any facial hair. Other features like scars, plastic surgery, dentures, and certain oral surgeries are reasons to fit test again.

 

How does the process work?

There are seven steps when it comes to fit testing, each of which take about seven minutes to do. There is a sensitivity test, exercises, and the rainbow passage you must read after every yearly test. The rainbow passage is a passage used by OSHA that goes through all the movements and motions of your mouth. It is essentially a speech pathology passage. Exercises include jogging in place, bending over and moving your head side to side and up and down.

 

How do I choose a fit test company?

Fit Testing, while simple, is not something that should be shortchanged. Whomever is providing the testing protocol should plan on spending at least 15-30 minutes per person.  They should also provide proof that they follow the steps outlined in OSHA guidelines.  Having fit testers that also use equipment themselves is also good practice since they have personal experience using this equipment.

 

Are there different types of Fit Tests?

Yes. There are two types of fit tests: quantitative and qualitative. Qualitative fit testing relies on your sense of taste and smell. Qualitative tests do not measure the amount of the irritant sprayed, it only tests whether or not your mask is protecting you from leakage. Quantitative tests are normally used for half-mask respirators. They only cover your nose and mouth. During this test, a machine is used to measure the amount, if any, of leakage into the mask.

 

What if my staff is too busy to leave our location to receive their fit testing?

Emilcott can arrange to come onsite to fit test for larger numbers of employees. We even have a bus that can provide fit testing to employees in the field.

 

How do I sign up?

You can call and make an appointment with us at 973-538-1110 or contact us on our website with a question.


6 Indoor Air Quality Tips for Buildings at Risk of Having Poor Air Quality

Are your building occupants complaining of symptoms like itchy eyes, coughs, allergies and headaches? Have you noticed a persistent and unusual odor in your building lately? You’d be surprised at how common it is to have poor indoor air quality—and how often it is caused by a distinct source with an easy fix. In our 30 years of air quality testing, we’ve seen all kinds of problems due to poor air handling maintenance: from HVAC filters that haven’t been changed in years to pigeons roosting near the air intake and leaving feathers and droppings to forgotten insulation and trash inside the AHU after a contracting job. These problems are not unusual, and they’re not going away.

 

Air quality concerns and problems aren’t going away either. In fact, they seem to be on the rise, especially with growing reports of poor outdoor air quality across the globe.

 

To mitigate these growing concerns, we’ve compiled 6 important air quality tips that we recommend all property managers consider when building issues arise:

 

#1: Confirm adequate ventilation and air flow. When evaluating operations and activities in the building, are functions and spaces properly located and ventilated? For example, printers can often give off fire particulates and kitchenettes and bathroom exhausts can create unpleasant odors. Making sure adequate ventilation and air flow are present relative to the purpose of the space can go a long way toward staving off complaints.

 

#2: Revisit your building’s cleaning services. Are building cleaning schedules adequate? How frequently are you preventing dirt from entering the building at the doors and windows? Does the housekeeping schedule provide adequate removal of dust and particulates? Do they vacuum the carpets and dust the shelves with regularity? Simple spot checks on these services can often provide clues as to the efficacy of cleaning services.

 

#3: Create a water intrusion policy. Do you have a formal policy or procedure for responding to water intrusion? Timely and appropriate response (within 24-48 hours) can eliminate the potential for mold. Be specific in your plan and consider differences in policies, procedures and timing regarding the source of the water intrusion (e.g., rainwater vs. toilet backup.)

 

#4: Develop a procedure for complaints. Do you have a standard operating procedure for responding to complaints? When a complaint occurs from a building occupant or a visitor, do you have a standard operating procedure for investigating and responding to the complaint? Often when complaints are ignored, there can be the perception that building air quality has worsened because no one is actively managing it…so make sure that you are proactively managing it!

 

#5: Maintain your HVAC filters. Have the HVAC filters been regularly and properly maintained? Filters must be changed on an appropriate schedule. We have found that even filters that have been changed quarterly create the potential for dust-related allergies and/or bacterial and fungal growth, which can aggressively impact building occupants. And remember – not all filters are the same so it is important you use filters that are of good quality.

 

#6: Visit the air handler. When was the last time you visited the air handler? Beyond filters, consider checking that water and dust are not accumulating inside the air handler. The entire AHU from outdoor air intake to discharge into the building, supply ducts, and return ducts all warrant inspection to identify problems.

