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On June 28, 2022, OSHA published an Advanced Notice of Proposed Rulemaking (ANPRM) in the Federal Register. The ANPRM looks to reduce medical removal protection and surveillance triggers under OSHA’s current General Industry and Construction standards. Public comments concerning blood lead triggers, medical surveillance, permissible exposure limit, PPE, housekeeping, hygiene, and training are due online by August 29, 2022. See the Federal Register notice for instructions how to submit comments.

Recent research indicates that workers can have adverse health effects from lead exposures below current permissible exposure limits. Employers must understand how to:

  • Meet their duty under OSHA’s standards,
  • Communicate lead exposure hazards to workers, and
  • Protect workers from occupational exposure to lead.

Lead (Pb) is a heavy metal that can threaten workers’ health in many occupations. Lead can be inhaled or swallowed, and once inside the body, it tends to remain in tissues and organs. Eventually, after repeated exposures, lead build-up becomes toxic.

Lead is an important ingredient in paint because of its rust-inhibiting properties. Lead-based paints are still used on bridges, railways, ships, lighthouses, and other steel structures. However, they are no longer used in household paints. Significant exposure can arise from removing paint from surfaces previously coated with lead-based paint, such as in:

  • Bridge repair,
  • Resdential renovation,
  • Remodeling, and
  • Demolition.

Welders, painters, or plumbers have increased chances of exposure to lead. If workers are not properly protected, they risk getting lead poisoning.

What duty do employers have?

Workers have the right to know what operations and processes in the workplace could cause lead exposure. While using lead in the workplace, employers must test air samples to determine if the amount of lead exceeds the limits set by OSHA. If air sampling in the workplace discloses that lead levels exceed permissible exposure limits (PELs), employers must:

  • Provide an overview of the OSHA rule on lead and the company’s written safety plan, if requested,
  • Post warning signs in all areas where exposure may exceed PEL,
  • Give initial training before the time of initial job assignment, and at least annually after that,
  • Inform you about sources of lead exposure in the workplace and operations which could lead to exposure,
  • Provide proper PPE. Proper use of work clothing and industrial hygiene can reduce exposure to lead, and
  • Offer a medical monitoring program if employees are exposed. You have a right to view the results of any medical examination.

How can it harm workers?

How can it harm workers? Lead can be absorbed into the body by inhaling it or ingesting it. As exposure to lead continues, the amount stored in your body may increase. Even though workers may not be aware of any immediate symptoms of the disease, the lead stored in their tissues can be slowly causing irreversible damage. The exposure can damage the nervous system, kidneys, immune system, reproductive system, and possibly cause cancer. Damage occurs to individual cells, organs, and the entire body system.

How can workers protect themselves?

How can workers protect themselves? Maintaining lead exposure at acceptable levels is possible if the following these practices:

  • Use an exhaust ventilation system, where provided.
  • Don a respirator that will give adequate protection.
  • Keep the worksite clean. When removing lead dust, use only a vacuum with a HEPA filter or wet cleaning methods. Never use compressed air for cleaning.
  • Eat, drink, or smoke in areas outside the worksite. Keep all lunch boxes and coffee cups away from the work area.
  • Use protective clothing. Store street clothes separately from work clothes. Never wear contaminated clothes home.
  • Shower and change into clean clothes, including shoes, before leaving the worksite so that no lead contamination is carried home.

Don’t forget to post signs too. In areas with lead, post signs where the permissible exposure level is exceeded in each work area. The signs must bear the legend:

  • WARNING
  • LEAD WORK AREA POISON
  • NO SMOKING OR EATING

Key to remember: If workers are not adequately protected, they risk getting lead poisoning. Workers have the right to know what operations and processes in the workplace could cause lead exposure.

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Most Recent Highlights In Environmental

EPA amends specific oil and gas emission standards
2026-04-10T05:00:00Z

EPA amends specific oil and gas emission standards

On April 9, 2026, the Environmental Protection Agency (EPA) published a final rule that makes technical changes to the emission standards established in March 2024 (2024 Final Rule) for crude oil and natural gas facilities. This rule (2026 Final Rule) amends the requirements for:

  • Temporary flaring of associated gas, and
  • Vent gas net heating value (NHV) monitoring provisions for flares and enclosed combustion devices (ECDs).

Who’s impacted?

The 2026 Final Rule affects new and existing oil and gas facilities. Specifically, it applies to the regulations for the Crude Oil and Natural Gas source category, including the:

  • New Source Performance Standards at 40 CFR 60 Subpart OOOOb, and
  • Emission guidelines at 60 Subpart OOOOc.

These emission standards are commonly referred to as OOOOb/c.

What are the changes?

The 2026 Final Rule implements technical changes to the temporary flaring and vent gas NHV monitoring requirements set by the 2024 Final Rule.

Temporary flaring

The rule extends the baseline time limit for temporary flaring of associated gas at well sites in certain situations (like conducting repairs or maintenance) from 24 to 72 hours. Owners and operators must stop temporary flaring as soon as the situation is resolved or the temporary flaring limit is reached (whichever happens first).

It also grants allowances beyond the 72-hour limit if exigent circumstances occur (such as severe weather that prevents safe access to a well site to address an emergency or maintenance issue) and there’s a need to extend duration for repairs, maintenance, or safety issues. Owners and operators must keep records of exigent circumstances and include the information in their annual reports.

NHV monitoring

For new and existing sources, the 2026 Final Rule exempts all flare types (unassisted and assisted) and ECDs from monitoring due to high NHV content, except when inert gases are added to the process streams or for other scenarios that decrease the NHV content of the inlet stream gas. In these cases, EPA requires NHV monitoring via continuous monitoring or the alternative performance test (sampling demonstration) option for all flares and ECDs.

Other significant changes include:

  • Replacing the general exemption from NHV monitoring for associated gas for any control device used at well site affected facilities with NHV monitoring requirements;
  • Granting operational pauses during weekends and holidays for the consecutive 14-day sampling demonstration requirements (limiting it to no more than 3 operating days from the previous sampling day); and
  • Permitting less than 1-hour sampling times for twice daily samples where low or intermittent flow makes it infeasible (as long as owners and operators report the sampling time used and the reason for the reduced time).

The 2026 Final Rule takes effect on June 8, 2026.

Key to remember: EPA’s technical changes to the emission standards for oil and gas facilities apply to temporary flaring provisions and vent gas NHV monitoring requirements.

EHS Monthly Round Up - March 2026

EHS Monthly Round Up - March 2026

In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.

OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.

OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.

Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.

Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.

On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.

And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

EPA releases draft list of drinking water contaminants for possible regulation
2026-04-07T05:00:00Z

EPA releases draft list of drinking water contaminants for possible regulation

The Environmental Protection Agency (EPA) published the draft Sixth Contaminant Candidate List (CCL 6) for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act (SDWA). The agency’s proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.

What’s on the list?

The proposed CCL 6 contains:

  • 4 chemical groups, including:
    • Microplastics,
    • Pharmaceuticals,
    • Per- and polyfluoroalkyl substances (PFAS), and
    • Disinfection byproducts.
  • 75 chemicals; and
  • 9 microbes.

EPA may regulate the listed contaminants in the future.

What does the CCL do?

The drinking water CCL is the first part of the process to regulate contaminants in public water systems. The list identifies unregulated contaminants known or anticipated to be present in drinking water that pose the greatest health risk. It helps EPA prioritize which contaminants to evaluate for potential regulation.

The SDWA requires EPA to make regulatory determinations (i.e., whether to develop rules for a contaminant) for at least five contaminants listed on the CCL every 5 years. When the agency determines a contaminant needs to be regulated, it begins the rulemaking process to develop a National Primary Drinking Water Regulation (NPDWR) for the contaminant. The NPDWRs apply to public water systems.

How can I participate?

EPA will receive public comments on the CCL 6 through June 5, 2026. You can send comments to EPA via regulations.gov or by mail. Make sure your submission includes the Docket ID No. EPA-HQ-OW-2022-0946.

Key to remember: The draft list of the next round of drinking water contaminants to be considered for regulation adds priority groups for microplastics and pharmaceuticals.

EPA delivers 2026–2027 renewable fuel volumes
2026-04-03T05:00:00Z

EPA delivers 2026–2027 renewable fuel volumes

On April 1, 2026, the Environmental Protection Agency (EPA) published the “Set 2” Rule, establishing the Renewable Fuel Standard (RFS) program’s 2026 and 2027 renewable fuel volumes and associated percentage standards for:

  • Cellulosic biofuel,
  • Biomass-based diesel (BBD),
  • Advanced biofuel, and
  • Total renewable fuel.

The final rule also implements other significant changes.

Who’s impacted?

The “Set 2” Rule affects:

  • Transportation fuel (i.e., gasoline and diesel) refiners, blenders, marketers, distributors, importers, and exporters; and
  • Renewable fuel producers and importers.

The volume and percentage requirements apply to obligated parties, which include transportation fuel refiners and importers.

What are the changes?

The final rule sets the renewable fuel volume requirements and associated percentage standards for 2026 and 2027. Volume requirements are measured in billion Renewable Identification Numbers (RINs). One RIN represents one gallon of ethanol-equivalent renewable fuel.

Renewable fuel categoryVolume requirements (in billion RINs)Percentage standards
2026202720262027
Cellulosic biofuel1.361.430.79%0.84%
BBD9.079.205.24%5.37%
Advanced biofuel11.1011.326.42%6.61%
Total renewable fuel26.8127.0215.50%15.78%

The “Set 2” Rule also:

  • Reallocates 70 percent of the exempted Renewable Volume Obligations (RVOs) for 2023–2025 to 2026 and 2027 (which are reflected in the above table’s volume requirements),
  • Partially waives the 2025 cellulosic biofuel volume requirement from 1.38 billion RINs to 1.21 billion RINs and adjusts the related percentage standard from 0.81 percent to 0.71 percent, and
  • Removes renewable electricity as a qualifying renewable fuel under the RFS program.

RFS program refresher

The RFS program requires transportation fuel sold in the United States to contain a minimum volume of renewable fuels. EPA sets the renewable fuel volume targets for each of the four renewable fuel categories.

To comply, obligated parties must:

  • Calculate their RVOs for each renewable fuel category, and
  • Obtain and retire enough RINs to meet their RVOs.

Regulations also apply to fuel blenders, marketers, and exporters.

Small refiners may petition EPA for a small refinery exemption (SRE), which allows refineries to produce gasoline and diesel without having to meet the RVOs required by the RFS program. EPA grants SREs annually, and they cover one specific compliance year.

Key to remember: EPA’s final “Set 2” rule establishes the renewable fuel volumes and percentage standards for 2026 and 2027 and drives other changes to the RFS program.

EPA releases final NESHAP for chemical manufacturing area sources
2026-04-02T05:00:00Z

EPA releases final NESHAP for chemical manufacturing area sources

The Environmental Protection Agency (EPA) published a final rule on April 1, 2026, amending the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical Manufacturing Area Sources (CMAS). The NESHAP controls hazardous air pollutant (HAP) emissions from facilities that manufacture a range of chemicals and products, such as inorganic chemicals, plastics, and synthetic rubber.

Who’s impacted?

The final rule applies to nine area source categories in the chemical manufacturing sector that are regulated by the CMAS NESHAP (40 CFR 63 Subpart VVVVVV).

What are the changes?

EPA’s final rule:

  • Establishes leak detection and repair requirements for equipment leaks and heat exchange systems in organic HAP service,
  • Adds detectable emissions monitoring standards for pressure vessels in organic HAP service and emission management practice standards for pressure relief devices (PRDs) in organic HAP service,
  • Prohibits closed vent systems in organic HAP service from bypassing an air pollution control device (APCD), and
  • Requires recurring performance testing of non-flare APCDs to demonstrate compliance with process vent and storage tank provisions.

The final rule also mandates electronic reporting for notifications of compliance status (NOCs), performance test reports, and periodic reports. Facilities must submit these reports through the Compliance and Emissions Data Reporting Interface (CEDRI) on EPA’s Central Data Exchange.

