What EHS Pros Should Know for Summer 2016

Posted on 5/31/2016 by James Griffin

Summer 2016 will bring major changes for hazmat shippers, hazardous waste professionals, and safety managers nationwide. Below is a quick snapshot of some major compliance updates, deadlines, and new rulemakings to be aware of now that beach season is officially underway!

The Last OSHA GHS HazCom Deadline Is Tomorrow!

In 2012, OSHA amended its Hazard Communication Standard to match the Globally Harmonized System of Chemical Classification & Labeling, or GHS. Also known as HazCom 2012, the implementation of GHS standards for classifying hazardous chemicals, creating Safety Data Sheets, labeling shipments and workplace containers, and training employees has been ongoing for four years.

Tomorrow, June 1, 2016, is the last deadline for HazCom 2012. By tomorrow, June 1, employers must “update alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards.” In other words: If any of the chemicals in your workplace meet the post-2012 definition of a hazardous chemical—but were not considered hazardous before GHS—you must make sure you have SDSs on file for these chemicals, that the containers are properly labeled in line with new GHS hazcom criteria, and that your employees know about the chemicals’ hazards and how to handle the chemicals safely.

For chemicals that are not newly regulated, you’ve likely received new, 16-section Safety Data Sheets. If you haven’t, call your suppliers to make sure the new SDSs are on the way. For the June 1 deadline, make sure all your SDSs are logged into your HazCom plan and available to your employees. Want to know more about GHS? Read Almost There: Final GHS Deadline—June 1.

Remember—temporary workers must be trained on GHS too. OSHA has provided guidance for staffing agencies and employers to clarify that both have responsibilities for keeping temp and contract workers safe from chemical hazards in the workplace.

How GHS Affects Your DOT Hazmat Shipments

New pictograms, classifications, and chemical labels are causing issues for hazmat shippers, carriers, and freight forwarders. Get a full picture of how GHS affects your site’s hazardous materials shipments, including how OSHA HazCom and DOT hazmat rules intersect and affect each other. Learn which labels to use, when, and on which packages to stay in compliance with both 49 CFR and 29 CFR rules.

TSCA Reports Start June 1, Too

Under the Toxic Substances Control Act (TSCA), with a few exceptions, US EPA requires establishments that manufacture and/or import large quantities (≥ 25,000 lbs.) of any chemical substance to periodically report on their activities.

The main goal of TSCA is to provide US EPA with a central set of data that covers all chemicals in the US and where they come from, so that if a chemical must be regulated for public safety, US EPA has information about which chemical manufacturers and importers will be affected and where to find large quantities of the chemical. Reports must be submitted between June 1 and September 30 and must describe the types and amounts of chemicals manufactured or imported in the previous four years, with extra detail on the previous years’ activity.

In the past, EHS professionals submitted the TSCA CDR report on Form U. Since 2012, though, TSCA reports MUST be made online. More information about electronic TSCA reporting is available from US EPA here.

Get ready to report! The TSCA Regulations Online Course will prepare you for compliance with TSCA chemical reporting and management rules—including Form U reporting, import certifications, managing PCBs, and much more.

EPCRA Toxic Release Inventory (TRI) Due July 1

The TSCA Form U report isn’t the only information US EPA requires from chemical manufacturers and importers. US EPA also requires you to report an inventory of all the toxic chemicals your facility released during the past year. In this context, a “release” could mean authorized air emissions, water discharges, waste treatment and disposal, and/or accidental or inadvertent releases to the environment.

Like TSCA reports, EPCRA reporting has gone digital. Since 2014, you must file your Toxic Release Inventory (TRI) or Form R online. More information on online EPCRA reporting from US EPA here. TRI reports are due on or before July 1 of each year, cataloging releases made during the previous calendar year.

To help EHS pros maintain compliance with major US EPA programs like EPCRA, TSCA, the Clean Air Act, Clean Water Act, SDWA, CERCLA/Superfund, and more, Lion will present the Complete Environmental Regulations Workshop in Cincinnati on June 6 and Pittsburgh on June 9.

Hazmat Registrations Due June 30!

Every June 30, PHMSA requires businesses that ship or transport high-consequence loads of hazmat to register and pay a fee. A high-consequence load of hazmat is a shipment of hazmat that requires placards or is otherwise described at 49 CFR 107, Subpart G.

Hazmat registrations are US DOT’s way of collecting statistics on commercial hazmat shipments nationwide: how many people ship hazmat, how much is being shipped, what kinds are being shipped, and how far and how often. The fees go to a fund that pays for equipment and training for local emergency responders to prepare for hazmat incidents.

Tags: GHS, hazard communication, hazmat registration

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