Continuing with my take on the EHS lexicon, let's talk about one of the more ubiquitous and unwieldy parts of the EHS regulatory arena: Air. Whether you're talking about environmental or safety, air quality is an issue that is going to come up, and it can get sticky. How are the contaminant emissions from the facility stacks impacting the local community? And 'closer to home' how is air quality within the facility impacting worker safety and productivity?
These are the kinds of questions that are at the heart of the air arena. Of course, the regulations that have been constructed around these two questions sometimes get just a wee bit off course, but that's part and parcel to our command and control regulatory structure here in the US. But I digress.
Let's explore some of the language of air in the EHS world.
CAA: Clean Air Act. This was the legislation that would forever create the regulatory structure for air quality under which US companies currently struggle. The enacting regulations are lengthy and convoluted (like many environmental regs) and for any company that employs contaminant-emitting processes, this likely represent the biggest time-eater for their environmental staff.
Title V: refers to Title V of the CAA as amended in 1990. This resulted in the creation of a new operating permit structure for 'major sources' of air emissions. Under this structure, a source is major if it emits more than the threshold of any of the criteria pollutants. If a facility is a major source, it is required to obtain a Title V operating permit.
Ok, I just re-read that definition, and it spouts lingo left and right, here are some of the related definitions, to help clarify.
Let's start with the NAAQS: National Ambient Air Quality Standards. Ambient Air Quality standards, or criteria, are set for six common, or 'criteria pollutants:' Ozone, Particulate Matter, Carbon Monoxide, Nitrogen Oxides, Sulfur Dioxide, and Lead. The criteria are not stagnant, and change periodically. When they do, it throws everyone into a tizzy because it impacts what areas of the country are designated 'attainment' versus 'non-attainment' for the pollutant in question.
Attainment/Non-attainment is basically an evaluation of the air quality of an area (in Ohio, areas are designated attainment/non-attainment on a county by county basis, for the most part, other states may vary) against the criteria for the pollutant in question. If an area is 'attainment' for a pollutant it means that the area, on average, meets the NAAQS criteria for that pollutant. The states had to set up a huge network of monitoring stations in order to monitor for the criteria pollutants, and it is based on this data that designations are made.
When a new NAAQS standard is released, USEPA includes a deadline for each state to recommend designations within its boundaries. The state environmental regulatory agency evaluates all available monitoring data, and makes recommendations to the USEPA, with supporting evidence, for the designation of each area as either attainment or non-attainment for the new criteria. USEPA then reviews the information provided, and either agrees (making the designation 'official') or disagrees, and counters. This process is lengthy, and can lead to some back and forth between the state agency and the Feds.
It makes a BIG difference how an area is designated, because it impacts the definition of 'major source' as well as what type of permit a major source must pursue when installing a new emitting unit (or a new facility, for that matter). Companies have been known to locate plants based on the existing designation of an area, and this can be a huge consideration for new installations. As a result, NAAQS designation can have a profound impact on the economy of an area, particularly in heavily industrialized regions. I'm from Ohio. I know from whence I speak here. Economic impact has become a huge issue between OEPA and the Feds for precisely this reason.
Alright, again, I barely scratched the surface of the environmental regulations realted to air quality, but I really want to get into the safety regulations, because it's an important topic. indoor air quality (IAQ) in a facility is essential to worker health and safety, and is something that can generally be managed through installation and maintenance of appropriate ventilation equipment.
OSHA has published data on what they consider 'adequate' air quality for various chemicals and pollutants. There is a whole bunch of acronyms that go along with understanding this regulatory realm, and what 'limits' an employer should evaluate against is something I've heard debated more than once. Let's start with the OSHA 'official' limits, and then we'll discuss other sources that you should review.
PEL: Permissible Exposure Limits - OSHA has established over 500 PELs, mostly within 29 CFR 1910.1000 Table Z-1. These are regulatorily-required limits related to air quality within workers' breathing zones (also referred to as BZ). PELs are set mostly as 8-hour TWA or time-weighted average, limits. For evaluating this limit, air quality is measured continuously over a typical 8-hour shift, and the average exposure must be below the TWA limit. There are also PEL-STELs or short-term exposure limits, usually 15-minutes. For evaluation purposes, the continuous measurements are averaged in 15-minute increments, and for no 15-minute period may the STEL go above the limit, even if the TWA is below the limit. Some chemicals may even have a PEL-C, or ceiling limit established, which is an exposure limit over which a worker should NEVER be exposed.