What didn’t change?

Significantly, the final rule doesn’t add previously proposed regulations for area sources that use ethylene oxide (EtO) to produce materials described by code 325 of the North American Industry Classification System (NAICS).

EPA states that it intends to address the regulation of EtO from area sources and major sources in one final action.

What are the compliance timelines?

Existing facilities must comply with the amendments by April 1, 2029.

New facilities (those that begin construction or reconstruction after January 22, 2025) have to comply with the changes by April 1, 2026, or upon startup, whichever is later.

Additionally, facilities must start electronically submitting:

  • Performance tests by June 1, 2026;
  • NOCs by August 31, 2026; and
  • Periodic reports by April 1, 2029.

Key to remember: EPA’s final HAP emissions rule for chemical manufacturing area sources adds new requirements for certain processing equipment and systems.

See More

Most Recent Highlights In Transportation

EPCRA inventory reports: A case study in federal, state, and local collaboration
2026-03-31T05:00:00Z

EPCRA inventory reports: A case study in federal, state, and local collaboration

Environmental regulations require many facilities to report annual inventories of the hazardous chemicals they use or store. Have you ever considered the impact that this information has beyond regulatory compliance? Reporting facilities, whether they realize it or not, serve an essential role in local emergency response planning.

The Environmental Protection Agency’s (EPA’s) Hazardous Chemical Inventory Reporting program under the Emergency Planning and Community Right-to-Know Act (EPCRA) offers a prime example of how collaboration among the federal, state, local, and facility levels supports safer communities.

What’s EPCRA's inventory reporting program?

The Occupational Safety and Health Administration (OSHA) requires facilities to keep Safety Data Sheets (SDSs) for any hazardous chemical used or stored in the workplace. Facilities that use or store the chemicals on-site at or above certain thresholds at any one time are subject to EPCRA’s Hazardous Chemical Inventory Reporting program. Regulated facilities must report information about the hazardous chemicals to the:

  • State Emergency Response Commission (SERC),
  • Local Emergency Planning Committee (LEPC), and
  • Local fire department.

What’s reported?

EPA’s EPCRA inventory program consists of two reporting requirements under Sections 311 and 312 of EPCRA.

SDSs/lists

Section 311 of EPCRA requires facilities to submit the SDSs for or a list of the hazardous chemicals used or stored on-site at or above the reporting thresholds to the SERC, LEPC, and local fire department.

SDSs usually include comprehensive information, such as:

  • The composition of ingredients,
  • Physical and health hazard information, and
  • First aid and firefighting measures.

If a facility opts to list the chemicals, it must group them by hazard categories and include each chemical’s name and any hazardous components as identified by the SDS. This is generally a one-time submission for each hazardous chemical. However, if a facility submits an SDS for a hazardous chemical and later discovers significant new information about it, the facility has to send an updated SDS to the SERC, LEPC, and local fire department.

Annual inventories

Under Section 312 of EPCRA, facilities must also submit an annual inventory (known as the Tier II inventory report) of the hazardous chemicals used or stored on-site at or above the reporting thresholds to the SERC, LEPC, and local fire department by March 1.

Facilities should check state regulations to confirm Tier II reporting thresholds, as they may be more stringent.

The Tier II inventory report requires information on the covered hazardous chemicals used or stored at the facility during the previous calendar year, including:

  • The locations of the chemicals,
  • The amounts of the chemicals, and
  • The potential hazards of the chemicals.

How do inventories support emergency planning?

Inventory reports provide information that’s vital to effective emergency response planning. Specifically, the inventories tell state and local officials about where hazardous chemical releases may occur and the risks that such releases may pose. Equipped with an accurate view of these hazards, officials can build and maintain effective emergency response plans for their communities.

Each participant in the emergency planning effort plays a distinct role:

  • Reporting facilities provide the SERCs, LEPCs, and local fire departments with the information they need to build effective response plans, such as the types of chemicals on-site and their quantities, locations, and possible hazards.
  • SERCs designate local emergency planning districts and appoint and supervise LEPCs. They also establish the inventory reporting procedures, review local emergency response plans, and process information requests from the public.
  • LEPCs use inventory reports to develop and update emergency response plans that address each community’s unique risks.
  • Local fire departments use the inventory reports to understand the potential chemical-related risks they may encounter at specific facilities. By knowing where the chemicals are and the potential hazards they pose, fire departments can improve personnel training and identify the most appropriate ways to respond to chemical emergencies.

Ultimately, reporting facilities aren’t just meeting a compliance requirement; they’re also supporting safer communities.

Key point: EPCRA’s hazardous chemical inventory requirements provide an example of effective collaboration between EPA, state and local officials, and facilities to prepare communities for chemical emergencies.

2026-03-27T05:00:00Z

Expert Insights: Four commonly overlooked categories in TRI reporting

Toxics Release Inventory (TRI) reporting can be tricky, even for seasoned EHS teams. Many facilities meet all the requirements but still miss chemicals that should be reported. Most oversights fall into four key categories. Here’s what they are and why they get missed, along with a few simple examples that show up in routine operations.

Newly added or updated TRI chemicals

The TRI list changes more often than many people realize. The Environmental Protection Agency (EPA) regularly updates it and recently added new per- and polyfluoroalkyl substances (PFAS) and even a full diisononyl phthalate (DINP) chemical category. When facilities don’t review these updates each year, they may keep using materials that now contain reportable chemicals without realizing it. For example, PFAS were expanded for Reporting Years 2024 and 2025, and the DINP category was added in 2023. These changes mean that everyday items like coatings, lubricants, and flexible plastics can suddenly trigger TRI thresholds.

“Otherwise used” chemicals

Not every reportable chemical is manufactured or processed. Many are simply “otherwise used,” including solvents, degreasers, cleaners, and maintenance chemicals. Facilities often overlook these because they aren’t part of the product mix, but they can add up fast. Even common shop chemicals, when used across a year, can exceed the 10,000-pound threshold and require reporting.

Coincidentally manufactured byproducts

Some chemicals are created unintentionally during normal operations. Ammonia may form during baking or heating steps, nitrates often appear in wastewater treatment, and metal compounds can be generated during welding, machining, or corrosion. These substances count as “manufactured” under TRI even if they weren’t intentionally manufactured. Examples like ammonia, nitrates, metal compounds, and diesel byproducts such as naphthalene and polycyclic aromatic compounds are regularly overlooked in TRI reporting because they’re easy to underestimate.

Impurities or additives in mixtures

Many reportable chemicals hide inside mixtures, oils, coatings, lubricants, and chemical blends. If a facility focuses only on the main ingredients, it may miss the smaller additive or impurity that’s actually subject to TRI reporting. These overlooked components can push a facility over a reporting threshold, even when the product is used in small amounts.

TRI oversights usually occur not because facilities ignore the rules but because chemicals show up in unexpected forms. Keeping an eye on updates, tracking cleaners and maintenance chemicals, monitoring byproducts, and checking mixtures closely can prevent the most common reporting mistakes.

The essential role of local governments in environmental regulation
2026-03-25T05:00:00Z

The essential role of local governments in environmental regulation

Counties and municipalities play a major role in protecting air, water, and land resources across the United States. Although federal and state agencies establish the overarching environmental framework, thousands of local agencies conduct the day to day permitting, inspections, and enforcement needed to make those rules work.

Local governments obtain regulatory authority largely through delegation. Federal environmental laws such as the Clean Air Act, Clean Water Act, and Resource Conservation and Recovery Act (RCRA) allow the Environmental Protection Agency (EPA) to authorize state agencies, which may then rely on local entities to administer components of these programs. In many states, local districts, counties, or municipalities operate significant environmental programs directly under state authority.

Common local level programs

A strong example of local involvement can be seen in air quality management. The National Association of Clean Air Agencies (NACAA) reports that 117 local air agencies participate in implementing federal and state clean air programs, highlighting how implementation frequently happens at the local level.

EPA’s AirNow directory lists numerous local air quality agencies across the country; Examples include air pollution control districts in California (such as the Sacramento Metropolitan Air Quality Management District, the San Francisco Bay Area Air Quality Management District, and the South Coast Air Quality Management District) as well as local air programs in Maricopa County, Arizona; Jacksonville, Florida; and Omaha, Nebraska. These districts conduct inspections, issue permits, investigate complaints, and maintain air monitoring networks, all of which support state and federal clean air requirements.

Local authority is also central to solid waste management, where many states rely heavily on counties and municipalities to manage planning, facilities, and enforcement. For instance, Washington State requires local governments to develop comprehensive solid and hazardous waste management plans that guide all waste handling and recycling programs within each county or city. These plans determine facility needs, outline reduction and recycling strategies, and shape local ordinances designed to meet state goals.

Additional examples appear across the country. Maryland’s Montgomery County, California’s Alameda County, and the District of Columbia all implement ambitious local waste diversion plans that supplement or exceed state requirements, demonstrating how counties and cities directly shape waste reduction and recycling policy. Likewise, South Carolina places most solid waste management responsibility on county governments, which must develop local plans, designate recycling coordinators, and report progress toward statewide goals.

Why is local involvement critical?

Local environmental regulatory authority matters because conditions vary widely across the nation. Counties and municipalities better understand their own industries, land uses, and growth patterns, allowing them to respond quickly to complaints, target outreach effectively, and adopt ordinances that go beyond state or federal minimums when necessary. Their proximity to communities makes local agencies essential partners in achieving environmental compliance and advancing public health protections.

As federal and state programs evolve, the role of local agencies continues to expand. Air quality districts, solid waste authorities, and local environmental health departments all demonstrate how counties and municipalities contribute directly to national environmental objectives.

Key to remember: With thousands of local agencies responsible for on the ground regulatory tasks, the strength and responsiveness of the United States’ environmental protection system depend heavily on the active engagement of local governments.

Toxics Release Inventory: Are you ready to report?
2026-03-24T05:00:00Z

Toxics Release Inventory: Are you ready to report?

Every year at the beginning of July, industrial facilities across the nation can breathe a collective sigh of relief — their annual inventories of toxic chemicals are complete! To ensure that your facility can be part of that celebration (and avoid a chaotic rush to meet the deadline), now’s the perfect time to start preparing for the Toxics Release Inventory (TRI).

The Environmental Protection Agency’s (EPA’s) TRI program requires industrial facilities to report waste management data on certain toxic chemicals they manufacture, process, and use by July 1 each year. Is your facility ready to report? Here’s an overview of the TRI program to help you answer this question.

Who’s covered by TRI reporting?

Generally, TRI reporting applies if the facility:

  • Is in a covered industry sector (40 CFR 372.23);
  • Employs 10 or more full-time-equivalent employees; and
  • Manufactures, processes, or otherwise uses a covered chemical or chemical category (372.65) in quantities above the threshold levels (372.25, .27, and .28) in a given year.

TRI tip: The TRI reporting year (RY) reflects the calendar year covered by the report, not the year in which you submit the report. For example, TRI reports for RY 2025 are due by July 1, 2026.

What’s covered by TRI reporting?

Facilities must submit the TRI Form R (or the streamlined Form A Certification Statement if eligible) for each TRI-listed chemical manufactured, processed, or used during the previous calendar year. The data covers chemical waste management activities (including releases to the environment) and any actions taken to reduce or prevent chemical waste.

Facilities usually report for each chemical:

  • The quantities of releases (routine and accidental),
  • Any releases caused by catastrophic or other one-time events,
  • The maximum amount on-site during the year, and
  • The amount contained in wastes managed on-site or transferred off-site.

What’s new for RY 2025?

