The applicability of the U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) is reasonably clear, but facilities with chemicals in amounts less than the RMP thresholds are finding themselves in trouble with the EPA because they are overlooking EPA’s General Duty Clause (42 U.S. Code 7412(r)(1)). Several times over the last 6 months the […]
Tag: General Duty Clause
OSHA uses the General Duty Clause of the Occupational Safety and Health Act (OSH Act) as a “gotcha” or “catchall” for hazards with no established standards, the members of a federal review board recently said.
The General Duty Clause (Clause) of the Occupational Safety and Health (OSH) Act has been in effect since the Act was passed in 1970 and, therefore, should be an important consideration in employer worker safety and hazard reduction plans. But while most employers that are familiar with the OSH Act and federal and state worker-protection […]
An OSHA standard to mitigate workplace violence in healthcare facilities does not appear to be on the horizon, but this is not because OSHA is not aware of the main provisions that would be included in such a standard. In fact, it is not uncommon for OSHA to issue citations against healthcare employers whose employees […]
In conjunction with a new report by Public Citizen, 130 groups have petitioned U.S. OSHA to initiate rulemaking for the first federal standard to protect indoor and outdoor workers from occupational exposure to excessive heat.
Q: Is the wearing of shorts in a parts warehouse permitted by OSHA?
Generally, when the Occupational Safety and Health Administration (OSHA) inspects an employer’s facility in one location, it issues citations and abatement requirements that apply only to that location. OSHA does not habitually attempt to issue citations and require abatement at facilities in other locations that are affiliated with the same employer—even in cases where repeat […]
Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]
Tomorrow, July 28, is World Hepatitis Day. According to the World Health Organization, 400 million people worldwide are currently living with hepatitis B and C, and 1.4 million die of these diseases each year. OSHA is taking workplace exposures to bloodborne pathogens seriously. On June 25, the agency issued enforcement guidance for inpatient healthcare settings […]
The CAA’s Chemical Accident Prevention Program requires that any facility that has listed substances above threshold quantities in any single process prepare a Risk Management Plan (RMP). The listed substances contain 77 toxic chemicals with thresholds ranging from 500 pounds (lb) to 20,000 lb and 63 flammable substances with a threshold quantity of 10,000 lb. […]