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Environmental Health and Safety Professionals are often faced with questions that do not seem to have black and white answers, but, in reality, regulatory requirements are not that gray. A common question: When do the requirements for 29 CFR 1910.120 and 29 CFR 1926.65 (OSHA’s Hazardous Waste Operations and Emergency Response regulations) apply? The challenge for EHS professionals is to communicate to workers the distinction between what are considered environmental health risks During a recent visit to a construction project, I came across a very common and unsettling problem, improper roadway protection and inappropriate high visibility clothing. A worker wearing an open-weave reflective vest (over a blue t-shirt) was working inside an active temporary traffic work zone; he was removing concrete curbing using a jackhammer with his back turned to oncoming traffic, and the work area lacked roadway protection. More often than not, construction workers and supervisors Both OSHA and the EPA seemed to have recently awoken from their regulatory slumber. OSHA has announced its first major rulemaking during the Obama administration with a proposed change to the agency’s Hazard Communication (HazCom) Standard. The existing OSHA HazCom Standard provides workers with the right to know the hazards and identities of the chemicals they are exposed to while working, as well as the measures they can take to protect themselves. This standard was originally 1. Is the material hazardous? This can be determined by looking at the Material Safety Data Sheet (MSDS) or the label. 2. Does the Department of Transportation consider the material a hazardous material for transportation? Check the Hazardous Material Table (HMT) found in 49 CFR 172.101. 3. Is the material listed by name in the HMT? If so, that would be the proper shipping name. 4. Is the material not listed by name in the HMT but is a |
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