EPA and OSHA requirements

The EPA and OSHA require development of an emergency plan and traiifing in the implementation of the plan [l(n), 2(95), 25]. Because the requirements differ, a site s plan should include the requirements of both standards, as shown in Table 17.10. 

The EPA and OSHA require self-audits every 3 years by at least one person who is knowledgeable in the process(es) that involve regulated chemicals, beginning June 21, 1999, and May 26, 1995, respectively, to determine conformance. The employer shall promptly determine and document appropriate responses to the findings of the audit and document that the deficiencies have been corrected [l(o), 2(58)]. 

After the law is official, how is it put into practice Laws often do not include the details for compliance. For example, the USC requires the appropriate respirator protection, but it does not specify the detailed types or limitations of respirators. To make the laws work on a day-to-day level, Congress authorizes governmental organizations, including the EPA and OSHA, to create regulations and/or standards. 

The second requirement of the RMP is a prevention program. The prevention program has 11 elements, compared to the 14 elements of the PSM standard. As shown in Table 3-4, many of these elements are duplicated. Fortunately, the EPA made a deliberate attempt to retain the same requirements wherever possible, although differences exist because the EPA and OSHA have different responsibilities. The first column in Table 3-4 lists each element of the PSM program, and the second column shows the corresponding element of the prevention program (some elements have no equivalence). 

W. Record keeping and reporting (FEMA, DHS, DOT, OSHA, EPA, and other requirements) (It is important to maintain accurate financial records of expenses associated with the emergency event for possible federal reimbursement.)... 

Chemical Hazard Communication Guidebook OSHA, EPA, and DOT Requirements... 

Across-the-board review of the personal protection required when working with chemicals. Why and when personal protective equipment is required three respirator classes, selection criteria, and fit testing and demonstration and explanation of EPA and OSHA system of A-B-C-D ensemble classifications. Part of four-volume series, "A Refresher Course in Chemical Safety."... 

The EPA and OSHA want to know that emissions will be at or below required thresholds. Ask the filtration manufaeturer for a written guarantee of emis-sions performance stated as grains per cubic foot. A reliable supplier should be willing to provide this, ong with a warranty on expected cartridge filter life. 

De Minimis Limitation. A listed toxic chemical does not have to be considered if it Is present in a mixture at a concentration below a specified de nvnimis level. The de minimis level is 1.0%, or 0.1% if the chemical meets the OSHA carcinogen standard. See Table II for the de minimis value associated with each listed toxic chemical. For mixtures that contain more than one member of a listed chemical category, the de minimis level applies to the aggregate concentration of all such members and not to each individually. EPA included the de minimis exemption In the njle as a burden reducing step, primarily because facilities are not likely to have information on the presence of a chemical in a mixture or trade name product beyond that available in the product s MSDS. The de minimis levels are consistent with OSHA requirements lor development of MSDS information concerning composition. 

New regulatory initiatives (e.g., from OSHA and EPA) and industry programs (e.g., the Chemical Manufacturers Association s Responsible Cate effort) have stimulated increased attention to PSM. While compliance is certainly a requirement in deciding to implement PSM, it is by no means the only ben t. Rather, compliance is the baseline from which other benefits evolve. The quality and effectiveness of the system your company ultimately adopts could well depend on how persuasively those benefits are conveyed. Remember, at this point in your initiative, the goal is to win endorsement of a concept, not approval of a full-fledged plan. The core of that concept is the idea that PSM offers benefits over and above compliance with new regulations, or conformance with an industry initiative. 

Although TSCA 6(a)(3) authorizes EPA to issue requirements containing hazard warnings and instructions, the Agency never has proposed any such rules. This may be due in part to the fact that OSHA has proposed certain hazard communication requirements (47 Fed. Reg. 12091, March 19, 1982) which may become effective during 1983. 

This book fully discusses requirements set forth by OSHA, EPA, and DOT for communicating chemical hazards. Up-to-date chemical lists for emergency planning, spill reporting, and toxic chemical release reporting are Included. 

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