The TRI reports for RY 2025 contain three differences from previous years:

  • The de minimis level for anthracene was lowered from 1.0 percent to 0.1 percent. Anthracene’s Chemical Abstracts Service Registry Number (CASRN) is 120-12-7.
  • More activity sub-use codes were added to the sub-use codes for “processing” and “otherwise use” activities.
  • Nine per- and polyfluoroalkyl substances (PFAS) were added to the TRI chemical list:
EPA registry nameCASRN
6:2 fluorotelomer sulfonate acid27619-97-2
6:2 fluorotelomer sulfonate ammonium salt59587-39-2
6:2 fluorotelomer sulfonate anion425670-75-3
6:2 fluorotelomer sulfonate potassium salt59587-38-1
6:2 fluorotelomer sulfonate sodium salt27619-94-9
Acetic acid, [(.gamma.-.omega.-perfluoro-C8-10-alkyl)thio] derivs., Bu esters3030471-22-5
Ammonium perfluorodecanoate3108-42-7
Perfluoro-3-methoxypropanoic acid377-73-1
Sodium perfluorodecanoate3830-45-3

How are TRI reports submitted?

Facilities must submit TRI reports electronically to the TRI-MEweb application on EPA’s Central Data Exchange (CDX). Even if a facility uses its own software to prepare TRI forms, it must upload and submit the forms to TRI-MEweb.

TRI tip: To complete the submission process on TRI-MEweb, you need to assign one user the Preparer role and another user the Certifying Official role. Ensure both users have added TRI-MEweb to their CDX user accounts.

TRI reports must be submitted to both EPA and the state. If your facility’s state participates in the TRI Data Exchange (TDX), TRI-MEweb will automatically send your report to the state. If your facility’s state doesn’t participate, you must send a hard copy of the report to the TRI state contact.

TRI tip: Use EPA’s “TRI Data Exchange” webpage to determine whether your facility’s state participates in TDX. As of March 2026, all 50 states participate in TDX. The District of Columbia doesn’t participate.

More TRI tips

Keep these things in mind when preparing your TRI reports:

  • You must submit a Form R (or Form A if eligible) for each TRI-listed chemical your facility manufactured, processed, or otherwise used above the threshold quantity.
  • TRI data is publicized. If a chemical’s identity needs to be protected, you have to submit substantiation forms to claim the chemical identity as a trade secret. EPA must approve the claims. Further, for each chemical with a trade secret claim, you have to mail hard copies of the substantiation forms and the corresponding Form Rs (or Form As if eligible) to EPA and the state.
  • EPA’s online GuideME platform offers comprehensive guidance for TRI reporting, including reporting forms and instructions, the TRI chemical list, and Q&As.
  • Contact the state environmental agency directly to confirm the submission method. EPA’s “TRI State Contacts” webpage contains state contact information.
  • Register your facility on CDX or ensure your facility’s CDX account is updated as soon as possible to avoid delays caused by technical issues.

Start preparing for TRI reporting now to give your facility plenty of time to gather data, complete the forms, and respond to unexpected issues that could arise. That way, your facility can breathe easily throughout the whole reporting season.

Key to remember: The submission deadline for TRI reporting is July 1, 2026. Make sure your facility is ready to report.

Final rule adds EtO emission limits to polyether polyol production
2026-03-19T05:00:00Z

Final rule adds EtO emission limits to polyether polyol production

The Environmental Protection Agency (EPA) finalized major changes to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyether Polyols (PEPO) Production (PEPO NESHAP).

Who’s impacted?

The final rule applies to facilities that produce polyether polyols and are subject to the regulations at 40 CFR 63 Subpart PPP.

What are the changes?

EPA’s final rule establishes ethylene oxide (EtO) standards, updates maximum achievable control technology (MACT) requirements, and revises other provisions for the PEPO NESHAP.

EtO standards

The final rule adds EtO emission standards for:

  • Equipment leaks,
  • Heat exchange systems,
  • Process vents,
  • Storage vessels, and
  • Wastewater.

The standards set emission limits and add requirements for monitoring and leak repairs.

MACT standards

Further, the final rule:

  • Requires heat exchange systems to use the more sensitive Modified El Paso Method (also known as the Air Stripping Method) for quarterly monitoring and a leak definition of 6.2 parts per million by volume of total strippable hydrocarbon concentration (as methane) in the stripping gas,
  • Lowers the MACT control thresholds for batch process vents and storage vessels,
  • Updates the requirements for internal floating roof storage vessels,
  • Lowers the threshold for equipment leaks for valves in gas/vapor service or light liquid service, and
  • Requires transfer operations with loading operations that exceed a certain threshold to use a vapor balance system or reduce emissions.

Other standards

EPA’s final rule also:

  • Requires 5-year performance testing for process vent control devices;
  • Revises flare monitoring and operational requirements to ensure they meet the MACT standards at all times when controlling hazardous air pollutant (HAP) emissions;
  • Adds new monitoring requirements for pressure vessels to verify that no detectable emissions exist;
  • Clarifies that any bypass of a pollution control device for closed vent systems is a violation;
  • Aligns the requirements for surge control vessels and bottoms receivers with the process vent standards;
  • Adds butylene oxide to the definition of “epoxide” and the HAPs list;
  • Expands “affected source” to cover specific post-reaction processes; and
  • Finalizes work practice standards for maintenance vents and equipment openings, storage vessel degassing, and routine storage vessel maintenance.

However, EPA didn’t finalize the 2024 proposed rule’s addition of a fenceline monitoring program for EtO or its changes to the continuous process vent standard.

What’s the compliance timeline?

Facilities subject to the PEPO NESHAP must comply with the changes by March 18, 2029, or upon startup, whichever is later.

Key to remember: EPA’s final rule for polyether polyol emissions makes significant changes, such as establishing EtO limits and revising MACT standards.

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Most Recent Highlights In Safety & Health

Key questions in industrial stormwater compliance
2026-03-16T05:00:00Z

Key questions in industrial stormwater compliance

Industrial stormwater compliance can feel complex for facilities balancing operations, employees, and shifting permit requirements. Many questions center on the federal general permit, pollution prevention plan expectations, monitoring, and what to do in everyday situations where stormwater risks arise. The following sections summarize core topics and practical concerns.

What is the current status of the federal 2021 Multi-Sector General Permit (MSGP)?

EPA issued the current MSGP in 2021, and it remains in effect beyond its February 28, 2026 expiration until EPA finalizes the proposed 2026 MSGP. Because the proposed 2026 permit is still under review, the 2021 MSGP continues to govern covered facilities.

Why has the proposed 2026 MSGP not taken effect?

EPA released the proposed 2026 MSGP in December 2024. Public comments, including an extended comment period ending May 19, 2025, must be reviewed before finalizing the permit. Since the existing MSGP remains valid until replaced, the 2021 permit stays in force while EPA completes its process.

What is a Stormwater Pollution Prevention Plan (SWPPP)?

A SWPPP outlines how a facility prevents pollutants from reaching stormwater. It identifies pollutant sources, control measures, inspection routines, monitoring steps, and staff training. A SWPPP must be written before submitting a Notice of Intent (NOI) for permit coverage and updated when operations or stormwater risks change.

What are the requirements for authorized state stormwater permits?

Most states issue their own industrial stormwater permits modeled on the federal MSGP. These permits typically require:

  • Preparation and maintenance of a SWPPP;
  • Inspections and monitoring (such as benchmark, effluent, or visual monitoring);
  • Corrective actions when control measures fail; and
  • Reporting through state online systems.

States may add requirements based on local conditions. When EPA updates the MSGP, states often revise their permits to align with new federal standards.

Who needs coverage under the MSGP?

Industrial facilities that discharge stormwater to waters of the United States generally need permit coverage unless they qualify for a no‑exposure exclusion. The federal MSGP applies in areas where EPA, not the state, holds National Pollutant Discharge Elimination System (NPDES) authority.

How does a facility obtain coverage?

To obtain coverage, a facility must:

  • Prepare and implement a SWPPP;
  • Put pollution controls in place, such as good housekeeping and spill prevention;
  • Identify sector specific requirements based on the permit; and
  • Submit a Notice of Intent through EPA’s online system.

The proposed 2026 MSGP includes updated forms and appendices, but current requirements remain based on the 2021 version until a new permit is published.

What monitoring is required?

Under the 2021 MSGP, required monitoring may include:

  • Quarterly visual assessments,
  • Benchmark monitoring in designated years, and
  • Effluent limitations monitoring for specific regulated discharges.

The proposed 2026 MSGP would expand per- and polyfluoroalkyl substances (PFAS) sampling, increase benchmark monitoring frequency, and add requirements for impaired waters. These changes remain pending.

What happens if benchmark thresholds are exceeded?

A benchmark exceedance requires the facility to investigate causes, improve control measures, and document actions in the SWPPP. The proposed 2026 MSGP would formalize additional implementation measures and reporting steps, but these wouldn’t apply until the new permit takes effect.

What about common real world compliance scenarios?

Industrial stormwater issues often arise from everyday activities. Consider these examples:

Employees’ vehicles leaking oil in parking lots

Leaks from employee vehicles can contaminate stormwater. While the MSGP does not regulate personal vehicles directly, the facility is responsible for any pollutants that enter stormwater from its property. Good housekeeping practices include absorbent stations, spill kits, drip pans, and designated parking areas with routine inspection.

Nonroutine outdoor maintenance

Temporary outdoor activities such as conducting maintenance, unloading equipment, or staging materials, can introduce pollutants. The SWPPP should address nonroutine tasks by requiring temporary controls like tarps, containment pads, or scheduling activities during dry weather. Documentation of these activities is also part of good recordkeeping.

Outdoor waste storage or scrap piles

These materials should be covered or sheltered, kept away from storm drains, and inspected frequently. If runoff contacts industrial materials, the discharge becomes regulated and must be managed under the permit.

These scenarios reinforce the need for strong housekeeping practices, staff training, and prompt corrective actions.

What documentation must facilities keep?

Facilities must maintain monitoring records, inspection logs, SWPPP updates, and corrective action reports. EPA may request these documents at any time. Appendices in the proposed 2026 MSGP preview updated forms, but the 2021 requirements remain in place for now.

What should facilities do while waiting for the 2026 MSGP?

Facilities should continue full compliance with the 2021 MSGP, track regulatory updates, and prepare for more frequent monitoring and PFAS sampling likely included in the 2026 permit. Reviewing proposed changes now helps facilities plan needed SWPPP updates in advance.

Key to remember: Industrial facilities covered under the 2021 MSGP or a state equivalent must continue following that permit until EPA issues a new federal MSGP. Staying informed, maintaining strong housekeeping, and keeping SWPPP documentation current remain the most effective strategies for compliance.

Toxics Release Inventory: Are you ready to report?
2026-03-13T05:00:00Z

Toxics Release Inventory: Are you ready to report?

Every year at the beginning of July, industrial facilities across the nation can breathe a collective sigh of relief — their annual inventories of toxic chemicals are complete! To ensure that your facility can be part of that celebration (and avoid a chaotic rush to meet the deadline), now’s the perfect time to start preparing for the Toxics Release Inventory (TRI).

The Environmental Protection Agency’s (EPA’s) TRI program requires industrial facilities to report waste management data on certain toxic chemicals they manufacture, process, and use by July 1 each year. Is your facility ready to report? Here’s an overview of the TRI program to help you answer this question.

Who’s covered by TRI reporting?

Generally, TRI reporting applies if the facility:

  • Is in a covered industry sector (40 CFR 372.23);
  • Employs 10 or more full-time-equivalent employees; and
  • Manufactures, processes, or otherwise uses a covered chemical or chemical category (372.65) in quantities above the threshold levels (372.25, .27, and .28) in a given year.

TRI tip: The TRI reporting year (RY) reflects the calendar year covered by the report, not the year in which you submit the report. For example, TRI reports for RY 2025 are due by July 1, 2026.

What’s covered by TRI reporting?

Facilities must submit the TRI Form R (or the streamlined Form A Certification Statement if eligible) for each TRI-listed chemical manufactured, processed, or used during the previous calendar year. The data covers chemical waste management activities (including releases to the environment) and any actions taken to reduce or prevent chemical waste.

Facilities usually report for each chemical:

  • The quantities of releases (routine and accidental),
  • Any releases caused by catastrophic or other one-time events,
  • The maximum amount on-site during the year, and
  • The amount contained in wastes managed on-site or transferred off-site.

What’s new for RY 2025?