NIOSH: the National Institute of Occupational Safety and Health is part of the Center for Disease Control & Prevention (CDC). This agency is responsible for conducting research and making recommendations on the prevention of workplace injuries and illnesses, and as part of that directive publishes the NIOSH Pocket Guide to Chemical Hazards (NPG). The NPG is updated far more frequently then the OSHA PELs. The 2005 NPG contains general industrial occupational exposure limits for 677 chemicals. The NIOSH limits, referred to as RELs (Recommended Exposure Limit), follow terminology analogous to that used by OSHA, with TWA, ST and C limits. The NPG is particularly useful, because it also provide a lot of other data on the chemical, such as its chemical properties, exposure routes, symptoms of exposure, etc. As a bonus, the entire guide is available on line, or in a downloadable format from the CDC. However, NIOSH is NOT a regulatory body, and can only make recommendations regarding exposure limits. These limits do not carry the force of law, though OSHA has been known to enforce them under the General Duty Clause.
ACGIH: American Conference of Governmental Industrial Hygienists (though I notice on their web page that they have dropped the 'governmental' part of the acronym, which I find curious). ACGIH also publishes their own set of occupational exposure limits. ACGIH is an entirely independent body, not related to the government. Their exposure limits, called TLVs or Threshold Limit Values, are developed by a body of independent IHs (Industrial Hygienists). There have been instances where the science behind thier limits has been questioned, and I am, by no means suggesting that you blindly accept the limits ACGIH publishes. However, though OSHA does not generally enforce these limits, it is always good to be aware of them. ACGIH is often at the leading edge of limit setting for occupational exposures, and if they choose to make a stink about a particular chemical, NIOSH and OSHA usually at least lend an ear, if not a hammer.
General Duty Clause: I realized, looking over the above, that I threw out a term that you hear bandied around in the OSHA realm a lot, and there's a good reason for it. The General Duty Clause is a catchall in the OSH Act of 1970, and states in part that "Each employer shall furnish . . . a place of employment which [is] free from recognized hazards that are causing or are likely to cause death or serious physical harm . . ." As an employer, therefore, it is not enough to comply with the OSHA standards, but you must take action to abate any and all recognized hazards. That is why it is important to be aware of what NIOSH and ACGIH have published as limits. Though fairly recent court rulings have put the brakes on OSHA issuing citations against NIOSH or ACGIH limits, note that states can, and often do adopt more stringent limits then OSHA (Particularly California, where CalOSH has been known to adopt ACGIH limits as law).
It is in every company's best interest to periodically test the air quality within their facility. Developing a routine Air Quality Evaluation protocol. Physical testing should be conducted at least once every couple years, or when there is a change in the facility operations. If your company is a small business, the state BWC (Bureau of Workers Compansation) will often offer help. I know in Ohio, at least at one point in time, BWC would actually come in and perform the testing for a small company, and provide the results with a preliminary evaluation. There are also consulting firms that offer this sort of testing, and can also provide aid for taking corrective measures where problems are found.
The key when designing any new industrial process is to ensure that proper ventilation and other safety measures are included in the design requirements up front to avoid the development of problems once the process goes into operation. However, as with any new process, it is important to test to ensure that everything is working as designed.
In addition, tracking results over time, and under different operating scenarios (summer versus winter, for example) can also help reveal conditions under which worker safety and health may be compromised, even with appropriate controls in place. Air quality is influenced by so many factors, that a one-time testing under controlled conditions is not enough to provide a clear picutre of the exposures a worker may experience.
I got a bit off-topic there toward the end. I will be back next week with the next installment of my take on the EHS lexicon. Again, if you have any particular areas you'd like covered, leave a comment and let me know.
Monday, April 5, 2010
Tuesday, March 30, 2010
The Language of EHS: Part 1
Every discipline creates its own nomenclature, develops its own acronyms, and specializes its own communication until it creates a language all its own. I have a friend who always asks me how my work is going and what I’ve been up to. I have to laugh, because I know she really wants to know, but her eyes glaze over as soon as I start talking.
