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TECH FORUM 2012ENVIRONMENTAL, HEALTH & SAFETY REGULATORY UPDATE
ISSUES O
N THE E
PA A
ND OSHA H
ORIZON
Fall P
rote
ctio
n, Sto
rm W
ater
, Gre
enhou
se G
asse
s, PM
2.5, D
efiniti
on o
f Sol
id W
aste
Rev
ised Fi
nal R
ule; A
dhesio
n Stu
dy Pr
esen
tatio
n
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 1
OSHAWalking Working Surface Standard to include Fall Protection
Provisions Personnel working Over 10 feet from the ground must meet fall
protection provisions. (This includes fixed and mobile working platforms)
Already covered are open sided floor openings, crow’s nests, working on rails, walls, vents/louvers, etc over 10 ft from floor
Harness, lanyard, and anchor point over the head or prevention of falls greater than 3 feet.
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 2
OSHA NATIONAL EMPHASIS PROGRAM
Workplaces with fatalities, and DART greater than 7.0 national average.
Crane operation, working under racked parts, material handling.
Have OSHA logs up to date (within the week) and review all existing programs (initial and date) for adequacy and audit consistent implementation on all levels. Make sure those not following protocol are disciplined in writing. This is a CYA for all. Employees should not be “at fault”, only supported.
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 3
HAZARD COMMUNICATION 1910.1200 HAS BEEN “GLOBALLY HARMONIZED”
Efective Completion Date
Requirement Who
Dec 2013 Train employees on new label and SDS format
Employers
June 2015 Comply with all provisionsNot ship after 12/1/2045
MFG, Importers, Distributors, employers
June 2016 Update workplace systems, labels and training
Employers
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 4
STORM WATER PROGRESSUSEPA is requiring SIP’s from states that include reduction in Combined Sewer Overflow events, upgraded and updated infrastructure, reduced pollutant loading.
1. reduce effluent, remove water from waste water discharge AND storm flow contributions to city infrastructure,
2. Reduce pollutant loading (concentrations and total mass),
3. Implement effective BMP’s and source reduction from NON POINT SOURCES in addition to the traditional point sources.
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 5
STORM WATER BMP’S• Containment around fueling stations
• Spill Kits located proximal to potential spill/leak locations
• >1320 gallons= SPCC plans
• Preventative Maintenance Program to avoid spills, drips or leaks
• Control garbage, debris and solids sources
• Good Housekeeping
• Raw materials contained, covered, transfer areas managed.
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 6
STORM WATER TECHNOLOGY IN USECapture Process Water for reuse
Divert zinc containing water to onsite containment for storage and reuse
Capture storm water for treatment prior to discharge Effective treatments
Source reduction Filtration and pH adjustment Chemical bonding Ion exchange
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 7
INDUSTRY PRACTICES• Collecting fines from process, separate from storm water
contact areas.
• Keep zinc particles under cover and minimize track out on shoes, tires and parts.
• Grind and brush and spray inside, near a dust collector
• Collect water from process areas in sumps for processing or re-addition
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 8
DATA COLLECTION REQUESTStorm water and process water data on the following metals Cadmium Chromium Nickel Copper Lead Zinc
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 9
AIR DISCHARGEGreenhouse Gas Emission Reporting
Most states require major sources to report carbon equivalent emissions
Minor sources will be added in by 2015Emission exchange programs are proposed in several states,
implemented in western climate statesPermit conditions will incorporate fugitive emissions for PM and
PM10 and PM2.5Steel Pickling MACT-Does not apply to HDGBoiler MACT is under a regulatory STAY, do not report this fall.
Keep data and calculations for when it goes back into effect.
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 10
SOLID & HAZARDOUS WASTEDefinition of Solid Waste Revision from 2008 has been re-written and
re-issued.Provisions include:Initial determination of the materialEnd use mattersDocument flow chart of decisionsDocument vendor use and quantities shippedAccount for materials the same as every other raw material and
product. (Beginning and ending inventory, storage rotation, storage inspections, QA samples etc)
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 11
DSW FLOW CHARTQ1: Is the material a waste
Q2: Will the material be discarded
Q3: Is the material inherently waste-like
Q4: Will the material be used in a manner consistent with waste disposal methods?
See flowchart in 40 CFR 261.4 Appendix A
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 12
AUDIT SURVIVALKeep all docs in one folder on your computer
Scan in every form, training roster, inspection record, checklist, and certification.
Complete Job hazard analysis, job description, procedure reviews, weekly walkthrough records, correct problems immediately
Train your workforce, observe and correct behavior, document
Octob
er 4
, 2012
AMERICAN GALVANIZERS ASSOCIATION 2012 13