TECH FORUM 2012ENVIRONMENTAL, HEALTH & SAFETY REGULATORY UPDATE

ISSUES O

N THE E

PA A

ND OSHA H

ORIZON

Fall P

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Rev

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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