Tag: General Duty Clause

How to Avoid RMP

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 […]

Are You Covered by the Bloodborne Pathogens Standard?

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 […]

What Is an EHS and Why Would I Want to Know?

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. […]

2014 EPCRA Enforcement Roundup

2014 EPCRA Enforcement Roundup   What do a wood door manufacturer, an organic food company, a wire manufacturer, a cheese manufacturer, and an oil sands crude refinery have in common? On the surface, it would appear they are pretty different, but when it comes to compliance with EPCRA, all reached settlements with the EPA during […]

On a Multiemployer Worksite, What Are You Responsible For?

How many employers have a presence on your worksite? Do you have two or three contractors renovating your office space, another contractor running your on-site cafeteria, some consultants evaluating your production unit, a medical group doing a wellness screening on-site, and a crew of temporary employees in the warehouse? All of those workers represent different […]

Understanding the CAA’s General Duty Clause

Understanding the CAA’s General Duty Clause The CAA Amendments of 1990 marked the birth of the GDC, which became effective in November of that year for any stationary source producing, processing, handling, or storing regulated substances or extremely hazardous substance. But the GDC is not an actual regulation, nor can compliance with the GDC be […]