If you are a covered facility, don’t forget to get online and submit your 300A information to OSHA by December 15th. OSHA and MIOSHA require this electronic reporting for employers with 250 employees or more, and for certain high hazard industries with 20 to 249 employees. More information and OSHA’s online portal can be found here.
The new reporting requirements will be phased in over two years:
This year make sure your family and friends have a merry and safe Christmas by fire proofing your Christmas trees and decorations. According to the National Fire Protection Association (NFPA) electrical distribution or lighting equipment was involved in 40% of home Christmas tree fires. This means that people are placing electronic equipment too close to trees and other combustible decorations. In addition, one-quarter of the Christmas tree fires had some type of heat source, such as a candle or electrical equipment, too close to the tree. And, we’ve all seen those fire safety videos showing what happens when an evergreen tree catches fire. They can go up like a match!
Check out the NFPA’s holiday safety page. It has useful information and statistics to share with your family and friends. Download and share the safety tip sheets to ensure your holiday season ends with lots of hugs and good cheer and not with the smell of stale smoke and wet ash.
If that’s not enough to convince you to fix your octopus electrical plugs hidden under the couch, or to move the kerosene heater away from the base of the tree, check out the NFPA’s statistics on holiday fires. You will find them eye opening and amazing!
For some industrial facilities located in the Muskegon River and other Michigan watersheds, April 1, 2018 brings some new requirements for your storm water programs. These requirements will include:
· Determining specific drainage characteristics of your property
· Selecting storm water sampling points
· Storm water sampling - Visual Assessments
· Storm water sampling procedures
· Procedures for collecting and evaluating water samples.
So, what are these new requirements actually asking of you? Here’s is some valuable information to help you understand the rest of the story.
For many companies this is a new requirement. When performing Visual Assessment (VA) the main theme to remember should be consistency, which means doing the same procedure the same way – every time. When you create your procedures make sure a description of the supplies, apparatus and sample jars to be used are specifically identified and that these items are available each time you collect and evaluate a sample.
For example, viewing your sample under consistent lighting and in front of a white backdrop are good practices to implement when making your observations. When you keep your apparatus consistent, then it will be easier to demonstrate that your samples have been evaluated in the same way every time.
Drainage Area & Sample Locations
The regulations require that you delineate the drainage areas within your facility and identify all of the potential pollutants that could possibly be in the storm water from those drainage areas. This is a great time to be best friends with your maintenance manager because you will likely need sewer maps and other information to complete this task.
For each sample location consider how each sample will be collected and the equipment you might need. Include safety considerations and safety procedures when determining your sampling methodology. For instance, some locations may be steep and have thick vegetation to contend with, while others may have heavy traffic concerns. Considerations should be made for engineered access points, traffic cones, barriers and even temporary traffic diversions. Work with your maintenance or grounds staff to help make each sample location accessible and safe.
SRM has Certified Storm Water Operators that can assist you with your storm water needs. Give us a call! For more MDEQ information, visit their industrial storm water web page.
Because the USEPA has adopted GHS, the reporting requirements under EPCRA have expanded. The Tier 2 reporting requirements now have 24 physical and health hazard categories. The new Tier 2 form now has 13 physical hazard choices and 11 health hazard choices. The following table lists the new categories:
The MDEQ is asking Michigan facilities to start updating their Tier 2 reports now to avoid the rush in January and February. The MDEQ Tier ll Manager software system is updated and ready to go!
USEPA has released the updated Tier 2 Submit software for CY 2017 for those companies with facilities in other states.
Helpful Hint in preparing 2018 Tier 2 Reports: Be sure to obtain updated SDSs. They will be incredibly helpful in selecting the hazard category for the chemicals you have on site. If you need assistance updating your Tier 2 report for 2017, contact our professionals at SRM.
For more information, check out the following links for the MDEQ and USEPA web sites