Tag: Recordkeeping

California’s Proposed Electronic Recordkeeping Rule Seeks to Provide Guidance

On October 10, 2018, California’s Division of Occupational Safety and Health (DOSH) issued an emergency proposal that would amend its State Plan to require designated employers in the state to electronically submit to federal OSHA their Cal/OSHA Form 300A, which contains data on occupational injuries and illnesses that occurred in 2017; under the proposal, the […]

OSHA log

Prevent Incidents Using the OSHA 300 Log

You may have wondered why OSHA and OSHA-authorized states refer to occurrences in which workers are injured or killed as incidents, not accidents. The main reason is that, by the dictionary definition, an accident is an “unexpected or unforeseen” incident that usually results in injury or damage. To take an extreme example, an airplane that […]

electronic reporting recordkeeping filing

Court Asked to Block OSHA’s Suspension of Electronic Recordkeeping Rule

Three public interest groups have petitioned the U.S. District Court for the District of Columbia to order OSHA to lift its suspension of portions of its rule requiring employers to electronically submit to OSHA certain information about injuries and illnesses that occur in their workplaces. According to the petition before the court, OSHA suspended the […]

UST Amendments—What You Need to Know about Biofuels Compatibility

Since 1988, the UST regulations required that tanks be made of or lined with materials that are compatible with the substance stored. Since that time, many new biofuel blends have come on the market. The 2015 UST amendments add new compatibility notification, demonstration of compatibility, and recordkeeping requirements concerning certain biofuels. Notification. UST owners and […]

Understanding Coal Ash and the New Final Rule—Part 2

Understanding Coal Ash and the New Final Rule—Part 2 Coal ash will not be considered a hazardous waste. The final requirements for coal ash disposal were established for nonhazardous waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA), rather than under Subtitle C that covers hazardous waste. As one result, under RCRA, […]

2014 TSCA Work Plan Assessment Update

2014 TSCA Work Plan Assessment Update—How It Works In the beginning, back in 2012, the EPA first used several sources to identify chemicals meeting prioritization factor criteria as potential candidates for review, a process that initially identified 1,235 chemicals. Next, the chemicals were screened to determine if any chemicals should be excluded due to other […]

2014 TSCA Work Plan Assessment Update—Chemicals

2014 TSCA Work Plan Assessment Update—The Chemicals As noted yesterday, Action Plan chemicals are the most important identified by the TSCA Work Plan for Chemical Assessments, and in 2014, the following chemicals and chemical groups were added: Bisphenol A (BPA)—Ranked high for hazard and exposure; Decabromodiphenyl ether (decaBDE)—Ranked high for hazard, exposure, and persistence/bioaccumulation; Hexabromocyclododecane […]

Understanding Risks with Sunken Vessels

Other Factors The NOAA states that there are multiple general factors that must be considered in developing and implementing a plan to remove fuel or another potentially polluting substance from a sunken wreck.  For example: •              Vessel construction/engineering.  The actual construction and engineering of the vessel in areas such as plate thickness, riveting, and welding […]

The Oil Threat from Sunken Vessels

But given the difficulty of confirming information about submerged shipwrecks, there are many uncertainties about the estimates.  For example, the NOAA says that 47 of the 87 priority vessels have unknown or unconfirmed locations.  Unconfirmed locations include vessels where divers have reported finding a shipwreck, but definitive identification of the shipwreck has not been made.  […]