The TRI reports for RY 2025 contain three differences from previous years:

  • The de minimis level for anthracene was lowered from 1.0 percent to 0.1 percent. Anthracene’s Chemical Abstracts Service Registry Number (CASRN) is 120-12-7.
  • More activity sub-use codes were added to the sub-use codes for “processing” and “otherwise use” activities.
  • Nine per- and polyfluoroalkyl substances (PFAS) were added to the TRI chemical list:

EPA registry nameCASRN
6:2 fluorotelomer sulfonate acid27619-97-2
6:2 fluorotelomer sulfonate ammonium salt59587-39-2
6:2 fluorotelomer sulfonate anion425670-75-3
6:2 fluorotelomer sulfonate potassium salt59587-38-1
6:2 fluorotelomer sulfonate sodium salt27619-94-9
Acetic acid, [(.gamma.-.omega.-perfluoro-C8-10-alkyl)thio] derivs., Bu esters3030471-22-5
Ammonium perfluorodecanoate3108-42-7
Perfluoro-3-methoxypropanoic acid377-73-1
Sodium perfluorodecanoate3830-45-3

How are TRI reports submitted?

Facilities must submit TRI reports electronically to the TRI-MEweb application on EPA’s Central Data Exchange (CDX). Even if a facility uses its own software to prepare TRI forms, it must upload and submit the forms to TRI-MEweb.

TRI tip: To complete the submission process on TRI-MEweb, you need to assign one user the Preparer role and another user the Certifying Official role. Ensure both users have added TRI-MEweb to their CDX user accounts.

TRI reports must be submitted to both EPA and the state. If your facility’s state participates in the TRI Data Exchange (TDX), TRI-MEweb will automatically send your report to the state. If your facility’s state doesn’t participate, you must send a hard copy of the report to the TRI state contact.

TRI tip: Use EPA’s “TRI Data Exchange” webpage to determine whether your facility’s state participates in TDX. As of March 2026, all 50 states participate in TDX. The District of Columbia doesn’t participate.

More TRI tips

Keep these things in mind when preparing your TRI reports:

  • You must submit a Form R (or Form A if eligible) for each TRI-listed chemical your facility manufactured, processed, or otherwise used above the threshold quantity.
  • TRI data is publicized. If a chemical’s identity needs to be protected, you have to submit substantiation forms to claim the chemical identity as a trade secret. EPA must approve the claims. Further, for each chemical with a trade secret claim, you have to mail hard copies of the substantiation forms and the corresponding Form R (or Form A if eligible) to EPA and the state.
  • EPA’s online GuideME platform offers comprehensive guidance for TRI reporting, including reporting forms and instructions, the TRI chemical list, and Q&As.
  • Contact the state environmental agency directly to confirm the submission method. EPA’s “TRI State Contacts” webpage contains state contact information.
  • Register your facility on CDX or ensure your facility’s CDX account is updated as soon as possible to avoid delays caused by technical issues.

Start preparing for TRI reporting now to give your facility plenty of time to gather data, complete the forms, and respond to unexpected issues that could arise. That way, your facility can breathe easily throughout the whole reporting season.

Key to remember: The submission deadline for TRI reporting is July 1, 2026. Make sure your facility is ready to report.

EPA finalizes emission standards for large municipal waste combustors
2026-03-12T05:00:00Z

EPA finalizes emission standards for large municipal waste combustors

On March 10, 2026, the Environmental Protection Agency (EPA) finalized emission regulations for large municipal waste combustors (LMWCs). The final rule revises nearly all emission limits for new and existing LMWCs.

Who’s impacted?

The final rule applies to LMWCs that combust more than 250 tons per day of municipal solid waste and are covered by the:

  • New Source Performance Standards (NSPS) for new LMWCs, or
  • Emission Guidelines (EGs) for existing LMWCs.

EPA established new subparts for the amendments at 40 CFR Part 60, including:

  • Subpart VVVV for the NSPS, and
  • Subpart WWWW for the EGs.

What are the changes?

Generally, stricter emission limits apply. For all LMWCs (new and existing), the rule revises the emission limits for:

  • Cadmium,
  • Hydrogen chloride,
  • Lead,
  • Mercury,
  • Particulate matter,
  • Polychlorinated dibenzodioxins and dibenzofurans, and
  • Sulfur dioxide.

For all new LMWCs, the final rule revises the emission limits for carbon monoxide (CO) and nitrogen oxides (NOx). The final rule also amends the CO and NOx limits for all existing LMWCs, except for the CO limits for two subcategories of combustors and the NOx limits for two subcategories of combustors for new municipal solid waste incinerators.

Other major changes include:

  • Removing certain exclusions and exemptions for startups, shutdowns, and malfunctions (requiring LMWCs to meet emission standards at all times);
  • Removing the NOx emissions averaging compliance alternative for existing LMWCs;
  • Amending recordkeeping and reporting requirements; and
  • Eliminating Title V operating air permit requirements for qualifying air curtain incinerators that burn only wood waste, yard waste, and clean lumber.

What’s the compliance timeline?

When EPA updates EGs, states must revise their State Implementation Plans (SIPs) to incorporate the changes. States have to submit revised SIPs by March 10, 2027. Once EPA approves the SIP, facilities with existing LMWCs must meet the new standards either within 3 years of the SIP’s approval date or by March 10, 2031, whichever is earlier.

New LMWCs must comply with the amended NSPS by September 10, 2026, or upon startup, whichever is later.

Key to remember: EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to the standards.

EHS Monthly Round Up - February 2026

EHS Monthly Round Up - February 2026

In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.

OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.

As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.

In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.

A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.

Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.

And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

2026-03-06T06:00:00Z

Colorado adds landfill methane emission regulation

Effective date: February 14, 2026

This applies to: Open and closed municipal solid waste landfills

Description of change: The Colorado Air Quality Control Commission added Regulation 31, which establishes new emission control and monitoring requirements for municipal solid waste landfills. Applicability is based on the landfill’s amount of waste it holds and methane emissions.

Significant changes implemented by Regulation 31 include:

  • Establishing a stricter emission control threshold than federal standards so that more landfills must install gas collection and control systems,
  • Mandating closed landfills with emission combustion devices to install biofilters when the devices are removed,
  • Expanding the methane monitoring requirements (allowing additional monitoring tools for identifying large emission sources) and allowing alternative monitoring technologies for periodic monitoring, and
  • Phasing in a ban on open flares to replace them with enclosed flares.

Related state info: Clean air operating permits state comparison

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Most Recent Highlights In Human Resources

2026-03-06T06:00:00Z

Louisiana amends Voluntary Environmental Self-Audit Program

Effective date: January 20, 2026

This applies to: Participating entities

Description of change: The Louisiana Department of Environmental Quality (LDEQ) revised the Voluntary Environmental Self-Audit Program rules in January 2026. Some of the changes include:

  • Adding definitions,
  • Changing the timeline to notify LDEQ of violations from 45 days within discovery to 30 days after the end of the audit, and
  • Requiring participants to submit monthly progress reports if corrective actions take longer than 90 days.
2026-03-06T06:00:00Z

Delaware revises 2026 NPDES general construction permit

Effective date: March 11, 2026

This applies to: Construction activities that discharge stormwater into Waters of the State

Description of change: The Delaware Department of Natural Resources and Environmental Control (DNREC) revised the Delaware National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP), which implements the DNREC Sediment and Stormwater Management Program.

It applies to construction activities that plan to disturb 1 or more acres (or activities that plan to disturb less than 1 acre but are part of a larger common plan of development or sale that will disturb more than 1 acre) that discharge stormwater to Waters of the State.

The DNREC made minimal changes to the NPDES CGP. The 2026 NPDES CGP will provide coverage for 5 years.

Related state info: Construction water permitting — Delaware

2026-03-06T06:00:00Z

California updates water diversion regulations

Effective date: February 1, 2026

This applies to: Water right holders who divert more than 10 acre-feet per year

Description of change: The California State Water Resources Control Board (SWRCB) updated the Water Measurement and Reporting Regulation (SB 88) with changes primarily affecting reporting requirements, such as:

  • Requiring diverters to submit data to the SWRCB using a template or the online reporting platform CalWATRS,
  • Requiring large diverters to submit data to CalWATRS instead of posting it to any public website,
  • Requiring diverters to identify and report measurement locations, and
  • Requiring diverters to submit their measurement methodologies.

Updated measuring and reporting requirements take effect on October 1, 2026.

EPA proposes electronic-only hazardous waste manifests
2026-03-06T06:00:00Z

EPA proposes electronic-only hazardous waste manifests

On March 5, 2026, the Environmental Protection Agency (EPA) issued a proposed rule to end the use of paper hazardous waste manifests and require waste handlers to use electronic manifests on the Hazardous Waste Electronic Manifest (e-Manifest) System to track all shipments of hazardous waste regulated under the Resource Conservation and Recovery Act (RCRA).

What are the proposed changes?

EPA proposes to “sunset” (i.e., phase out) the use of paper manifests and shift to using only electronic manifests (either fully electronic or hybrid) to track RCRA hazardous waste shipments.

The sunset compliance date would be 2 years from the publication date of a final rule. On and after the sunset compliance date, EPA would no longer accept paper hazardous waste manifests (image-only and data-plus-image submission types). In other words, regulated waste handlers would have to use fully electronic or hybrid manifests on the e-Manifest System for all hazardous waste shipments initiated on and after the sunset compliance date.

Who would be impacted?

The proposed rule would affect waste handlers involved in manifesting hazardous waste, including:

  • Generators,
  • Transporters, and
  • Receiving facilities.

Many of the proposed changes would align RCRA regulations with the shift to electronic-only manifesting and with the 2024 e-Manifest Third Rule’s changes. The proposed rule also contains technical corrections to import and export regulations.

Additionally, EPA’s proposed rule would add requirements for:

  • Very small quantity generators (VSQGs) managing episodic events,
  • RCRA hazardous waste transporters,
  • Healthcare facilities and reverse distributors subject to RCRA’s hazardous waste pharmaceutical requirements,
  • Certain polychlorinated biphenyl (PCB) waste generators,
  • PCB waste transporters, and
  • Hazardous waste treatment or storage facilities with standardized RCRA permits.

Examples of these requirements include:

  • Mandating specific waste handlers to register with the e-Manifest System;
  • Requiring VSQGs, healthcare facilities, and reverse distributors to submit data corrections to the e-Manifest System within 30 days of a request from EPA or an authorized state; and
  • Requiring hazardous waste generators and PCB waste generators to identify brokers on the manifest.

EPA will accept public comments on the proposed rule (Docket ID No. EPA-HQ-OLEM-2025-3456) through May 4, 2026.

Key to remember: EPA proposes to end the use of paper manifests and require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments.

EPA temporarily extends 2021 MSGP coverage
2026-03-04T06:00:00Z

EPA temporarily extends 2021 MSGP coverage

The Environmental Protection Agency (EPA) has issued an administrative continuance of the 2021 Multi-Sector General Permit (MSGP) and a No Action Assurance memorandum for industrial stormwater discharges regulated under the National Pollutant Discharge Elimination System.

The 2021 MSGP expired on February 28, 2026. However, because EPA hasn’t reissued a new permit to replace the expired permit, the 2021 MSGP remains in effect for facilities previously covered. Additionally, the No Action Assurance allows facilities without previous coverage to discharge industrial stormwater in compliance with the 2021 MSGP.

Who’s affected?

Facilities are required to obtain MSGPs for stormwater discharges from industrial activities in areas where EPA is the permitting authority, including:

  • Existing facilities (those that had active coverage under the 2021 MSGP), and
  • New facilities (those that didn’t obtain coverage under the 2021 MSGP before it expired).

What do existing facilities do?

The administrative continuance automatically applies to existing facilities that were actively covered by the 2021 MSGP before it expired. The facility’s coverage status should show “Admin. Continued” in the NPDES eReporting Tool (NeT-MSGP).

Facilities will remain covered by the 2021 MSGP until EPA issues a new MSGP and the facilities obtain coverage under the new MSGP. Until then, existing facilities should continue to comply with the 2021 MSGP requirements.

