A safe workplace is sound business
This article continues the introduction of OSHA’s Safety and Health Program which includes six recommended practices of which two will be highlighted in each of the first three quarterly SEI Newsletters of 2017. The six recommended practices are:
- Management Leadership
- Worker Participation
- Hazard Identification and Assessment
- Hazard Prevention and Control
- Education and Training
- Program Evaluation and Improvement
Management provides the leadership, vision, and resources needed to implement an effective safety and health program. Management leadership means that business owners, managers, and supervisors:
- Make worker safety and health a core organizational value.
- Are fully committed to eliminating hazards, protecting workers, and continuously improving workplace safety and health.
- Provide sufficient resources to implement and maintain the safety and health program.
- Visibly demonstrate and communicate their safety and health commitment to workers and others.
- Set an example through their own actions.
To be effective, any safety and health program needs the meaningful participation of workers and their representatives. Workers have much to gain from a successful program and the most to lose if the program fails. They also often know the most about potential hazards associated with their jobs. Successful programs tap into this knowledge base.
Worker participation means that workers are involved in establishing, operating, evaluating, and improving the safety and health program.
In an effective safety and health program, all workers:
- Are encouraged to participate in the program and feel comfortable providing input and reporting safety or health concerns.
- Have access to information they need to participate effectively in the program.
- Have opportunities to participate in all phases of program design and implementation.
- Do not experience retaliation when they raise safety and health concerns; report injuries, illnesses, and hazards; participate in the program; or exercise safety and health rights.
For more information on creating a culture of safety at your workplace contact
GA EPD STORMWATER PERMIT for DISCHARGES ASSOCIATED with INDUSTRIAL ACTIVITY
As a reminder, the 2012 Stormwater Permit requires that a smoke or dye test be completed during the term of the permit which is scheduled to expire on MAY 31, 2017.
Call SEI for a proposal to complete this requirement.
2017 STORMWTER PERMIT for DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
The DRAFT 2017 replacement storm water permit is available on the GA EPD Website. We have summarized below some significant changes to the requirements contained in the permit:
- Notice of Intent: A new, revised NOI must be submitted within 30-days of the effective date of the new permit.
- Control Measures: There are requirements for implementing very specific Control Measures and for documenting the implementation and effectiveness of the Control Measures.
- Employee Training: Detailed requirements for employee training that include specific topics and training for specific types of employees.
- eReporting Requirements: All forms must be submitted electronically as well as a summary of analytical results.
- Quarterly Observation Sampling: There are more specific requirements for documenting this permit activity.
- Monitoring: Sector Specific Benchmark monitoring continues to be required and a new term, Impaired Waters Benchmarks are established and require monitoring.
TIER II REPORTS
By the time you read this articles, you should have received your 2016 Tier II Reports. Most states now accept some form of electronic reporting (E-Plan for most states) that technically meets the reporting deadline of March 1st. We do recommend that you contact your local fire departments and Local Emergency Planning Committee (LEPC) to see if they prefer a paper copy or a copy of the .pdf or .t2s file sent directly to them.
PESTICIDE PRODUCING AND REPACKAGING REPORTS
If applicable, these reports have been sent to you for review, signature, date, and submission as the US EPA requires an original signature of the person listed as Authorized Agent for your company. Like Tier II Reports, these are also due March 1st of each year. Significant changes in reporting are being implemented for Calendar Year 2017 reporting. All submissions of this report must be done electronically via the Central Data Exchange (CDX). We will be contacting you in the near future to provide assistance in establishing an account for your company.
ELECTRONIC LOGGING DEVICES (ELD)
The final rule became a reality December 16, 2015. The rule will take full effect on December 18, 2017, two years after the date of the final rule being issued. ELDs automatically record driving time and monitor engine hours, vehicle movement, miles driven, and location information.
