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12 Changes in Store for EPA’s MSGP for Stormwater Associated with Industrial Activities

Twelve changes to the 2008 federal MSGP for stormwater discharges associated with industrial activity are included in EPA’s draft 2013 MSGP. Coverage under the 2008 MSGP, which expired September 29, 2013, is administratively extended until the 2013 permit is issued, provided facilities submit a Notice of Intent (NOI) to be covered by the new permit […]

Cord-and-Plug-Connected Equipment: What Does OSHA Say?

Yesterday, we looked at OSHA’s answers to some employers’ questions about training certification and LOTO verification. Today, we’ll look at what OSHA has to say about workers performing maintenance on plug-and-cord-connected equipment covered under an exception in the LOTO rules. Employers often write to OSHA asking for clarifications of its requirements. Sometimes, OSHA writes back. […]

11 Tips for Qualifying Under the “No Exposure” Exclusion for Stormwater Associated with Industrial Activities

Under the conditional no-exposure exclusion (found at 40 CFR 122.26(g)), operators of industrial facilities subject to stormwater regulations have the opportunity to certify to a condition of “no exposure” if their industrial materials and operations are not exposed to stormwater. Note: This no-exposure exclusion does not apply to construction activities, which are addressed under the […]

Electronic Training Records and Lockout Verification: What Does OSHA Say?

Here’s a question: Your employees carry identification badges that identify the individual employee when it is swiped on an electronic reader. The badges are used for workplace security, documenting time on the clock, and recording attendance in training classes. The badge-swiping system identifies individual employees, but is not equivalent to an “electronic signature.” Is it […]

SPCC: What Are Your Security Requirements

Standard SPCC plans must describe security procedures for their operation (excluding oil production facilities). The security requirements are meant to prevent oil discharges that result from vandalism or other unauthorized access to oil containers or equipment. Security procedures must include provisions to: Secure and control access to each facility’s handling, processing, or storage areas. Secure […]

Deal Breakers for Forklift Operators

All forklift operators must be certified through a process of classroom and hands-on training in order to operate a forklift. Once they’re certified, they should be expected to operate the forklift safely at all times. If they don’t, they should be retrained before being permitted to operate a forklift again. What sorts of behaviors would […]

SPCC: Tips for Tank Inspections

The following Table outlines the inspection requirements for tanks and associated piping at onshore nonproduction facilities that store petroleum and nonpetroleum oils—except animal fats and vegetable oils, which have their own set of inspection requirements. Note: The SPCC rule also contains integrity testing provisions for tanks, which are not included in this table.  In addition, […]

What Makes a Forklift Operator? Basic Qualifications

An unqualified forklift operator is a hazard to himself, to coworkers, and to your bottom line. The answer to the question “What makes a forklift operator qualified?” might seem straightforward—“a certified forklift operator,” right? But what goes into that qualification? What does a certified forklift operator know? Here are the basic ingredients that identify a […]

Environmental Crisis Communication: How to Avoid Community Outrage

10 Tips for Communicating an Environmental Crisis Accept responsibility for real and perceived environmental risks at your facility. The time to develop a public relations program is not after the incident happens. Facilities should already have a plan that addresses crisis communication. Companies that isolate themselves in times of crisis will be blamed by a […]

Safety and Health Training for the Public Sector

Today’s Advisor reports on OSHA’s new safety and health training program for the public sector. The Occupational Safety and Health Administration’s (OSHA) jurisdiction doesn’t extend to the public sector, but that doesn’t mean the agency is neglecting the safety and health of state and local government employees. Late in 2013, OSHA launched a new certificate […]