I’ve seen quite a few lexicons for the EHS field, but thought I’d compile some of the terminology I hear most frequently, along with my own personal spin on their definition. Maybe this is something that will help those newbies, and not-so-newbies in the field that need an interpreter for the lingo!
These aren’t in any particular order, though I have tried to group Environmental terms together, and Safety & Health terms together.
EHS (alternatively, HSE, SHE, ES&H, etc.): All acronyms for the wonderful world of Environmental, Health and Safety. Every company comes up with their own acronym, depending on what they want to emphasize. Personally, I’m rather fond of the ‘SHE’ order, but that’s a personal thing. Some companies add Quality into the mix, some Security, so there are additional variations even in the letters included. Is it any wonder we have an identity crisis as a profession – I think not!
EPA (or USEPA, also known as the Feds – no, not the FBI, but close enough in our world): the United States Environmental Protection Agency. These folks set the directions for everyone. Regulations adopted by the states, can NOT be less stringent then the Federal regulations. And the Feds watch the states very closely. Trust me. I know. I live in Ohio, and OEPA (Ohio EPA) and the Feds have had some minor skirmishes. It’s interesting to watch the dynamics – forget about trying to truly understand them, because they’ll change again.
It’s also worth noting that each state adopts there own acronym for their environmental regulatory entity, and they aren’t all ‘EPA’. Ones I’ve seen include ‘DEP’ (Department of Environmental Protection, as in Pennsylvania); ‘DEM’ (Department of Environmental Management, as in Indiana), and ‘DEQ’ (Department of Environmental Quality, as in Michigan) – can you tell I’m a portal to the Midwest kind of girl?
RCRA: Resource Conservation and Recovery Act. This regulatory framework covers the disposal of solid and hazardous waste. The acronym ‘RCRA’ is often used synonymously with ‘hazardous’ when discussing waste, but the solid/non-hazardous wastes are addressed under this general framework as well. The primary federal hazardous waste regulations are found in 40 CFR 260-265. Note that 40 CFR is where most of the environmental regs are found, but in this business it isn’t the only CFR title you’ll need to be familiar with, so don’t put on blinders.
CFR: Huh, see how easily those acronyms creep in, and then you realize that not everyone knows what a CFR is. The CFR is the Code of Federal Regulations. If you don’t have the eCFR bookmarked, and you’re going to work in this field, do it now. No one, I repeat, no one, can keep all this in their head, and it changes periodically anyway. Even if you think you know it, check it. Also know your state regs. In Ohio, we’re governed by the OAC (Ohio Administrative Code) and the ORC (Ohio Regulatory Code). Know the code, check the code, love the code!
Back to RCRA . . . it’s worth exploring this realm a bit. Here are some of the (very) basics:
Solid Waste: A waste cannot be a hazardous waste unless it is first a solid waste. Now a solid waste is not to be confused with an actual ‘solid’ in the scientific sense. This is a lesson in READING THE DEFINITIONS because the definition of a solid waste is NOT intuitively obvious (in fact, it’s pretty convoluted and confusing). You will find that there are many things in the environmental arena that are not intuitively obvious. Always, always, always read the definitions for the title, chapter and part of the code you are reading!
Characteristic Hazardous Waste (also known as D-coded waste): These are wastes that exhibit, based on a standard test methodology, one of the four characteristics of a hazardous waste: Ignitability, Reactivity, Corrosivity and/or Toxicity. Each characteristic carries its own D-code (hence the term, D-coded waste). A waste can carry several different D-codes, and it is up to the Generator (the person who generated the waste) to ensure that it is properly tested and all applicable waste codes applied.
Listed Hazardous Waste (F-coded, K-coded, P-coded, or U-coded): This is where the haz waste regs get fun. F-coded wastes are wastes from non-specific sources. Generally speaking, F-coded waste likely also carry a D-code, but not always. K-coded waste are from specific sources (i.e., specific industrial processes), like a steel pickling line. Again, these can also, and often do carry a D-code. P- and U-coded wastes are for specific chemicals that are being discarded, and I’ve encountered them mostly when doing lab packs. The important thing to know about listed wastes is that once a waste is listed, it’s always hazardous, including any residue resulting from the treatment of it, unless it has gone through a delisting process. This is an ugly truth about listed hazardous wastes.