 

So what do you do if you find you have a more serious air quality problem? Indoor air quality should always be evaluated relative to outdoor air quality. If outdoor air quality is good, increasing ventilations may be sufficient. However, when outdoor air quality is an issue, active management of air inside the building envelope is critical.

 

In an age where air quality in increasingly challenging to manage, proactive measurement and maintenance of indoor air quality – as suggested in our 6 tips above – can be critical to maintaining employee health and wellness.


EPA Implements New Rules for Hazardous Waste Generators

EPA Implements New Rules for Hazardous Waste Generators

New Jersey and Pennsylvania have adopted the EPA’s Hazardous Waste Generator Improvements Rule. This revised rule for hazardous waste generators became effective May 30, 2017 for states that do not have an EPA authorized RCRA program (Iowa and Alaska) and for states (such as New Jersey and Pennsylvania) that have adopted the rule by reference.

  • Other Authorized States run the RCRA program in their state and, thus, will go through the state adoption & authorization process for this new RCRA rule. Authorized states will have to pick up the more stringent provisions, typically by July 1, 2018 (or July 1, 2019 if state law change is needed).

What Does This Mean to Your Site’s Operations?

  • The new rule allows for Very Small (formally “Conditionally Exempt Small”) and Small Quantity Generators (SQG) to have an episodic increase in hazardous waste production without resulting in a change in hazardous waste generator status. There are notification, marking, labeling, storage, and recordkeeping requirements associated with this provision.
  • Additional notification requirements are in effect for Small and Large Quantity Generators.
  • In addition to determining the type of waste that has been generated, hazardous waste generators will have to determine the physical and health hazards of the waste. Hazardous waste container marking requirements include identifying the physical and health hazards of the waste.

Key changes to the Hazardous Waste Generators requirements:

  • Reorganization of the regulatory requirements placing all of the generator requirements in 40 CFR Part 262. The regulation has been reorganized, and the rules are easier to find.
  • New for Small Quantity Generators
    • Conditionally Exempt Small Quantity Generator (CESQG) will now be designated as a Very Small Quantity Generator (VSQG).
    • Creation of the “episodic event” provision which allows SQG and VSQG to generate a volume of waste (that would have previously moved them to a higher-level generator category) with certain limitations. The generator category would not change as a result of an “episodic event”. Note: An increase in production resulting in an increase of waste generation does not qualify as an “episodic event”.
    • VSQG under the ownership of a Large Quantity Generator (LQG) may transport their waste to the LQG for disposal. Note – there are DOT requirements and NJDEP hazardous waste transporter requirements which are not considered as part of this ruling.
    • New rules require SQG’s to submit a notification to the EPA every 4 years beginning in 2021. The notification serves as verification that the SQG is still in operation.
  • New for Large Quantity Generators
    • LQG’s need to notify the EPA or their authorized state if the facility is closing.
    • LQG’s must create and submit a Contingency Plan quick reference guide for emergency responders. The content requirements are found in 40 CFR 260.262. Note: LQG’s with existing Contingency Plans do not need to create a quick reference guide until the next Contingency Plan revision.
  • Hazardous waste container markings requirements now include identification of the hazards of the contents (this can be accomplished with GHS markings and/or DOT markings) in addition to marking as “Hazardous Waste”.

Clarifications to the Hazardous Waste Generators requirements:

  • 3-day rule for moving waste in Satellite Accumulation Areas to a Central Accumulation Area has been clarified to mean 3 calendar days.
  • New rules clarify that a hazardous waste generator can only have one generator category per month. If an activity makes a generator a LQG at a given moment, they are a LQG for the entire month.
  • New rules clarify that solid and hazardous waste determinations must be made at the point of generation before any dilution, mixing, or other alteration of the waste occurs.
  • Storage areas for hazardous waste that do not meet the definition of satellite accumulation areas are called “central accumulation areas” (CAA). The new rules clarify that there can be more than on CAA and that “central” does not mean that it is in the center of the facility.
  • New rules clarify that SQGs and LQGs must identify the RCRA waste code(s) associated with their waste. Hazardous waste determination has always been a requirement for generators; however, many relied on disposal vendor to identify the waste code. The new rules clarify that this is a requirement of the hazardous waste generator.

HOW CAN EMILCOTT HELP?