EPA will provide further guidance on renewing coverage when it issues the new MSGP.

What do new facilities do?

New facilities can’t obtain coverage under the MSGP until EPA issues a new permit. However, EPA issued a memorandum on February 27, 2026, establishing a No Action Assurance. The agency won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.

The No Action Assurance extends from March 1, 2026, to the new MSGP’s effective date.

Applicability

EPA’s No Action Assurance applies to facilities that:

  • Discharge stormwater on or after March 1, 2026 (but before the new MSGP’s effective date); and
  • Didn’t submit a Notice of Intent (NOI) for coverage under the 2021 MSGP before its expiration on February 28, 2026.

The assurance doesn’t apply to existing facilities that started stormwater discharges before February 28, 2026, without obtaining 2021 MSGP coverage.

Conditions

To be covered by the No Action Assurance, new facilities have to:

  • Meet the 2021 MSGP eligibility criteria,
  • Submit an NOI form (Appendix G of the MSGP) via msgp@epa.gov to notify EPA of their intention to operate according to all applicable 2021 MSGP requirements before discharging industrial stormwater, and
  • Comply with all applicable 2021 MSGP regulations, such as:
    • Developing and implementing a Stormwater Pollution Prevention Plan,
    • Installing and maintaining stormwater controls, and
    • Conducting site inspections and monitoring.

What’s next?

Once EPA issues the new MSGP, facilities planning to continue industrial stormwater discharges must submit a new NOI through Net-MSGP within 90 days of the new MSGP’s effective date to obtain coverage under the new MSGP.

EPA provides guidance for existing and new facilities on its “Administrative Continuance of EPA’s 2021 MSGP” webpage.

Key to remember: EPA has temporarily extended coverage under the 2021 MSGP for industrial stormwater discharges until the agency issues a new general permit.

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Activities

Activities

Following are some activities that can assist you in your safety efforts.

Start a safety bulletin board

Safety bulletin boards can be great ways to showcase your safety efforts and to increase awareness of important safety issues. Here are some ideas for items to feature on a bulletin board:

  • Injury rates, days without lost time, etc.
  • Workers’ comp statistics
  • List of safety committee members
  • List of emergency responders
  • Emergency information
  • Training sign-up sheets
  • New Safety Data Sheet updates
  • Safety committee meeting minutes
  • Cost of safety (Indirect and direct accident costs)
  • Risk matrix
  • Safety slogans
  • Contests/winning entries
  • “Caught in the act” (of working safely) (Can also ask employees to bring photos from home of something safety related they did, such as wearing PPE while mowing)
  • Pamphlets/handouts (on pertinent safety topics)
  • Small mirror with “We are all responsible for safety!” above it
  • Cartoons
  • Safety suggestion box/forms
  • Stretching/exercise illustrations
  • Seasonal safety information (e.g., summer = boating safety)

Use your smart phone for safety

With most smart phones these days coming equipped with digital cameras and computing capabilities, it’s a natural fit for safety professionals to utilize the devices on the job. There are countless uses for smart phones when it comes to safety, including:

  • Photographing accident scenes;
  • Documenting deficiencies during incidents/walkthroughs;
  • Calculations/conversions;
  • Noise-level measurement;
  • Showing safety videos (if your phone has an output feature to a television or projector); and
  • Accessing reference materials, to name a few.

Most smart phones will allow you to fairly easily upload your data and pictures to your computer or else access them through the “cloud,” making audit/inspection/investigation reports much easier to manipulate. There are also several apps (applications) pre-made to help you with various safety activities, including:

  • NIOSH Ladder Safety app — The National Institute for Occupational Safety and Health (NIOSH) recently announced the availability of a new Ladder Safety smart phone app. This new app uses visual and audio signals to make it easier for workers using extension ladders to check the angle the ladder is positioned at, as well as access useful tips for using extension ladders safely. The app is available for free download for both iPhone and Android devices. The new smart phone app provides three methods for proper ladder setup:
    1. Measuring Tool — Actually uses the phone’s positioning capabilities to guide the user through beeps.
    2. Body Method — Provides instructions based on where the palms/shoulders should be relative to the ladder.
    3. 4:1 ratio — Provides instructions for using the 4:1 ratio of ladder setup. To learn more and download the Ladder Safety app visit www.cdc.gov/niosh/topics/falls/.
  • Safe Lifting app from Oregon OSHA — If you’ve ever wondered “how much is too much” for a worker to lift, you’re not alone. Many supervisors and safety professionals have this same question. Given the frequency of lifting in workplace settings, it is surprising to many that OSHA does not set maximum weight limits or provide much guidance on what is a safe lift. To further complicate matters, many of the tools that have been available, such as the NIOSH Lifting Equation, can be complex. There is, however, a new tool developed by Oregon OSHA that allows users to quickly determine how much can be safely lifted. The tool walks users through an illustrated and interactive 3-step process:
    1. First, users select the beginning position of the lift;
    2. Next, users pick the lifts per minute and hours of lifting per day; and
    3. Finally, the results show the lifting weight limit (with an additional limit for more than 45 degrees of twisting during lifting.) To access the tool, visit https://osha.oregon.gov/OSHAPubs/apps/liftcalc/lift-calculator.html
  • OSHA Heat Stress app — The app allows workers and supervisors to calculate the heat index for their worksite, and, based on the heat index, displays a risk level to outdoor workers. Then, with a simple “click,” you can get reminders about the protective measures that should be taken at that risk level to protect workers from heat-related illness — reminders about drinking enough fluids, scheduling rest breaks, planning for and knowing what to do in an emergency, adjusting work operations, gradually building up the workload for new workers, training on heat illness signs and symptoms, and monitoring each other for signs and symptoms of heat-related illness. To download the app, visit www.osha.gov/heat/heat-app.

Uncover your safety culture

As a safety professional, you may have a solid understanding of how your workers feel about the company’s safety program. But, are you certain?

If you really want to find out what people think, meet with workers (usually best if done by department) for a lively discussion on the safety culture. Consider some of these topics:

  • Who is responsible for your safety: you, your coworkers, or your employer?
  • What has top priority: safety, production, or quality?
  • How should hazards be reported and corrected? How should suggestions for safety improvements be handled?
  • What is the purpose for accident investigations: to find blame or to prevent recurrence?
  • Who should enforce safety rules?
  • Is safety training conducted to improve safety or to meet regulatory requirements?
  • Should safety performance be included in performance reviews?
  • Who should have the final word on safety: management, the safety department, the safety committee, or the employee?

The objectives are to share opinions, establish the current status of the safety program, and identify potential directions for future safety efforts. One goal is to explain why policies are set up the way they are. Policies and procedures are easier to accept when they’re fully understood.

Make it clear that the exercise is just a discussion and that there’s no guarantee that any policies will be changed. But, agree to tell management about any strong concerns that come up. You might get feedback for improving or adding safety programs. Employees may mention training needs, they may give you ideas for how to better recognize safety efforts, or they may identify previously unreported hazards.

Start a program of measuring leading indicators of safety

Measuring safety is always a challenge. Typically, companies look at lagging indicators, such as injury rates. There is a recent push to shift to leading indicators, which refer to ways to measure safety performance prior to or independent of an accident or injury actually occurring; for example, how many safety inspections have been conducted, how many training sessions have been held, or how many employees attended safety meetings. The theory is that if you only look at the incident rate (lagging indicator), you might see that your company has 0 injuries over a given period of time. But, does that mean there were no unsafe behaviors? Does that mean the company was committed to safety? It might. But, it could also just be luck. So, the lagging indicators don’t show you the complete picture.

But, where do you start? Following is a listing of leading indicators that some employers are using:

  • Percent of departments conducting self-inspections
  • Number of safety committee meetings/percent attendance
  • Number of safety presentations
  • Supervisor training sessions
  • Time from hire to orientation/safety training
  • Percent of company goals/objectives that incorporate safety
  • Percent of purchasing contracts that include safety stipulations
  • Number of behavior-based observations/percent employee participation
  • Number of safety suggestions/percent employees
  • Number of safety committee projects/successes
  • Number of emergency drills/participation
  • Audit findings/corrective action time
  • Average time to act on safety suggestions
  • Percent training on-time

Start a “caught in the act” or “caught working safely” program

When employees work safely, acknowledging it — and/or rewarding it — can reinforce the behavior. Many employers utilize “caught in the act” or “caught working safely” programs where supervisors or safety professionals stop/approach a worker who is exhibiting a safe behavior and issue them a card. The cards can simply be an acknowledgment of the act, or they can be coupons for local restaurants, etc., or worth points that ultimately end up in a raffle, or that can be accumulated and spent (there are several commercial programs of this nature) or turned into vacation time. In addition, some employers have success photographing workers working safely and posting them on a bulletin board, to further drive home the message. A few tips to keep in mind:

  • Make the behaviors meaningful, not simply catching someone wearing required PPE. The behaviors should be those things that are above-and-beyond (that show a safety attitude) or that are problem areas that you are targeting (such as safe lifting or team lifting).
  • Don’t be stingy with the cards; be on the lookout so all employees have an opportunity to be “caught.”
  • It doesn’t have to come from the safety manager. Supervisors can play a great role in handing out the cards.
  • Get permission before posting photos on a bulletin board. Some employees may be uncomfortable with the recognition.

Participate in national safety observances

There are many safety observances that can be great opportunities to get your employees involved in safety, as well as helping your company show commitment to safety. These include:

  • North American Occupational Safety and Health Week (NAOSH) — Held in May each year; see https://nationaltoday.com/north-american-occupational-safety-and-health-week/.
  • Workers’ Memorial Day — April 28 each year. Workers’ Memorial Day is observed every year on April 28. It is a day to honor those workers who have died on the job, to acknowledge the grievous suffering experienced by families and communities, and to recommit ourselves to the fight for safe and healthful workplaces for all workers. It is also the day OSHA was established in 1971.
  • Workplace Eye Wellness Month — March each year. For more information, visit www.preventblindness.org.
  • Drive Safely to Work Week — In early October each year. For more information, visit www.trafficsafety.org.

Following is a calendar (broken down by quarter) to help you track some of the more popular safety-related observances. Often, the sponsoring organization will provide handouts, posters, presentations, and talking points several weeks in advance; visit their website for additional details. These observances can tie in nicely with safety bulletin board set-up.

National Safety and Health Observances (1st qtr)*
JanuaryFebruaryMarch
National Radon Action Month - www.epa.gov/radon/national-radon-action-month-information
National Drug and Alcohol Facts Week- teens.drugabuse.gov/national-drug-facts-week
American Heart Month - www.cdc.gov/heartdisease/american_heart_month.htm/
National Burn Awareness Week - https://ameriburn.org
National Nutrition Month® - www.eatright.org/NNM/
National Sleep Awareness Week® - www.sleepfoundation.org
National Poison Prevention Week - poisonhelp.hrsa.gov/
Flood Safety Awareness Week - www.weather.gov/safety/flood
National Safety and Health Observances (2nd qtr)*
AprilMayJune
National Work Zone Awareness Week - www.ops.fhwa.dot.gov/wz/outreach/wz_awareness.htm
Alcohol Awareness Month - https://recovered.org
National Facial Protection Month - www.ada.org

Air Quality Awareness Week - www.airnow.gov/aqaw/
Healthy Vision Month - www.nei.nih.gov/hvm/
National Physical Fitness and Sports Month - https://odphp.health.gov/news/202505/help-make-america-healthy-again-during-national-physical-fitness-and-sports-month
UV Safety Month - www.preventblindness.org
North American Occupational Safety and Health Weekhttps://www.naosh.ca/
National Hurricane Preparedness Week - www.nhc.noaa.gov/prepare/
National Safety Stand-Down to Prevent Falls in Construction - https://www.osha.gov/StopFallsStandDown/
Motorcycle Safety Awareness Month - https://www.nhtsa.gov/road-safety/motorcycles
National Safety Month - www.nsc.org
National Lightning Safety Awareness Week - www.weather.gov/safety/lightning
National Forklift Safety Day - http://www.indtrk.org/national-forklift-safety-day
National Safety and Health Observances (4th qtr)*
OctoberNovemberDecember
Home Eye Safety Month - www.preventblindness.org
Drive Safely Work Week - trafficsafety.org/dsww-site/safe-driving-is-serious-business/
Respiratory Care Week - www.aarc.org/resources/programs-projects/respiratory-care-week/
National Lead Poisoning Prevention Week - https://www.epa.gov/lead/national-lead-poisoning-prevention-week
Drowsy Driving Prevention Week- www.thensf.org/drowsy-driving-prevention/
Great American Smokeout - www.cancer.org
Safe Toys and Gifts Month - www.preventblindness.org
National Handwashing Awareness Week - www.henrythehand.com
*Some entries adapted from 2013 National Health Observances, National Health Information Center, Office of Disease Prevention and Health Promotion, U.S. Department of Health and Human Services, Washington, DC.