Mixture and Derived From Rule: Less a ‘rule’ and more part of a definition, this is often how I’ve heard it referenced. It relates to listed hazardous wastes, and it’s part of what makes them so difficult to deal with. Basically, if you mix a listed waste with another waste the whole mess carries the listed hazardous waste code, regardless of the resulting mixture characteristics. If you treat a listed hazardous waste, any residue that is left over from the treatment carries the listed hazardous waste code, regardless of the residue’s characteristics. See the definition of a hazardous waste for specifics.
Cradle to Grave: this is the extent of a Generator’s liability where hazardous waste is concerned. Basically, the concept is that once you generate a hazardous waste it is yours forever and ever – your liability for that waste never terminates. If it is buried in a landfill somewhere, and dug up 30 years in the future because it’s contaminating groundwater, you will still be footing the bill for dealing with it. This leads us into another, closely-related regulatory realm, CERCLA (see the next definition.
CERCLA (commonly know as Superfund): The acronym stands for the congressional act: Comprehensive Environmental Response, Compensation, and Liability Act. Superfund, as CERCLA is better known, is a huge, political morass of legalese that I hate to even get into. Suffice it to say that it earned its nickname ‘Superfund.’ If you’ve ever worked for a company that has been named as a PRP (Potentially Responsible Party) in a Superfund suit, you know what I’m talking about. It’s a behemoth, it’s ugly, and you don’t want to go there if you can help it. Really. Of all the lists out there the NPL (National Prioritites List) is not one any company wants to end up on.
The mantra of every environmental person worth their salt should be to MINIMIZE FUTURE LIABILITY. It’s the name of the game, because if you don’t, sometime, 20, 30 or more years down the road, it will come back to bite your employer right in the pocket book. Regardless of whether the bigwigs are interested in short-term goals, your view, as an environmental specialist, absolutely must be focused on the long-term liability of your actions.
CYA: Yeah, I know, everybody knows what that acronym means. Take it to heart. Document, document, document, if for no one else but yourself. I’ve been part of a discussion on LinkedIn recently discussing the documentation and investigation of incidents. “Our lawyer says not to do it.” Stupid, in every sense of the word in my opinion, whether you’re talking about issues related to employee safety, or environmental impact, or any other EHS issue that may come up.
Nobody is perfect – I’d argue that 100% compliance is an impossibility in the regulatory reality of the US. Just peruse the reams of regulations that are out there and tell me you can comply with the letter of the law at all times. But, that doesn’t mean that you don’t try to. Continuous improvement is the name of the game, and I think that’s why EHS ends up partnered with Quality so often. The goal should always to be to get a little bit better every day.
Alright, I know, I didn’t even scratch the surface of the environmental lingo, let alone OSHA. But this article is quite long enough. I’ll post another round of definitions in my next article. And probably another round after that. There is a LOT of ground to cover in EHS. If you are looking for a career that challenges you, this is the place to be.
If you have an area of particular interest that you would like me to address, please, leave a comment and let me know.
I’ve seen quite a few lexicons for the EHS field, but thought I’d compile some of the terminology I hear most frequently, along with my own personal spin on their definition. Maybe this is something that will help those newbies, and not-so-newbies in the field that need an interpreter for the lingo!
These aren’t in any particular order, though I have tried to group Environmental terms together, and Safety & Health terms together.
EHS (alternatively, HSE, SHE, ES&H, etc.): All acronyms for the wonderful world of Environmental, Health and Safety. Every company comes up with their own acronym, depending on what they want to emphasize. Personally, I’m rather fond of the ‘SHE’ order, but that’s a personal thing. Some companies add Quality into the mix, some Security, so there are additional variations even in the letters included. Is it any wonder we have an identity crisis as a profession – I think not!
EPA (or USEPA, also known as the Feds – no, not the FBI, but close enough in our world): the United States Environmental Protection Agency. These folks set the directions for everyone. Regulations adopted by the states, can NOT be less stringent then the Federal regulations. And the Feds watch the states very closely. Trust me. I know. I live in Ohio, and OEPA (Ohio EPA) and the Feds have had some minor skirmishes. It’s interesting to watch the dynamics – forget about trying to truly understand them, because they’ll change again.
