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Category Archives: Resources
IESO Presenting at the 2011 TN Safety Congress
On Monday August 1, 2011, Dr. Scott Harris will present at the 34th annual Tennessee Safety Congress in Nashville. ”Coordination with Federal Assets – The EPA Emergency Response Process” is a plain-English overview of activating and coordinating with U.S. EPA emergency response assets: notification, National Response Framework, Federal On-Scene Coordinator authorities, Unified Command, the National Contingency Plan and Responsible Party obligations. Our web visitors can download slides of Scott’s presentation here.
Meet Us in Norfolk in July!
The 33rd annual Occupational Safety and Health Summer Institute in Norfolk, VA is scheduled for July 26-30, 2010. The Institutes, part of the North Carolina OSHERC continuing education program at the University of North Carolina at Chapel Hill, are designed for industrial hygienists, safety and environmental managers, occupational physicians and nurses and anyone else involved in EHS management. There are about 30 courses covering everything from regulations to healthcare hazmat to environmental health, all eligible for recertification points toward your CHMM, CIH, CSP or other professional certs.
IESO will be there instructing Environmental Regulations for Occupational Health and Safety Professionals, and co-teaching two new courses, Managing Hazmat Responses in Healthcare and Environmental Health and Safety Management Systems in Healthcare.
Posted in Environmental Compliance, Health and Safety Compliance, Resources
Tagged "chapel hill", "continuing ed", "continuing education", "Dr. Scott Harris", "hazardous substance training", "healthcare accreditation", "healthcare industry", "ieso llc", "iesollc", "iso 14001", "Keith Spencer", "kenneth Harris", "Kenneth Scott Harris", "NC OSHERC", "osh erc", "Scott Harris PHD", "Scott Harris", "summer institute", chmm, ehs, EPA, Gillings, institute, NCOSHERC, norfolk, nurses, OSHA, osherc, regulations, training, UNC
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Florida Worker Grant Funding Alert
The state of Florida has just received nearly $62 million in new stimulus money for worker training programs. Since this is the time of year that states are usually out of funds and not accepting applications, they are in the very unusual position of having funding, but few applications. The Incumbent Worker Training grant coordinator has told IESO, LLC that with such low application volume, at least for the short term she can achieve an unheard-of two-day turnaround time for approval.
Posted in Hot List, Resources
Tagged "cost recovery", "Dr. Scott Harris", "grant program", "ieso llc", "iesollc", "incumbent worker training", "incumbent worker", "iso 14001", "kenneth Harris", "Kenneth Scott Harris", "Scott Harris PHD", "Scott Harris", "stimulus money", "training provider", "worker training", florida, grant, IESO, ISO, iso14001, reimbursement
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EPA Reimbursement for Hazmat Response
The U.S. EPA has been reimbursing local governments for hazmat responses since 1986, but it seems that many LEPCs and other eligible groups are still unfamiliar with the program. From the LGR website: “In the event of a release (or threatened release) of hazardous substances, EPA may reimburse local governments for expenses related to the release and associated emergency response measures. The Local Governments Reimbursement (LGR) Program provides a ‘safety net’ of up to $25,000 per incident to local governments that do not have funds available to pay for response actions.” So with over $3 million in reimbursements awarded to date, how do you get your money back? It really is not all that complicated, but first we need a basic understanding of the relevant terms and requirements.
Who is eligible?
Posted in Hot List, Resources
Tagged "40 cfr 300.700", "cercla 107 a", "cercla 107a", "cercla response", "cost recovery", "Dr. Scott Harris", "hazardous substance", "hazmat reimburse", "hazmat reimbursement", "kenneth Harris", "Kenneth Scott Harris", "lgr program", "local government reimbursement", "local governments reimbursement", "Scott Harris PHD", "Scott Harris", cercla, hazmat, lepc, lgr, lgrp, PRP, PRPs, reimbursement, RP, rps
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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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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.
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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On Being an EPA Superfund PRP
On Being an EPA Superfund PRP
CERCLA, more commonly known as Superfund, allows EPA’s Emergency Response Program to take or compel action by others at sites contaminated or potentially contaminated by hazardous substances, pollutants or contaminants, and then recover costs associated with those activities. Whether an emergency response or a longer-term investigation and cleanup, EPA uses an Enforcement First Policy (EFP) to identify potentially responsible parties (PRPs) to cover the cost of any action underway or anticipated. The hunt for you will be thorough, and there is a specific 381-page manual to guide it. There is even a directory of Agency experts (PRP Search Enhancement Team) available to support the effort.
Posted in Environmental Compliance, Resources, Risk Management
Tagged "contaminated site", "contaminated sites", "cost recovery", "demand letter", "Dr. Scott Harris", "emergency response", "enforcement first", "federal on-scene coordinator", "federal onscene coordinator", "iesollc", "information request letter", "kenneth Harris", "Kenneth Scott Harris", "nfi letter", "notice of liability letter", "on-scene coordinator", "onscene coordinator", "potentially responsible parties", "potentially responsible party", "prp search enhancement team", "recovery action", "Scott Harris PHD", "Scott Harris", cleanup, DOJ, EPA, FOSC, nfi, notice of federal interest", osc, PhD", PRP, PRPs, reimbursement, remediation, RP, Superfund, treble, UAO
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