For anyone that has been following the e-manifest updates provided by the EPA, you know that the myRCRAid module within the RCRAInfo Industry Application system is not available in MA to date.
It finally appears that spring is on its way and there will be no more snow! Be prepared for spring by thinking about your PPE policy and consider any spring cleaning that could happen in your labs.
Consider taking a walk through of your labs with the sole purpose of looking at labeling. Keep an eye out for compliance with labeling of chemical bottles, aspiration flasks, tubes, samples, etc. How many instances of encountering a potential ‘unknown’ would you come across?
The Massachusetts State Sanitary Code, 105 CMR 480, requires generators of medical and biological waste to maintain a Medical/Biological Waste Record-keeping Log with various information related to the biological waste handling practices.
There seem to be more and more facilities operating with shared laboratory space these days. Some facilities have very clearly defined and distinct lab space for each company, and some facilities offer the opportunity to share bench space and equipment.
As companies evolve, relocations seem almost inevitable for many facilities. Relocating an entire facility, expanding to additional space, and downsizing all require involvement from EHS personnel early in the process.
The EPA is planning to launch their long anticipated Electronic Manifest System (e-Manifest) this June. There are a couple of tasks that regulated entities can do now in order to prepare for the roll out of this system.
As we are experiencing the third Nor’easter in a short period of time, this should serve as a good reminder to keep emergency planning documents up to date. Various regulations stipulate requirements for emergency planning, including OSHA regulations, the Massachusetts Comprehensive Fire Safety Code, and hazardous waste regulations.
On February 7, 2018, the Plumbing Board enacted a policy that adopts the ANSI Z-358.1 Standard for Emergency Eyewashes and Shower Equipment. The MA Uniform State Plumbing Code, 248 CMR 10.00, ANSI Z-358.1 standard, and OSHA regulations present several inconsistencies with requirements for the installation, operation, and maintenance of emergency eyewashes and safety showers.
If you are registered with the MA DEP as a Large Quantity Generator (LQG) of hazardous waste, do not forget that 2018 is a year when biennial reports must be filed. A new electronic reporting system called RCRAInfo Industry Application (RIA) must be used to file.
OSHA is strongly encouraging employers to join the trend towards incident prevention by identifying and addressing hazards before they lead to injury or illness. While employers are reviewing their OSHA 300 logs, they are asking companies to use these logs as a road map to finding and fixing hazards.
The Massachusetts Comprehensive Fire Safety Code, 527 CMR 1.00, was revised as of January 1, 2018. The revisions mainly update this code by adopting the 2015 edition of NFPA 1, with amendments specific to Massachusetts. The previous version was based on the 2012 edition of NFPA 1.
