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Monthly Archives: May 2009
Guidance on the Use of Chemical Countermeasures on Inland Oil Spills
Guidance on the Use of Chemical Countermeasures on Inland Oil Spills
The U.S. Environmental Protection Agency (USEPA) recognizes the major role of local government responders, such as firefighters, as the first line of defense for mitigating threats to public health and the environment from spills of oil and hazardous substances, and tries to provide them with the tools necessary to safely and effectively mitigate such incidents. Chemical countermeasures (CCMs) are one of those tools, but their use must be authorized and carefully managed. This article describes that process where countermeasures are proposed for use on inland events such as fuel spills that may affect navigable waters. These may include surface waters and conduits to them, including road ditches and storm drains, though the exact definition remains in flux.
Posted in Environmental Compliance, Resources, Risk Management
Tagged "chemical countermeasure", "Chemical Countermeasures", "Dr. Scott Harris", "first responder liability", "fuel spill", "fuel spills", "iesollc", "inland oil spill", "inland oil spills", "kenneth Harris", "Kenneth Scott Harris", "navigable waters", "oil spills", "product schedule", "Scott Harris PHD", "Scott Harris", "subpart j", CCM, CCMs, dispersant, dispersants, EPA, IESO, ncp, nrc, osc, rrt
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Healthcare and ISO?
The U.S. healthcare industry has only barely noticed ISO or similar internationally recognized EHS management approaches. Reports are that only a handful of these facilities are accredited to the ISO 14001 (Environmental Management System) or the OHSAS 18001 (occupational safety and health) standards. This is an industry that would benefit greatly from what the rest of us already know — that good environmental, health and safety management systems work, and much better than traditional “catch and release” compliance audits and inspections.
On page 11 of this ASSE Newsletter, (healthbeat-newsletter-20091) there is an excellent article (“An Ever-Changing Environment”) comparing the “management system versus inspection” approach. The author, who sits on the ASSE Healthcare Practice Speciality Committee, makes a strong case for the use of a reliable EMS.
Posted in Hot List, Management Systems, Risk Management
Tagged "Dr. Scott Harris", "healthcare accreditation", "healthcare industry", "kenneth Harris", "Kenneth Scott Harris", "management systems", "Scott Harris PHD", "Scott Harris", "Tony Stewart", accredited, ASSE, DNV, EMS, healthcare, ISO, PhD"
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Fire in the Hole!
Video (with audio) from an EPA cleanup site in east Texas. Cans of crystallized ether had to be exploded on-site. This material is shock-sensitive, has to be handled like an unstable explosive and is too dangerous to move anywhere else. The solution here was a “blow-in-place” scenario. Our ATF bomb tech put the cans in shallow holes, rigged them with a small donor charge and we remote-detonated them.
Refer to the EPA web site at http://www.epaosc.org/site_profile.asp?site_id=06RZ for detailed information.
Proposed EPA Greenhouse Gas Reporting Rule
On March 10, 2009 EPA announced a proposed rule (“Mandatory Reporting of Greenhouse Gases”) that would apply to an estimated 13,000+ suppliers of fossil fuel and industrial chemicals, manufacturers of motor vehicles and engines and large direct emitters of greenhouse gases (GHGs) with emissions equal to or greater than a threshold of 25,000 metric tons per year. Those familiar with existing reporting programs should think “Form R” for GHGs. The quickest way to get familiar with it is to review the EPA fact sheet.
Posted in Environmental Compliance, Hot List
Tagged "clean air act", "Dr. Scott Harris", "GHG emissions", "greenhouse gas emissions", "greenhouse gases", "kenneth Harris", "Kenneth Scott Harris", "proposed rule", "Scott Harris", CAA, carbon dioxide, ch4, co2, EPA, GHG, GHGs, greenhouse gas reporting", methane, PhD"
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Useful Links and Downloads
EPA FOSC Homepage (EPA Federal On-Scene Coordinators, responses and cleanups)
KAM (Ky Association of Manufacturers)
NIOSH Pocket Guide (e-version of latest Pocket Guide)
DOT ERG (e-version of DOT Emergency Response Guidebook)
EPA – LMOP (EPA Landfill Methane Outreach Program)
Proposed GHG Rule (Proposed EPA rule on greenhouse gas reporting)
Drug-Free Workplace Advisor (Wizard for DFWA program)
ATSDR – ToxFAQs™ Hazardous Substance Fact Sheets (Detailed toxicology info)
Available CFR Titles on GPO Access (Search for CFRs)
Occupational Safety & Health Administration (OSHA Home Page)
SIRI MSDS Index (Search for MSDSs)
OSHA e-HASP (Electronic Health & Safety Plan)
ALOHA (Modeling software for releases)
NRC (National Response Center)
CDC (Centers for Disease Control homepage)
Posted in Resources
Tagged "epa links", "kenneth Harris", "Kenneth Scott Harris", "osha links", "useful downloads"
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Independent Audits and Reviews
Independent audits and reviews are one very good way of evaluating a program objectively and accurately to determine vulnerabilities and risk. These plans and programs come in many forms and serve many purposes, ranging from EPA and OSHA compliance and Emergency Action Plans to Risk Management Plans, Worst-case Scenarios and Off-site Consequence Analysis to SPCC and RCRA contingency plans.
A related critical risk management tool follows an environmental incident, such as a spill or explosion, and is frequently referred to as an Emergency Response Review or “Hotwash.” Following the review, you may be asked to develop a “lessons learned” or “after-action report” to help do the job better and safer the next time. EPA or other Agencies often require this following an emergency response in which they were involved.
Posted in Environmental Compliance, Health and Safety Compliance, Management Systems, Resources
Tagged "after action", "audit policy", "audit team", "compliance audit", "compliance audits", "corrective action", "Dr. Scott Harris", "emergency response review", "external auditing", "external auditor", "hot wash", "independent audit", "independent audits", "internal audit", "internal auditor", "kenneth Harris", "Kenneth Scott Harris", "lessons learned", "regulatory audit", "regulatory inspection", "Scott Harris PHD", "Scott Harris", "voluntary audit", "voluntary audits", "work product", audit, auditing, auditor, auditors, audits, consultant, consulting, disclosure, EPA, finding, findings, hotwash, inspection, inspections, inspector, internal, ISO, NFPA, OSHA, PhD", plan, plans, regulatory auditing", report, reporting, review, risk
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