EHS Updates

July 13, 2015: Definition of Solid Waste

The U.S. Environmental Protection Agency (U.S. EPA) released its final rule amending the Resource Conservation & Recovery Act (RCRA) Subtitle C "Definition of Solid Waste." The final rule will go into effect July 13, 2015.

Under the final rule, U.S. EPA may bring a RCRA enforcement action against any recycler of hazardous secondary materials if the recycling activity does not meet all of the following four recycling legitimacy criteria:
1. A hazardous secondary material must make a useful contribution to a final product or intermediate
2. The recycling process must produce a valuable product or intermediate
3. The hazardous secondary material must be managed as a valuable commodity
4. The final product must be comparable to a legitimate product or intermediate with respect to hazardous characteristics and levels of hazardous constituents

June 1, 2015: Hazard Communications Standards Deadline

The Occupational Safety and Health Administration (OSHA) modified the Hazard Communication Standard (HCS). The purpose is to bring the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). While HCS, first promulgated in 1983, gave the workers the 'right to know,' the Agency publicizes that the new Globally Harmonized System gives workers the 'right to understand.'

The new HCS still requires chemical manufacturers and importers to evaluate the chemicals they produce or import, and provide hazard information to employers and workers by putting labels on containers and preparing Safety Data Sheets (SDS), previously called Material Safety Data Sheets (MSDSs). However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and MSDSs in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards, and specifies hazard communication elements for labeling and SDSs.

The following is a brief outline of the major changes to the HCS:

Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards, as well as classification of chemical mixtures.
Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
Safety Data Sheets (SDSs): The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
Information and training: To facilitate understanding of the system, the new standard requires that workers be trained by Dec. 1, 2013 on the new label elements and safety data sheet format, in addition to current training requirements.

Various provisions of the new standard have different effective dates. Compliance with modified provisions of the rule takes effect on June 1, 2015 for chemical manufacturers, importers, distributors and employers. Employers should continue to update their safety data sheets as new ones become available, provide training on the new label elements, and update hazard communication programs if new hazards are identified.

Companies producing SDSs to review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and SDSs according to the new specified format. Access OSHA's Website

Jan. 1, 2015: New OSHA Reporting Requirements

As of Jan. 1, 2015, there was a change to what covered employers are required to report to the Occupational Safety and Health Administration (OSHA). Employers are now required to report all work-related fatalities within eight hours and all in-patient hospitalizations, amputations, and losses of an eye within 24 hours of finding out about the incident.

Previously, employers were required to report all workplace fatalities and when three or more workers were hospitalized in the same incident. The updated reporting requirements have a life-saving purpose: they will enable employers and workers to prevent future injuries by identifying and eliminating the most serious workplace hazards.

Employers have three options for reporting these severe incidents to OSHA. They can call their nearest area office during normal business hours, call the 24-hour OSHA hotline at 800-321-OSHA (800-321-6742), or they will be able to report online. For more information and resources, visit OSHA's Web page on the updated reporting requirements.


RadTech Phone Number: (240) 497-1242

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