The electronic logging device (ELD) rule is intended to help create a safer work environment for drivers, and make it easier, faster to accurately track, manage, and share records of duty status data. An ELD synchronizes with a vehicle engine to automatically record driving time, for easier, more accurate hours of service recording. The rule applies to most carriers and drivers who are required to maintain records of duty status. All FMCSA-registered and certified ELDs will be listed on FMCSA’s website: www.fmcsa.dot.gov/devices.
The ELD Rule:
· Specifies who is covered by the rule and exceptions to it.
· Provides for ELDS to be certified, registered, and listed on a FMCSA website.
· Includes technical specifications to ensure ELDs are standardized and compliant.
· Includes a phased implementation timeline to give drivers and carriers time to comply.
· Includes provisions to help prevent data tampering and harassment of drivers.
· Creates standard data displays and data transfer processes, making it easier to demonstrate compliance and faster to share records of duty status with safety officials.
ELD Rule Impacts
· Carriers and Drivers who are subject to the rule must install and use ELDs by the appropriate deadline:
· Carriers and drivers who are using paper logs or logging software must transition to ELDs no later than December 18, 2017.
· Carriers already requiring drivers to use automatic on-board recording devices (AOBRDs) according to the specifications in Section 395.15 may continue to use the AOBRD until December 16, 2019.
DOT HAZMAT EMPLOYEE TRAINING
DOT HAZMAT Employee Training is required once every three-years for all employees associated with the shipment of HAZMATs including those that prepare the shipping documents, load/unload vehicles, drivers, and those that supervise the above employees. Training requirements include:
- DOT Security Training
- DOT HAZMAT Basic Training
- DOT Emergency Response
- Function Specific Training such as Forklift Operator Training, Chemical Handling, etc.
- HAZMAT Training for Drivers
For more information give us a call at 229-924-9390
FIRST AID / CPR / AED / BBP Training
The OSHA First Aid standard (29 CFR 1910.151) requires trained first-aid providers at all workplaces of any size if there is no “infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees.” OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace. This interpretation generally has been upheld by the Occupational Safety and Health Review Commission, an independent tribunal that decides OSHA cases, and by federal courts.
We are now offering the National Safety Council (NSC) First Aid/CPR/AED/BBP Training Course with two NSC certified trainers, Greg Turner and Rick Cimino.
OSHA Industrial Hygiene Inspections
It is becoming more common for an OSHA Safety Inspection to be followed by an OSHA Industrial Hygiene Inspection due to potential noise or pollutant exposures. In association with Dave Comen, CIH, we provide a wide-range of Industrial Hygiene services including area monitoring and full exposure surveys. Contact Jim Smith for more information.
DOT DRIVER QUALIFICATION FILE MANAGEMENT – J.J. Keller
DOT requires that employers of commercial motor vehicle operators maintain a Driver Qualification File (DQF) for each driver. We are a multi-user licensee of J. J. Keller’s DQF Management Program. The system ensures that a complete and up-to-date file is maintained and available for each driver. Reminders are sent as items in each file need to be updated or renewed so that you never have to idle a driver. Contact Greg Turner for more information.
SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) PLANS
The SPCC Plan regulations continue to be updated and tightened. As the definition of “navigable waters” continues to be expanded more facilities are regulated. US EPA also continues to expand the list of regulated entities now including many small businesses and farms. If a facility has 1,320-gallons or more of “storage capacity” for petroleum products in containers of 55-gallons and larger, an SPCC Plan is required. The facility may self-certify a plan if the storage capacity is between 1,320 and 10,000-gallons. If the storage capacity is over 10,000-gallon the SPCC Plan must be reviewed and stamped by a Professional Engineer. We provide this service in association with Robert P. Stevens, P.E. Contact Jim Smith for more information.
JIM SMITH, GREG TURNER, ASP, RICK CIMINO, CSP and DAVID ORR
We provide a wide range of OSHA, EPA (Federal and State), and DOT compliance services.
Please give us a call the next time you have a regulatory compliance issue at 229-924-9390.
We appreciate your business!