Hold a safety fair

Safety fairs can be a great way to get employees across the company involved and excited about safety. Often held in conjunction with wellness fairs, these events give employees a chance to participate both in presenting/exhibiting and also as fair-goers. Here are some tips for hold a fair:

  • Start early on with planning. You’ll want to allow at least six months, ideally a year. If possible, start a planning committee made up of department heads to get their buy-in.
  • Have a few contests (e.g., slogan, poster) prior to the fair, so you can use the fair to announce/recognize the winners.
  • Allow each department/team to come up with their ideas for the fair. Encourage them to make it safety related relative to what their department does.
  • Bring in outside help. Medical professionals for blood pressure checks, flu shots, etc. Police for “drunk glasses” and self-defense demonstrations. Fire departments for home safety tips.
  • Focus on wellness: blood pressure stations, scales, vision checks, etc., are all fairly easy to set-up.
  • Give safety-related prizes for contests/games; for example, flashlights, vehicle emergency kits, fire extinguishers, smoke detectors, premium safety glasses, etc.

Start/revise your incentive programs

If you have been looking to start an incentive program related to safety, or if your current incentive program is heavily tied to the occurrence of injuries/illness, the following are some tips and ideas to consider.

  • Focus on proactive measures NOT injury rates. OSHA looks unfavorably on incentive programs that could lead employees to hide injuries in an attempt to retain the incentive. OSHA prefers incentive programs that focus on employee involvement in safety activities, such as participation in a safety committee, attending safety training, or conducting inspections.
  • Decide what you want to accomplish. Whether it be general awareness or focus a specific issue, it’s better to have a focus on mind rather than just starting a program just for the sake of starting one.
  • Recognize all employees who meet the criteria. Random drawings can lead to bad feelings, particularly if an employee who generally isn’t regarded as caring much about safety wins the drawing. Also, when it comes to supervisor recognition (such as for “on the spot” recognition), make sure all employees who perform safely get recognized.
  • Consider individual rewards before group rewards. Individual awards allow employees to control their own destiny so to speak. Group awards often result in either a few employees ruining it for the rest, or a few employees riding the coattails of the other employees and getting the goals.
  • Stagger your rewards. It doesn’t have to be all or nothing. If an employee partly completes the objective (e.g., participates in 25 safety observations versus 30), give some reward.
  • Remember being safe IS already expected. So, make your rewards focused on those who earn a reward by going above and beyond.
  • Beware of the IRS! Incentive programs are likely considered taxable — particularly if you are dealing with monetary rewards, high-value personal property, or awards to a large percentage of employees. Consult with your payroll staff or tax professional. Also, consider reviewing the IRS publications 15-A, 15-B and Publication 525 (www.irs.gov).

What’s the prize?

When it comes to safety incentives, many employers choose to provide prizes. For reasons mentioned above, employers need to be very careful about this, as it can lead to under-reporting of injuries. However, there are many other options available to reward employees:

  • Accumulate money and donate to the local fire/emergency responders (or charities).
  • Give away safety-related items, such as fire extinguishers, car safety kits, etc.
  • Purchase something for the entire department or company (such as new TVs in the break room). These “reminders” will be around much longer than a few dollars for each employee that will be spent quickly.

Get supervisors onboard with safety: Through their Bonuses

There are many reasons line supervisors need to be involved in safety. In many ways they are the ones who can most directly influence an employees’ safe behavior. But, how do you do that? It can be challenging.

One popular approach is to tie safety into supervisors’ bonuses — for example, the year end bonus. Safety should not be the sole criteria for bonuses, but it should be an equal part. (As noted above, anytime safety and incentives and bonuses are tied together it’s a tricky subject. It may be a little more tricky for employees than for supervisors, but still you want to make certain that the bonus/incentive program is actually promoting safety and not hiding injuries.)

One company had success with an approach of utilizing five criteria for forming the supervisors’ year-end bonus. Two of five criteria were safety-related activities (one was the injury rate and the other one was different each year, but was a proactive, forward looking, positive objective that everyone could understand and affect, like “do X number of Job Safety Analyses (JSA) for the year” or do “X number of Safety Notifications.”).

This was very effective at getting supervisor’s attention, as you can find supervisors in any organization that are motivated by money. The company utilized a graded scale — so a target may have been to get 200 JSA’s done for the year, and if the supervisor got 50 done, they would get a percentage of the goal.

The second part of that criteria — the job safety analysis criteria that supervisors were graded on — is key. It’s a positive influence. It is recommended that employers have at least one of these in any sort of bonus program. If an organization only has the injury rate — which really is shaped by negative influence s — it is setting itself up for troubles. For starters, there will be the temptation to hide injuries. But beyond that, with the injury rate, if the employer experiences an injury on January 1 of the year, in some systems the goal is already lost. To have supervisors accept failure early in the year, they can actually become a negative influence on safety. So in addition to not doing anything to promote safety, these types of things can actually negatively affect safety. So employers must be careful and add positive bonus criteria that have an equal weight as criteria such as injury rates.

Departmental “charge-backs”

On the opposite end of the spectrum, some companies utilize negative incentives. For instance, they charge-back costs of accidents to the department. This can be tricky to do — and do fairly — but some companies have figured out ways to do it. Basically, the employers “charge” the department when accidents take place, which in turn directly impacts that department’s budget. The theory is that if you can make any sort of connection between accidents and profits, the department will quickly become more interested in preventing accidents. And, when accidents do happen, they’ll be quick to try to figure out WHY. And, this doesn’t have to be charging them for the actual costs of the accident, but could be some sort of pre-determined charge. Also, by charging the department, you aren’t singling out a supervisor.

Start your library of industry standards

Industry standards, such as ANSI standards, can be invaluable to safety professionals. Unfortunately, most require purchase (though some are relatively inexpensive). However, there are a few — even some very useful ones — that are free to download and/or view online. Look for free-to-view ANSI standards at https://ibr.ansi.org/.

NFPA® standards

You may think of NFPA standards as being related to fire safety only. But the fact is, many provide insight into many issues in your workplace, including emergency stops for machinery (NFPA 79), and storage height for empty pallets (NFPA 13). The NFPA makes their standards available to view for free online (no printing/copying/downloading, however). For more information, visit www.nfpa.org.

ITSDF standards

The Industrial Truck Standards Development Foundation (ITSDF) is the secretariat for many industry standards related to powered industrial trucks, such as forklifts. They make many of their standards available for free download. For more information, visit www.itsdf.org.

Local OSHA Area Offices

Your local or regional OSHA office will also likely have copies of many industry standards. They probably will not let you take the materials offsite, but should allow you to view them — you can then determine if the standard would be a benefit to you before purchasing.

Find hidden hazards

Workers may be regularly exposed to, and accept as normal, certain situations as part of doing their routine jobs. No one really recognizes the situations as hazardous because they’ve become so ingrained in the normal procedures that everyone anticipates and puts up with them. For example:

  • “When the machine cycles into the pressure release, it gets real loud for a little while;”
  • “Sometimes you have to pick defects out of the product — you’ll probably get a few blisters, but you can’t work the tool if you’re wearing gloves;”
  • “A lot of dust kicks up when we start filling a new bin;” or
  • “The floor gets kind of slippery after the sprayer’s been running awhile.”

An internal safety inspection may acknowledge the situations as normal operating procedures and move on without a second thought. After all, the procedures are likely to be intermittent and of short duration; and “we’ve always done it this way.” It isn’t easy to identify something as hazardous when it’s an obvious part of the daily routine. The inspectors don’t want to be nit-picky, either; they’re out there to find the real problems — the ones that cropped up since the last inspection.

When a normal occurrence is identified as hazardous, it’s easy to think it presents a low risk of serious injury.

However, the hazards may actually present more risk than everyone realizes. Exposures may have cumulative effects.

How do you identify them? A job safety analysis process would help. Other resources could include injury and first aid reports, employee interviews (especially with employees newly assigned to a job), and even worker complaints.

Once identified, the hard work of finding ways to eliminate or control the hazards begins. There isn’t always an obvious quick fix for these problems. Since these hazards likely result from long-established procedures, you’ll have to change attitudes along with equipment, materials, and procedures. Brainstorm with everyone involved to come up with the best solutions. After you get some of the hazards under control, the rest of them should be easier to address; and you’ll find it easier to identify the hazards hiding in the obvious.

Occasionally ask workers about these types of issues and be on the lookout for machines that are constantly being re-started due to jams, etc. Better to intervene now than to risk an actual injury/illness down the road.

Give your supervisors safety tools — without breaking the bank!

It’s no surprise that supervisors play a key role in keeping workplaces safe. They are the ones who know the work best, know the workers best, and are in the best position to ensure employees follow company safety policies and procedures. Naturally, supervisors need safety training — not just on safety-related topics, but also on how to effectively supervise and lead. Holding regular supervisor meetings can be a great way to get them involved. But, you don’t have to stop with just holding the meeting — if you give the supervisors a “take away” tool, it can really reinforce your training and serve as a call to action.

The good thing?

The tools do not have to be expensive to be effective. Consider the following take-away tools for your supervisors.

Inexpensive safety “tools”

  • Machine guard opening/distance-to-point-of-operation measuring tool/stick (these are available from many machine safeguarding suppliers/consultants)
  • Electrical — GFCI tester, tic tracer
  • Inspection checklist packet
  • Wallet cards — GHS pictograms, ladder setup, emergency numbers, forklift operator safe behaviors, etc.
  • Flashlight, smoke detector for home use

Review your PPE hazard assessment

If your facility has never conducted a baseline hazard assessment on the need for personal protective equipment (PPE) in your workplace, then certainly that should be a priority. But, even if there has been an assessment, if it has been many years since it was done, it may be a good idea to reassess to make sure changes in jobs or processes haven’t created new hazards for which PPE may be needed, OR to see if hazards have been eliminated over the years that would make PPE unnecessary for certain tasks.

How to do a PPE hazard assessment?

A baseline survey is a thorough evaluation of your entire workplace — including work processes, tasks, and equipment — that identifies safety and health hazards. A complete survey will tell you what the hazards are, where they are, and how severe a potential injury could be. Oregon OSHA provides the following suggestions for conducting your PPE hazard assessment:

  • Use a safety data sheet (SDS) to identify chemical hazards. An SDS has detailed information about a hazardous chemical’s health effects, its physical and chemical characteristics, and safe handling practices.
  • Review equipment owner and operator manuals to determine the manufacturer’s safety warnings and recommended PPE.
  • Do a job-hazard analysis. A job-hazard analysis (JHA) is a method of identifying, assessing, and controlling hazards associated with specific jobs. A JHA breaks a job down into tasks. You evaluate each task to determine if there is a safer way to do it. A job-hazard analysis works well for jobs with difficult-to-control hazards and jobs with histories of accidents or near misses. JHAs for complex jobs can take a considerable amount of time and expertise to develop. You may want to have a safety professional help you.
  • Have an experienced safety professional survey your workplace with you.

