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TSCA questions are pouring in and we are responding. To ensure that the information is available in a reasonable (and non-overwhelming) way, Emilcott has created a TSCA resource section of our web site for centralizing all kinds of intelligence, notifications, links, and summaries about Toxic Substance Control Act (TSCA) 2012 Chemical Data Reporting (CDR). Read below and click on the links to learn more. If you are a foreign or domestic business in the US who is either a chemical importer (resells for use in blending, repackaging) or chemical manufacturer (make new chemicals out of chemicals purchased from others with the exception for pharmaceutical companies) or a chemical exporter, this update is about mandatory compliance with the EPA’s Toxic Substances Control Act (TSCA), specifically filing the 2012 TSCA Form U “Chemical Data Report”. Emilcott’s “take aways” regarding the EPA’s Sept 23 webinar about the 2012 CDR reporting requirements and the use of the electronic Form U reporting tool (“e-CDRweb”) are included in this blog entry. When providing guidance on the selection and use of PPE, it is critical for occupational safety and health experts to understand not only the technical issues surrounding the use of PPE as an exposure control method, but also the regulatory compliance burden placed on the employer. I recognize that “just” complying with OSHA standards is not equivalent to meeting industry best practices, but is important to understand the what might be considered the ‘back-bone’ of PPE programs in the US. This blog lists who buys what and which standards the required PPE is to meet. We just had our first cold weather snap in the northeast reminding me that 2012 is just around the corner. A change in the seasons is our cue to ask Emilcott clients that manufacture or import chemicals: Have you gathered the 2010 chemical volume data AND are you collecting the 2011 data needed for the 2012 TSCA Chemical Data Report? by Paula Kaufmann Upcoming TSCA Reporting Period: February 1 – June 30, 2012. As of August 6, the EPA has finalized the TSCA IUR — now named the Chemical Data Reporting (CDR) – Rule. There are many changes with the TSCA IUR to CDR … some of these will be in place for the 2012 reporting submission and many more for the 2016 submission. Read more for a complete update. As we approach the tenth anniversary of the 9/11 attacks, DHS (the Department of Homeland Security) is increasing their focus on utilities and chemical facilities which may become targets for terrorist activities. In a recent ABC news release DHS Press Secretary Matt Chandler is quoted as saying “While DHS has no specific, credible intelligence of an imminent threat posed to the private sector utilities, several recent incidents highlight the on-going threat to infrastructure in the utility sectors from insiders and outsiders seeking facility-specific information that might be exploited in an attack.” Have you ever driven by a crew constructing a new house or installing a new roof? Have you noticed a guardrail system in place to keep workers from falling when working on the upper levels? Or have you seen a personal fall arrest systemsthat will lock and hold a falling worker like a seatbelt in your car? Most likely you have not seen either of these fall protection systems in place for residential projects! Nearly one residential construction worker dies each workday as a result of falls. OSHA believes that no job is worth a life. For workers employed by a mid-sized contracting group or a small crew engaged in house painting or outside repairs, OSHA has published a new directive which mandates the use of fall protection for all residential construction workers at heights of 6 feet off of the ground. The Occupational Safety and Health Administration’s (OSHA) Fall Protection Policy for Residential Construction went into effect on June 16, 2011. Do you have hazardous chemicals in your workplace? If you think the answer is no, are you sure? Let’s start with a definition! OSHA defines a hazardous chemical as one that presents either a physical or a health hazard. Many common and readily available products such as paints, cleaners, and other materials found in the workplace meet this definition. In fact, last year OSHA issued over 6,300 violations to companies that failed to comply with this standard. Learn more about your Right-to-Know! Slips, trips, and falls aren’t at the top of anyone’s “most glamorous” EHS topics list. Many people perceive slips, trips, and falls as minor incidents resulting solely from either carelessness or clumsiness. Quite the opposite — slips, trips, and falls are a very costly and serious worker safety issue. In 2008, these incidents cost American businesses a staggering $13.67 billion in direct workers compensation costs. That’s more than any other cause and more than the combined cost of the third through sixth ranked causes. |
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