Emilcott can assist with getting your operation aligned with the Hazardous Waste Generator Improvements Final Rule. Every day Emilcott’s experienced professionals help hazardous waste generators understand the new requirements, and how the rule affects their operations. This is your opportunity to learn more about what you can do to comply with the new rule.

Emilcott can provide a broad range of technical support related to RCRA Compliance:

  • Training: Client-needs specific training for site-wide RCRA Awareness for waste generators and shipment manifest signers.
  • Program Development: Update site programs and implementation methods to reflect new requirements.
  • Prepare RCRA Regulatory Submissions: Biennial Reports, Notifications, and Status Updates
  • Gap Assessments: Identify potential gaps in compliance related to program implementation or operational changes.

Please give us a call – we can help you meet your goals!


Mid-year Regulatory Submissions Reminder

Just as we all take a deep breath after getting the CRTK submissions on March 1 — now it is time to get started gathering the information for the next round of submissions.  We’ve pulled together our Spring and Summer submission list.  Similar to our 1Q2017 Regulatory Submission Reminder , we detail information about the regulations that require submissions from mid-April through July 2017 along with specific dates to help you ensure that everything is submitted on time! 

For more information and for a more comprehensive outline of each submission and what is required, including links to government pages, download our FREE ebook “ Spring/Summer Regulatory Submissions Reminder”.

Please feel free to call us at 973-538-1110 to speak to an EHS Consultant regarding any further questions you may have or for help with your regulatory submissions or safety compliance. 


UPDATED: When Dust Is Not Just Dust: New silica guidelines you need to know now

* UPDATE: The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has now delayed enforcement of this new standard to begin on September 23, 2017 as opposed to the original date of June 23, 2017.  

Silica is the second most common mineral in the crust of the earth.  Silica can be found in materials like sand, concrete, brick, block, stone and mortar. Overexposure to dust that contains crystalline silica can cause scar tissue to form in the lungs, which reduces the lungs ability to function. The resulting disease is called Silicosis.  It is an incurable lung disease that sometimes causes bronchitis and puts victims at increased risk of tuberculosis, and may lead to lung cancer.

All this disease, from breathing in dust that is not just dust.

The hazards of breathing crystalline silica have been known by stone cutters and quarrymen for eons. In the 1700’s Bernardino Ramazzini (considered the father of occupational medicine) wrote about stone cutter “maladies” of cough, asthmatic afflictions, and consumption resulting from breathing in rough, sharp and jagged splinters of stone. 

In 1938, the US Secretary of Labor started the “Stop Silicosis” campaign after hundreds of workers died from silicosis while working on construction of the Gauley Bridge tunnel. 

In the 1990’s, the Department of Labor recognized that worker exposure to crystalline silica still caused a significant health hazard and once again rolled out a campaign to raise awareness and highlight safe work practices “It’s Just Not Dust”.  The source of exposure to airborne crystalline silica today is not predominately in tunnel construction, it occurs with the increased use of dry cutting, drilling and grinding of concrete and masonry material in construction along with the popularity of stone surfaces in residential and commercial buildings.

In 2016 OSHA published a detailed new standard for OSHA’s new standard for Crystalline Silica. And now compliance dates are approaching with June 23, 2017 for the Construction Industry and most of General Industry scheduled for June 23, 2018.

How are you set for June 23, 2017 compliance with the Construction Industry requirements your business must follow in order to protect your employees against the effects of crystalline silica.

Here are six questions to ask:

  1. Are your site work protocols and equipment aligned with the new “Safe Methods for Working with Silica” issued by OSHA?
  2. Are you confident any recently performed a worker exposure to crystalline silica measurements reflect the new exposure control methods issued by OSHA in regulation §1926.1153 Respirable crystalline silica.
  3. Do you have a respirator program for your employees wearing respirators (even dust masks?)
  4. Have your employees wearing respirators been medically cleared to wear these respirators?
  5. Are your employees receiving training about the dangers of crystalline silica?
  6. Do you have records of your training?

If you answered no to any of these question and your employees are potentially exposed to crystalline silica, you may not be in compliance the latest OSHA standards.  Contact Emilcott today or check out our full compliance checklist.  We offer comprehensive solutions to:

  • Write programs customized to your business that comply with the OSHA standard
  • Provide training on using the methods recommended by OSHA in specified exposure control methods
  • Help you meet the requirements on communicating the hazards of silica to be in compliance with OSHA hazard communication regulations
  • Train your employees at their work site on your schedule
  • Provide on site exposure assessments for silica.

