There are many moving parts involved with the launch of the e-Manifest system, which occurred over the summer. Under the new regulations, receiving facilities must submit paper manifests to EPA within 30 days of receipt.
OSHA stipulates recording and reporting criteria for work-related injuries and illnesses in 29 CFR 1904.0-1904.11. There are various considerations to take into account when determining if an incident, injury, or illness is considered work-related and therefore needs to be evaluated for recording and reporting criteria.
Ensure your industrial discharge volumes are monitored on a regular basis to verify regulatory compliance. If you are the holder of a Low Flow/Low Pollutant wastewater discharge permit with the Massachusetts Water Resources Authority (MWRA), be sure to keep an eye on the average daily discharge volume to confirm that this permit remains applicable to your facility.
Have you conveyed the importance of accurate hazardous waste labels to all employees working in your labs? Waste labels should be used to create waste stream information profiles, which are used to generate hazardous waste manifests when waste is removed for off-site disposal.
The second annual OSHA Safe + Sound week has arrived! It is not too late to participate in this fun event. Take a moment to check out who else is participating and what activities they are holding.
When evaluating expansion space or entirely new space, be sure to evaluate the control areas. The Maximum Allowable Quantity (MAQ) of Hazardous Material per Control Area table in 527 CMR 1 establishes the limits for hazardous materials storage.
It started with pipet tip boxes, which were piling up in labs with many hoping to find a way of recycling them. Recycling was fully implemented for homes, but there were limited options for labs. The demand for implementing a recycling program for cardboard boxes and styrofoam was also high based on the high generation of these waste materials as well.
When facilities are established, safety manuals need to be put into place. Customization of the initial manuals can be challenging when the full scope of lab operations is not completely certain. As work evolves and work practices become firmly established, updates to the manuals may be necessary.
OSHA's Access to employee exposure and medical records standard, 29 CFR 1910.1020, stipulates the requirements for medical and exposure records. The requirements for how to keep these
records as well as the retention of these records is specified in this standard.
There will inevitably be a time when you are asked about how to transport a small quantity of a hazardous material to another location without going through the process of hiring a licensed hazardous material transporter. Some situations like the transport of samples to a collaborating facility may fall under the Materials of Trade classification
I hope everyone enjoys a safe, cool, and happy 4th of July week! It is definitely hot out there this week, and OSHA is encouraging employers to protect workers from heat-related illnesses and hazards.
Be sure to take advantage of the available resources that provide guidance on the implementation of e-manifests. From what I have been seeing and hearing, there are many questions surrounding this topic. EPA has issued a very useful e-Manifest Frequently Asked Questions summary that provides guidance on the logistics of the e-manifest system.