It is also a good idea to involve your employees, particularly for hazards they may be aware of, such as atypical jobs, that you might not catch on a regular walkthrough. In addition, employees can provide great input on how the PPE they are currently using works with the various tasks, as well as comfort. The PPE review should not only focus on whether PPE has been identified for a hazard/task, but also whether the current PPE is the correct PPE for the hazard and the best choice for the job.

PPE policies are often handed down from safety professional to safety professional, with the original baseline having been done decades ago. If that may be the case in your facility, it might be wise to conduct a comprehensive reassessment.

Caution — When hazard assessments are not done

The following provided courtesy of Oregon OSHA:

A worker died from complications resulting from severe burns on his face and hands when he tried to remove the bottom of a 55-gallon drum, which contained traces of motor oil, with a plasma cutter. The drum exploded. He shouldn’t have been using a plasma cutter on an oil drum until it had been cleaned and decommissioned; however, he might have survived with less severe burns if he had been using a face shield and appropriate protective gloves. He was wearing gloves, but they were made with fabric that melted on his hands from the heat of the explosion. His employer had not done a PPE hazard assessment.

In this example, the worker was using a plasma cutter without a face shield and synthetic gloves to cut open a 55-gallon metal drum that had not first been properly cleaned or decommissioned. An effective PPE hazard assessment would produce the following information for the task of using a plasma cutter:

  • Task: Using a plasma cutter.
  • Hazards: The plasma-cutting arc produces hot metal and sparks, especially during the initial piercing of the metal. It also heats the work piece and the cutting torch. Never cut closed or pressurized containers such as tanks or drums, which could explode. Do not cut containers that may have held combustibles or toxic or reactive materials unless they have been cleaned, tested, and declared safe by a qualified person.
  • Likelihood of injury without PPE: High
  • Severity of a potential injury: Life-threatening burns
  • PPE necessary for the task:
    • Body: Dry, clean clothing made from tightly woven material such as leather, wool, or heavy denim
    • Eyes and face: Safety glasses with side shield or face shield
    • Feet: High-top leather shoes or boots
    • Hands: Flame-resistant gloves

Start a hazard mapping process

Note: The following is adapted, with permission, from: Systems of Safety and Hazard Communication, First Edition – Written and Produced by The Rutgers Occupational Training and Education Consortium (OTEC) and New Labor (For the University of Medicine & Dentistry of New Jersey (UMDNJ), School of Public Health, Office of Public Health Practice).

A Hazard Map is a visual representation of the workplace that identifies where there are hazards that could cause injuries. For example, a hazard map might look at the following:

  • Physical hazards
  • Frequency of exposures
  • Levels of exposures
  • A specific chemical
  • Specific workers or job classifications most likely to be exposed

Hazard maps and worker experiences

Hazard mapping draws on what workers know from on-the-job experience. The hazard mapping approach works best when conducted by a small group of workers from the same department or work area.

Why hazard map?

Hazard mapping can help you identify occupational safety and health hazards. If your workplace has other ways or approaches for identifying hazards, they can be included in your hazard map.

The point of hazard mapping is to gather the knowledge about hazards from co-workers so you can work together to eliminate and/or reduce the risks of accidents and injuries.Hazard mapping respects the vast array of skill, experience and knowledge that workers have about their jobs.

Hazard mapping requires working together to identify, prioritize and solve problems.

One of the main components of hazard mapping is the system of codes/colors to be used when designating the identified hazards on the illustrated layout/representation of the area or facility. Following is a sample “hazard code key.” Note that the key is typically color-coded. In the print version of this manual, descriptors are shown alongside the circles indicating the color represented.

Hazard mapping labels

Examples of hazard mapping labels

Earlier in this section, a hazard code, as well as a "level of hazard" key was shown. Following is the combination of the two elements, which reveals how the hazard mapping process comes together. The numbers merge with the colored circles to have a specific meaning, e.g. "Electrical — Medium hazard" because of a blue circle (electrical) with a rating of "2" (Medium hazard).

Later in this section a sample layout using the code is applied to a home setting, which most are familiar with — it provides an easy way to illustrate the hazard mapping process.

Identifying areas of concern

Example of home hazard map

Summary

  1. A Hazard Map is a visual representation of the workplace where there are hazards that could cause injuries.
  2. Hazard mapping can help you identify occupational safety and health hazards.
  3. The point of hazard mapping is to gather the knowledge about hazards from your co-workers so you can work together to eliminate and/or reduce the risks of accidents and injuries.

Start a forklift behavioral observation program

Forklifts are prevalent in most operations. And, while OSHA requires a three-year evaluation, and general supervision in between, it can be beneficial to have supervisors conduct more formal frequent checks, and importantly reward operators for exhibiting the desired behaviors. The first step is to develop a list of critical behaviors that you want your operators to perform. Then work with your operators to ensure the behaviors are appropriate, and have them sign off that they will abide by them. Example behaviors include:

  • Slows down and sounds horn at intersections,
  • Looks in the direction of travel,
  • Wears seat-belt (if equipped),
  • Keeps hands inside the truck,
  • Drives a safe speed,
  • Stays in designated aisles,
  • Makes smooth and deliberate movements, and
  • Other behaviors that are appropriate for your organization (you might consider reviewing injury/incident records for appropriate root causes).

Each quarter have supervisors conduct unannounced observations of operators. When they notice the behaviors, supervisors should give the operator a small reward or recognition. Rewards can be given for individual behaviors, or when the operators has demonstrated all the desired behaviors or a set number.

Ensure temporary worker safety

Temporary staffing agencies and host employers share control over the employee, and are therefore jointly responsible for temp employees’ safety and health. It is essential that both employers comply with all relevant OSHA requirements. Host employers should:

  • Work with a reputable staffing agency. Ask to see their safety programs.
  • Arrange for a site visit with the temporary agency, so they can learn your operations, hazards, and need for work.
  • When feasible, exchange and review injury and illness prevention programs with the staffing agency.
  • Define the scope of the work in the contract with the staffing agency.
  • Assign responsibility for various aspects of compliance and safety. In some cases, the staffing agency will be in best position to provide the training or compliance, in others, it will be the host employer.
  • Make sure your job descriptions and expectations of roles are clearly written out and explained to temp worker candidates.
  • Only allow temporary workers to perform work within the scope of the contract.
  • Request and review the safety training and any certification records of the temporary workers who will be assigned to the job.
  • Keep injury and illness records, if supervising the temporary worker’s work.
  • Provide — either separately or jointly with the staffing agency — safety and health orientations for all temporary workers on new projects or newly-placed on existing projects.
  • Provide temporary workers with safety training that is identical or equivalent to that provided to the host employers’ own employees performing the same or similar work.
  • Train temporary employees on emergency procedures including exit routes.

Use your safety policy as a working part of your program

Most employers have a company safety policy outlining the organization’s philosophy on and commitment to safety. And, most companies inform employees of that policy at the time of hire or when the policy is implemented/changed. Sadly, for most companies, that’s where the policy ends. But, it doesn’t have to — a company safety policy can be a working and active part of your safety program.

For example, some companies have found it beneficial to print the company safety policy on a wall-sized banner that covers a wall in the shop floor. All employees sign the policy banner. Then, when a worker commits a safety violation (i.e., a violation of a well-communicated safety rule, or displays a general disinterest in safety), the company management takes the employee to the wall and points to the signature that the worker understands the policy and will work to uphold it.

The safety policy can also work as a recruitment tool or an aid in contracting — if it is displayed on the company’s external website. Most employers display their policy on the intranet, but not all display it for the larger community to see. With OSHA’s recent push to make negative information available via OSHA.gov, employers can be proactive in putting out positive safety information about their company.

Show upper management commitment to safety

What’s the best way to show upper management commitment to safety? Give them a voice! And, make that voice heard. How do you do that? The following activities, adapted from OSHA’s Safe + Sound initiative, can help:

Send an email blast

A good way to get management involved in safety is to encourage upper management to send an email blast. The email can focus on any number of safety topics, but should include a key message about your company’s commitment to safety and health. Use this email, or a series of emails, to:

  • Share why safety is important to management;
  • Show how injury and illness prevention is tied to organizational goals and values;
  • Provide recognition for positive outcomes from existing safety and health strategies; or
  • Highlight upcoming investments in safety and health.

Ideally, the email blast will begin on a Monday. You can also include a different health and safety message each day of the week. For example, one day’s email could feature your upcoming safety activities, another day could highlight safety resources available at your worksite (e.g., trainings, job hazard analysis forms), and the last day could summarize how you will use what you learned during the week to establish or improve your safety and health program.

Create a video

Record an interview with the head of the company talking about why safety is important to them and/or demonstrating how to properly operate equipment, use personal protective equipment, or conduct a task safely in your workplace. You could also invite workers to interview the boss about his or her commitment to safety. Have senior managers host a screening for all workers and show the video during new worker orientation. A simple video shot on any smartphone should suffice.

Write a company newsletter column or article

Start a senior manager column in your company’s newsletter to reiterate your commitment to safety in the workplace. This column could feature organizational goals for safety and health; recognize workers for their safety and health efforts and participation; or report the outcomes of analysis and action taken to address identified concerns or hazards. Ideally, managers will focus on the safety and health best practices they have used first-hand, in the first person. It is also very impactful when management tells a story about how safety (or a lack of good hazard controls) has affected them personally, and why it’s so important to them now.

Find or become a safety mentor

Does an organization you work with have safety efforts or results you would like to emulate? If so, ask the lead safety officer or a peer at that company to serve as your safety mentor. Likewise, if you have a successful safety and health program, consider mentoring a colleague at a supplier, customer, or related organization who is trying to get a fledging program underway. Mentorship is a way to improve your relationships and help strengthen both organizations.

To find mentoring opportunities, try the local chapter of your industry trade association, safety professionals’ organizations, or an OSHA Voluntary Protection Program (VPP) participant near you. Following are some groups that may be helpful:

Jumpstart your safety program in 10 easy steps

If you are not quite ready to implement a complete safety and health program, here are some simple steps you can take to get started. Completing these steps will give you a solid base from which to take on some of the more structured actions you may want to include in your program.

  1. Always set safety and health as the top priority. Tell your workers that making sure they finish the day and go home safely is the way you do business. Assure them that you will work with them to find and fix any hazards that could injure them or make them sick.
  2. Lead by example. Practice safe behaviors yourself and make safety part of your daily conversations with workers.
  3. Implement a reporting system. Develop and communicate a simple procedure for workers to report any injuries, illnesses, incidents (including near misses/close calls), hazards, or safety and health concerns without fear of retaliation. Include an option for reporting hazards or concerns anonymously.
  4. Provide training. Train workers on how to identify and control hazards in the workplace.
  5. Conduct inspections. Inspect the workplace with workers and ask them to identify any activity, piece of equipment, or material that concerns them. Use checklists, such as those in the Identify and Control Hazards section of this publication.
  6. Collect hazard control ideas. Ask workers for ideas on improvements and follow up on their suggestions. Provide them time during work hours, if necessary, to research solutions.
  7. Implement hazard controls. Assign workers the task of choosing, implementing, and evaluating the solutions they come up with.
  8. Address emergencies. Identify foreseeable emergency scenarios and develop instructions on what to do in each case. Meet to discuss these procedures and post them in a visible location in the workplace.
  9. Seek input on workplace changes. Before making significant changes to the workplace, work organization, equipment, or materials, consult with workers to identify potential safety or health issues.
  10. Make improvements. Set aside a regular time to discuss safety and health issues, with the goal of identifying ways to improve the program.

Use your OSHA 300 log to uncover hazards

Most workplace injuries and illnesses don’t just happen — they are usually predictable and preventable. That’s why OSHA calls them “incidents” instead of “accidents.”

While using a different word might seem like a small thing, it’s part of a huge shift underway. It’s a shift toward prevention — finding and fixing hazards before they lead to injury or illness. It’s like choosing between putting out fires after they damage people and property and making sure fires never start in the first place.

This is where your OSHA 300 log comes in. The log is not just a way to look at your past safety and health record, and it’s not just something for OSHA. It’s a powerful tool to help you identify hazards in your workplace so you can correct them and prevent future injuries and illnesses.