Checking the list… Annual Regulatory Reporting Checklist

2016 has been full of surprises but it is never good to be surprised when it comes to annual regulatory reporting! There are many things that we can do to minimize surprises and last minute scrambling.  The time to start the process is in the beginning of January 2017.

First – identify the regulatory submissions required for your organization and the deadlines for filing. These include submissions of the EPA Community Right to Know (CRTK) Survey and the Hazardous Waste Biennial Report (or Annual for some states) which are due March 1st. Also on the horizon are the EPA Toxics Release Inventory (TRI) and the New Jersey Release and Pollution Prevention Report (RPPR) both due July 1st.

The compilation and reporting process is less stressful and yields better results if it is started early and a strategy is developed with deadlines in mind.  Waiting until the last minute not only increases the potential for making mistakes, it is sometimes hard to get the submission through due to high volume of users on the same electronic filing system.

Here is my personal January 1st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle….

Download the checklist e-book here!

1)      Start requesting and gathering all the information needed for these submittals.

  1. 2016 purchasing records of the chemicals you are reporting
  2. 2016 production logs where these chemicals are used
  3. 2016 waste information
  4. 2016 recycling information for any reported chemicals that were recycled
  5. 2016 air emission inventory

2)      Develop and write down a comprehensive set of due dates so that you have time to review information as it comes in. If the requested data is late, have a plan to follow up or find another source because the deadline is not going to change!

3)      Review the rules early to avoid unpleasant surprises.

4)      Allow time for anomalies and additional fact-finding. Reported amounts from different sources may not match. If you find that is the case, it is your job to figure out why and that always adds more time to the already challenging process.

Emilcott’s clients depend on our environmental knowledge and organizational capabilities to gather the required information on time and give them fair warning if there is trouble ahead.  My best advice for successful reporting-don’t wait until the last minute.  Much like filing your income taxes on April 15th, waiting until February to gather the information for the CRTK or starting in June for the TRI will be stressful and could result in costly errors. So, what am I doing today?  Like Santa, I’m checking my own list twice!

Have you been meeting the CRTK and TRI deadline? If yes, can you offer additional advice or do you have particular steps that you take to get the submission process rolling?


Does Your Facility Need to File an Annual Community Right to Know Survey?

Community Right to Know (CRTK) Surveys must be completed and submitted by March 1 of each year by all industries with a listed NAICS code. A listing of applicable NAICS codes can be found at the following url: http://www.nj.gov/dep/enforcement/opppc/rtknaics.pdf.

The New Jersey Department of Environmental Protection (NJDEP) is initiating an enforcement effort against all entities that have not filed their 2015 CRTK Survey and did not receive an exemption from filing. If your company has not filed a CRTK Survey for 2015 and has not received an exemption, the NJDEP is encouraging entities to file. Filing before being forced to do so by the NJDEP may reduce the risk of a monetary fine.

If you are unsure whether you should file a survey or file for an exemption, here are the basics:

Requirements for Filing a CRTK Survey

1. Your facility is in a regulated NAICS Code

2. Your facility stored reportable quantities of regulated substances as listed in:

http://www.nj.gov/dep/enforcement/opppc/crtk/ehsalpha.pdf and

http://www.nj.gov/dep/enforcement/opppc/crtk/ehscasno.pdf

For an Exemption:

You must submit a CRTK Reporting Exemption Form which you can find at: http://www.nj.gov/dep/opppc/crtk/crtkrptexemptfm.html , if your facility meets one of the following criteria:

1. Your facility is in a regulated NAICS Code however NO environmental hazardous substances (as

listed in:) were present in 2015

2. Listed substances were present but below the applicable reporting thresholds;

3. Your facility is in a regulated NAICS Code and you meet the definition of an unstaffed site

(“Unstaffed site” means a remotely operated site, not contiguous to any other staffed sites and at which no full-time or part-time employees are assigned at any time except for maintenance or emergency repair – N.J.A.C. 7:1G1.2 (h)); or

4. If you determine that your facilities are in a regulated NAICS Code and ALL FACILITIES YOU OWN IN NJ conduct administrative office functions only.

Emilcott professionals are here to help if you determine that your facility needs to file a 2015 CRTK Survey or file for an exemption. Emilcott can also act as a liaison between your organization and the New Jersey Department of Environmental Protection.


