Regulatory Updates
TRAINING REQUIREMENTS FOR THE REVISED HAZARD COMMUNICATION STANDARD [posted April 4, 2013]
The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. Once implemented, the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals. This update will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.
“Exposure to hazardous chemicals is one of the most serious threats facing American workers today,” said U.S. Secretary of Labor Hilda Solis. “Revising OSHA’s Hazard Communication standard will improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive.” OSHA’s website sums it up nicely with this quote “The standard that gave workers the right to know, now gives them the right to undertand.”
While the transition to OHSA’s new Hazard Communication Standard (HCS) happens in 2015, 5 million businesses face an employee training deadline that’s set for this year. By December 1st, 2013, 43 million employees must be trained on the new label elements and safety data sheet (SDS) format included in the HCS update. Until the new standard takes effect in 2015, companies can either use the old labeling and SDSs or the new versions, but all employees must be trained on the new version by the December 1st, 2013 deadline. According to OSHA, the training is needed early in the transition process because workers are already beginning to see the new label and SDSs on chemicals in their workplace. To ensure that workers have the information they need to better protect themselves from chemical hazards in the workplace, it is imperative that they understand the new label and SDS formats. To view a sample of the new SDS for Toluene, click here.
For more information about the December 1st, 2013 deadline and the training requirements, please refer to the OSHA FactSheet.
VERMICULITE
In light of many recent inquires regarding vermiculite insulation we decided to put together some information and resources to provide guidance to those of you who may have questions or concerns. Vermiculite has been causing quite a stir lately because many anxious homeowners are growing concerned about the possibility that their homes are insulated with vermiculite insulation.
According to the Environmental Protection Agency (EPA), vermiculite is a naturally occurring mineral composed of shiny flakes, resembling mica. It has been used in numerous products, including insulation for attic and walls. A mine near Libby, Montana was the source of over 70% of all vermiculite sold in the United States from 1919-1990. Unfortunately, there was a deposit of asbestos at that mine and Libby’s vermiculite was contaminated with asbestos. If you have vermiculite insulation in your home, you should assume that this material may be contaminated with asbestos and take the necessary precautions to protect you and your family from potential exposure. The most important thing to remember if you have vermiculite insulation in your home is not to disturb it. Asbestos fibers must be airborne to cause a health risk through inhalation, and disturbing vermiculite insulation can release asbestos fibers into the air.
The EPA recommends the following tips in order to help limit your potential exposure:
- Leave vermiculite insulation undisturbed in your attic or walls.
- Do not store boxes or other items in your attic if it contains vermiculite insulation.
- Do not allow children to play in an attic with vermiculite insulation.
- Do not attempt to remove the insulation yourself.
- Hire a professional asbestos contractor if you plan to remodel or conduct renovations that would disturb the vermiculite in your attic or walls to make sure the material is safely handled and/or removed.
To find out more about vermiculite insulation, please visit the EPA’s website by clicking here or you can find additional information about asbestos, in general, by clicking here. Providing this information is just another way that Hillmann Consulting, LLC strives to make “Your Property Our Priority.”
LICENSED SITE REMEDIATION PROFESSIONAL (LSRP)
On May 7, 2009, Governor Jon Corzine signed the Site Remediation Reform Act (SRRA) into law. This law provides vast changes to the way sites are remediated in New Jersey. It also amends other statutes such as the Brownfields and Contaminated Sites Act and the Spill Compensation and Control Act.
SRRA establishes a program for the licensing of Licensed Site Remediation Professionals (LSRPs) who will essentially act on behalf of the New Jersey Department of Environmental Protection (NJDEP) when providing oversight of environmental remediation and cleanup in the state. The law changes the way sites are remediated while ensuring that the same stringent clean-up standards remain intact. Under the new law, the day-to-day management of a remediation site will be overseen by qualified LSRPs but the NJDEP will retain significant authority over the remediation process.
So what does this mean for Hillmann Consulting, LLC clients?
Under SRRA, NJDEP approval is no longer needed prior to proceeding with remediation. However, an LSRP is required to conduct remediation of sites in New Jersey. Implementation of the SRRA results in contaminated sites being cleaned up more quickly. This, in turn, provides greater environmental protection to New Jersey residents and speeds up the development of underutilized properties.
Any parties that began remediation prior to November 3, 2009 will not be required to hire a LSRP to conduct the remediation right away. The remediation of those sites will proceed with traditional NJDEP oversight until 2012. All parties that begin remediation after November 3, 2009 are urged to opt into the LSRP paradigm and follow the provisions of the SRRA. All parties remediating sites on or after May 7, 2012 will be required to follow the provisions of SRRA. You can view those provisions by clicking here.
Hillmann Consulting, LLC is pleased to offer LSRP services to our clients. Our in-house LSRP, Mark Hasting, comes from an extensive remediation background. If you have questions about LSRP services, please feel free to contact Mark at (908) 688-7800.