  • Think of the 300 log as part of your road map to finding and fixing hazards. For example: “Slip and fall” injuries might tell you that there are housekeeping-related hazards to correct or procedures to adjust.
  • A back injury might show you that there is a need for lifting equipment or better training in safe lifting techniques.
  • A needlestick injury might indicate that you need to improve your needlestick prevention program and/or implement safer needle devices.
  • A fall-related injury might indicate the need for improvements in fall protection or training.

You should examine the log regularly (at least annually), to look for trends. The log should indicate the types of injuries or illnesses that have occurred, their frequency, and the specific processes, activities, tasks, or equipment/material involved.

You can use this information to “find and fix” safety and health problems. [Note: Make sure to review injuries or illnesses among temporary or contractor employees you may have working onsite as well.] Using the 300 log to identify injury and illness trends is a good first step in identifying hazards and demonstrating management commitment to safety and health. Involving workers in reviewing the log and making recommendations for correcting hazards will make this step much more effective.

Start tracking SIFs (Serious Injuries and Fatalities)

Consider the following two scenarios:

  • A worker is doing some work on top of a railcar. He slips, but doesn’t fall. He suffers a strained back.
  • A worker is walking across the parking lot. He slips, but doesn’t fall. He suffers a strained back.

What we have are two work-related cases, likely to end up on the OSHA logs. Both would go down as back strains. The question is: How related are the two incidents? How related should the interventions be? If you went back through injury records and noticed you had two back strains in the past month, would it concern you that much? Should it?

It’s all about potential

Most would agree that in the situation with the railcar, there is a high probability that a serious injury COULD have occurred, if the worker had actually fallen off the railcar. That’s not to say that a worker couldn’t be seriously injured falling in a parking lot, but the probability is less.

That is the concept behind SIFs: Identifying, intervening, and tracking exposures, either actual or potential, where there is the liklihood of a serious injury or fatality.

Ask many plant managers how the safety program is doing and they’ll say “Good, our injury rates are as low as they’ve been in years.” Then, when a serious injury happens, they’re blindsided. Obviously you don’t want them to be blindsided, so you want to prevent as many serious injuries and fatalities as you can. But, also you want to make sure that management understands the true picture of what’s going on — and that involves more than just the recordable rate. You need to teach them about the SIF rate also.

What the data says

A quick look at the data shows that in 2016 the number of recordable incidents declined to near record-low numbers. However, in the same year, a total of 5,190 fatal work injuries occurred, the highest since 2008.

And, this is a common occurrence in companies who have analyzed their data — that is, the serious injury and fatality rate is not dropping at the same rate as the recordable rate.

So, what gives?

For many years, companies have focused most attention on lagging indicators, such as OSHA’s recordable incident rate, to assess how they are performing year to year.

Further, there is a long-held belief that reducing the number of incidents (recordables) would reduce the number of serious and fatal events (SIFs) (or as some have referred to them, FSI for Fatalities and Serious Injuries). However, data is showing that’s not the case. Focusing on the causes of minor injuries has no major correlation to the future occurrence of a serious or fatal injury.

For example, one company had a 10-year span of declining recordable incident rates, with the highest yearly rate around 6.0. The company is doing something right, right? When that company looked at their fatalities during that same period, they discovered there had been over 60. Most safety professionals would agree that 60 workplace fatalities over a 10-year span is not indicative of a perfectly functioning safety system.

Another issue is the focus on the “safety pyramid,” which has been used for years to correlate near misses and minor injuries to more serious injuries and fatalities, for example for every 1 major injury, there are 29 minor injuries, and 300 near misses. The theory was that focusing on near misses would automatically reduce the number of serious injuries.

Studies are showing that the triangle is not predictive because not all injuries or near misses actually have the potential to cause a SIF. This means that a reduction or intervention at the bottom of the triangle (i.e., near misses) will not necessarily correspond to an equivalent reduction in SIFs. Actually the number is closer to 20 percent.

What you can do

First, you have to target SIFs independently of other injuries and hazards. They are not equal in terms of their causes. Take for example an incident that could result in a minor cut. That may be the worst injury that could happen from the exposure. On the other hand, if you take a burn injury, maybe a slight shift in positioning or pressure could have taken the minor burn to a major one.

To do this, it’s important to create a list of SIF exposures in your work environment. You can start this by reviewing injury and near miss records for the past several years. How many could have been SIFs? What are the common elements of those that met that criteria?

Next, create a list of SIF exposures. These will vary from company to company, but common examples are:

  • Fall from greater than 6 feet
  • Electrical work
  • Confined space
  • High-pressure line rupture
  • Rigging/lifting-related incident
  • Mobile equipment contacting electrical line
  • Forklift/pedestrian contact
  • Material handling equipment falling from loading dock
  • Lockout/tagout or machine guarding failure
  • Motor vehicle incident
  • Non-routine task
  • Combustible dust

You should communicate this list with a campaign to kick off the new SIF focus. You should also target any new SIFs with aggressive hazard controls.

At the same time, you should create an initial SIF rate. This is calculated similarly to your incident rate or DART rate, only you substitute in actual and potential SIF incidents:

(Actual SIF incidents + Potential SIF incidents) * 200,000 / Total Hours Worked = SIF rate

From there, you evaluate every new incident to see if it fits into your new SIF criteria.

Start communicating your SIF rate annually to employees and management, so it is top of mind.

Set effective, SMART leading indicators

Good leading indicators are based on SMART principles, meaning they are Specific, Measurable, Accountable, Reasonable, and Timely:

  • Specific: Does your leading indicator provide specifics for the action that you will take to minimize risk from a hazard or improve a program area?
  • Measurable: Is your leading indicator presented as a number, rate, or percentage that allows you to track and evaluate clear trends over time?
  • Accountable: Does your leading indicator track an item that is relevant to your goal?
  • Reasonable: Can you reasonably achieve the goal that you set for your leading indicator?
  • Timely: Are you tracking your leading indicator regularly enough to spot meaningful trends from your data within your desired timeframe?

The chart below, adapted from OSHA’s Using Leading Indicators to Improve Safety Outcomes, demonstrates how to create a SMART leading indicator to address the issue that workers have not been attending monthly safety meetings. It walks through a good and bad example for meeting each SMART criterion using the leading indicator “Number of workers who attend a monthly safety meeting.”

Example Leading indicator: Number of workers who attend a monthly safety meeting
Goal: 97% worker attendance rate at monthly safety meetings
SPECIFICDoes your leading indicator provide specifics for the action that you will take to minimize risk from a hazard or improve a program area?
GOOD EXAMPLE
Workers will attend a safety meeting every month.
This is specific because it clearly identifies what the activity is and who needs to attend.
BAD EXAMPLE
Safety meetings will be held monthly.
This is not specific because it does not describe who needs to attend.
MEASURABLEIs your leading indicator presented as a number, rate, or percentage that allows you to track and evaluate clear trends over time?
GOOD EXAMPLE
Workers will attend a safety meeting every month.
This is measurable because you can track the number of workers that attend every month.
BAD EXAMPLE
Workers will attend safety meetings.
This is not measurable because it does not track a number, rate, or percentage with respect to your goal.
ACCOUNTABLEDoes your leading indicator track an item that is relevant to your goal?
GOOD EXAMPLE
Workers will attend a safety meeting every month.
This indicator is relevant to your goal because it asks workers to attend the meeting.
BAD EXAMPLE
Safety meetings for workers will be held monthly.
This indicator is not relevant to your goal because it does not specify that your workers would be asked to attend.
REASONABLECan you reasonably achieve the goal that you set for your leading indicator?
GOOD EXAMPLE
Workers will attend a safety meeting every month. Your goal is a 97% attendance rate.
Your 97% goal is achievable because it takes into account that you will not have a make-up meeting and workers missing work will not be able to attend on the day the meeting is scheduled.
BAD EXAMPLE
Workers will attend a safety meeting every month. Your goal is a 100% attendance rate.
Your 100% goal is not achievable because you know that some workers will occasionally miss work on the day the meeting is scheduled.
TIMELYAre you tracking your leading indicator regularly enough to spot meaningful trends from your data within your desired timeframe?
GOOD EXAMPLE
You decide to track meeting attendance monthly.
This is timely; because you track your meetings monthly, you can identify meaningful trends before the end of the year, which is when you wanted to analyze your data.
BAD EXAMPLE
You decide to track meeting attendance twice a year.
Because you only tracked two meetings, you cannot see any meaningful trends until at least the following year.

Designate safety advocates

Getting employees to support safety, or even just follow your written procedures, can be a challenge. Supervisor support and reinforcement is critical because they’re the day-to-day contact for employees. As a safety professional, you can’t reinforce safety with every employee every day.

One option could increase compliance while also help to alleviate the burden on supervisors. It involves identifying at least one employee in each team or department to serve as a safety advocate.Even supervisors who fully support safety need to create time for including that obligation among their other duties.

As a result, safety may not be something they devote time to every day.

Creating a program that identifies individual employees to serve as safety advocates, who promote compliance among their peers, could provide much-needed assistance and backup for a busy supervisor. In addition, other workers in the department may be more willing to listen to feedback from a coworker, since the reinforcement won’t seem like an authoritarian demand from management.

Identifying candidates

You’ll need volunteers for a safety advocate program, since the participants should willingly support all safety efforts.

However, supervisors should help identify likely individuals, based on performance and particularly seeking individuals who have the respect of their coworkers. Potential candidates might include individuals who:

  • Know someone (friend, family member, coworker) who was injured at work and would like to help others avoid that fate; or
  • Have a personal story regarding safety, whether they were injured or experienced a frightening near-miss incident.

Workers may have other relevant backgrounds, for example, military or EMT experience. The goal is finding individuals whose experience helps them understand that “safety is serious.” If you can identify a few individuals and present the safety advocate role as a development opportunity, you may be able to develop safety “deputies” and gain eyes, ears, and peer support for your programs.

Your company may want to provide incentives for participating, but someone who volunteers for a reward is not necessarily the best candidate. The ideal advocate is someone who participates out of a desire to help others.

Running the program

Once a few potential advocates are identified, they’ll need training on their expected roles. You can start small, since even one person from three or four different departments could have a substantial impact in their areas.

When developing training, don’t expect them to learn everything at once. Identify a few key issues that have been challenging in their work areas, and focus only on those areas to start.You can always add additional items in the future.

Training might cover a review of key safety issues, along with guidance on how to gently remind coworkers to follow the rules. For instance, ask them to share the experience that caused them to volunteer or to offer phrases to use such as, “Steve, I’m worried you’ll get hurt reaching past the guard. I have a friend who lost two fingers doing that.” If the potential advocates don’t have their own stories to share, give them examples from your own company’s experience or (if your safety record is strong) from other employers.

Although they’ll be telling friends and peers to “follow the rules” in a practical sense, their purpose is to deliver reminders and encouragement, not to threaten discipline or to report violations. Essentially, these advocates are leading from the middle by inspiring others through their actions, along with giving encouragement.

Keep your drivers safe

Texting while driving dramatically increases the risk of a motor vehicle injury or fatality. Employers need to make it clear to all workers that their company doesn’t require or condone texting while driving. It’s literally a matter of life and death.

Strong policies

  • Have a strong policy that prohibits the use of portable electronic devices while driving.
  • Establish work procedures and rules that do not make it necessary to text while driving.
  • Make safe driving an integral part of your business culture.

Vehicle and driver safety

  • Review and consider the safety features of all vehicles used, including late model vehicle safety systems (e.g., collision warning, driving control assistance).
  • Check the driving records of all employees who drive for work purposes.
  • Ensure vehicles are safe and properly maintained.
  • Encourage workers to focus on the road, avoid electronic distractions, slow down in work zones and not drive if fatigued.

Training

  • Provide continuous driver safety training and communication.
  • Train workers on driving distractions and to not solely rely on navigation and other advanced technology systems.
  • Instruct drivers to take extra precautions during inclement weather.
  • Ensure drivers know procedures, times and places for drivers to use phones and other technologies for communicating with managers, customers and others.
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