OSHA Fine Increase

OSHA fines have remained the same since 1990 and are increasing now due to congressional legislation that required all federal agencies to raise penalties based on inflation.

OSHA Fines will increase 78% from previous levels.

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State OSHA plans are also required to adopt the new maximum penalty levels.

The new penalties will take effect after August 1, 2016.

Any citations issued by OSHA from now on will be subject to the new penalties if the related violations occurred after November 2, 2015. Meaning if the inspection occurred after 11/2/15 and the citations were not issued until after 8/1/16, the new fines apply.

Annual increases for inflation will now be required and posted by January 15 of that year.

OSHA will continue to work with small businesses to provide reductions based on employer size and other factors.


OSHA New Injury/Illness Reporting Requirements

On May 12, 2016 the New OSHA Recordkeeping Rule was finalized and it will become effective January 1, 2017.

Electronic Data Submission

Some employers will be required to submit annual recordable injuries/illnesses reports electronically and this data will be available to the public. This is intended to:

 Encourage employers to reduce accidents

 Provide improved data to researchers to innovate safety solutions

 Allow the public, prospective employees, customers, competitors, and investors to assess the company’s safety record

Employers with 250 or more employees, who are required by OSHA to maintain work related injury/illness data, will be required to submit information from the OSHA 300 Log, 300A Summary, and 301 Form (First Report of Injury). A phased in approach allows that only the 300A Summary data needs to be submitted in 2017 for the 2016 data. In subsequent years, data from all three documents will be required.

Employers with 20-249 employees in designated high injury rate industries will be required to submit information from a 300A Summary. A list of the designated high injury rate industries is attached.

Submission deadline for 2016 OSHA 300A Summaries from both types of employers is 7/1/2017.

Submission deadline for 2017 data, from both types of employers, is 7/1/2018. Subsequent year’s submission deadlines will be March 2 of the following year.

OSHA will remove all personally identifiable information prior to posting the data on its website.

Employers that are exempted from the recordkeeping requirements, have less than 20 employees or are conditionally exempted based on NAICS code, are not required to report electronically.

Non-Retaliation, Informing Employees and Drug Testing Policies

The final rule also includes provisions to encourage worker reporting of injuries/illnesses and prohibits employers from retaliating against these employees.

 Employers must inform employees of their right to report workplace injuries/illnesses by posting or other means

 The procedure for reporting must not discourage employees from reporting

 Employers may not retaliate or penalize employees who report injuries/illnesses

The rule may require changes to post incident drug testing policies. The employer must be able to establish that the purpose of the test was not retaliation as would be the case if such testing were required by a law (ie. DOT). However, if not required by law, employers will need to show appropriate motive for testing.

OSHA New Injury/Illness Reporting Requirements


EPA Updates the Community Right to Know Survey to Align with GHS Hazard Communication Standard

 

The Environmental Protection Agency (EPA) has revised the reporting requirements of the Community Right to Know Survey (CRTK) to align with the terminology and chemical hazard categories of the Globally Harmonized System (GHS) Hazard Communication Standard (Hazcom). The final rule was released in the June 13, 2016 Federal Register: https://www.gpo.gov/fdsys/pkg/FR-2016- 06-13/pdf/2016-13582.pdf. Companies required to complete the annual CRTK Survey (also known as Tier II)will see some changes to the reporting forms as a result of the new rule.

What will change?

1. GHS has replaced “Material Safety Data Sheet (MSDS)” with the term “Safety Data Sheet (SDS)”.

Instructions and reporting forms for the CRTK Survey will use both terms and their acronyms.

2. Changes to the “Hazard Category” section in Part 2 of the CRTK Survey.

Since its implementation in 1987, the CRTK Survey form has had five (5) hazard category

options. These categories included fire, sudden release of pressure, reactive, acute health

hazard, and chronic health hazard.

The new rule replaces the 5 hazard categories with two (2) hazard categories. The newly defined

hazard categories include:

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The June 13, 2016 final rule had inadvertently omitted the hazard ‘‘serious eye damage or eye irritation’’under the definition of ‘‘health hazard’’. Therefore, EPA released a correction in the July 21, 2016 Federal Register: https://www.gpo.gov/fdsys/pkg/FR-2016- 07-21/pdf/2016- 17277.pdf adding “serious eye damage or eye irritation” to the definition of “health hazard”.


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