It’s also worth noting that each state adopts there own acronym for their environmental regulatory entity, and they aren’t all ‘EPA’. Ones I’ve seen include ‘DEP’ (Department of Environmental Protection, as in Pennsylvania); ‘DEM’ (Department of Environmental Management, as in Indiana), and ‘DEQ’ (Department of Environmental Quality, as in Michigan) – can you tell I’m a portal to the Midwest kind of girl?
RCRA: Resource Conservation and Recovery Act. This regulatory framework covers the disposal of solid and hazardous waste. The acronym ‘RCRA’ is often used synonymously with ‘hazardous’ when discussing waste, but the solid/non-hazardous wastes are addressed under this general framework as well. The primary federal hazardous waste regulations are found in 40 CFR 260-265. Note that 40 CFR is where most of the environmental regs are found, but in this business it isn’t the only CFR title you’ll need to be familiar with, so don’t put on blinders.
CFR: Huh, see how easily those acronyms creep in, and then you realize that not everyone knows what a CFR is. The CFR is the Code of Federal Regulations. If you don’t have the eCFR bookmarked, and you’re going to work in this field, do it now. No one, I repeat, no one, can keep all this in their head, and it changes periodically anyway. Even if you think you know it, check it. Also know your state regs. In Ohio, we’re governed by the OAC (Ohio Administrative Code) and the ORC (Ohio Regulatory Code). Know the code, check the code, love the code!
Back to RCRA . . . it’s worth exploring this realm a bit. Here are some of the (very) basics:
Solid Waste: A waste cannot be a hazardous waste unless it is first a solid waste. Now a solid waste is not to be confused with an actual ‘solid’ in the scientific sense. This is a lesson in READING THE DEFINITIONS because the definition of a solid waste is NOT intuitively obvious (in fact, it’s pretty convoluted and confusing). You will find that there are many things in the environmental arena that are not intuitively obvious. Always, always, always read the definitions for the title, chapter and part of the code you are reading!
Characteristic Hazardous Waste (also known as D-coded waste): These are wastes that exhibit, based on a standard test methodology, one of the four characteristics of a hazardous waste: Ignitability, Reactivity, Corrosivity and/or Toxicity. Each characteristic carries its own D-code (hence the term, D-coded waste). A waste can carry several different D-codes, and it is up to the Generator (the person who generated the waste) to ensure that it is properly tested and all applicable waste codes applied.
Listed Hazardous Waste (F-coded, K-coded, P-coded, or U-coded): This is where the haz waste regs get fun. F-coded wastes are wastes from non-specific sources. Generally speaking, F-coded waste likely also carry a D-code, but not always. K-coded waste are from specific sources (i.e., specific industrial processes), like a steel pickling line. Again, these can also, and often do carry a D-code. P- and U-coded wastes are for specific chemicals that are being discarded, and I’ve encountered them mostly when doing lab packs. The important thing to know about listed wastes is that once a waste is listed, it’s always hazardous, including any residue resulting from the treatment of it, unless it has gone through a delisting process. This is an ugly truth about listed hazardous wastes.
Mixture and Derived From Rule: Less a ‘rule’ and more part of a definition, this is often how I’ve heard it referenced. It relates to listed hazardous wastes, and it’s part of what makes them so difficult to deal with. Basically, if you mix a listed waste with another waste the whole mess carries the listed hazardous waste code, regardless of the resulting mixture characteristics. If you treat a listed hazardous waste, any residue that is left over from the treatment carries the listed hazardous waste code, regardless of the residue’s characteristics. See the definition of a hazardous waste for specifics.
Cradle to Grave: this is the extent of a Generator’s liability where hazardous waste is concerned. Basically, the concept is that once you generate a hazardous waste it is yours forever and ever – your liability for that waste never terminates. If it is buried in a landfill somewhere, and dug up 30 years in the future because it’s contaminating groundwater, you will still be footing the bill for dealing with it. This leads us into another, closely-related regulatory realm, CERCLA (see the next definition.
CERCLA (commonly know as Superfund): The acronym stands for the congressional act: Comprehensive Environmental Response, Compensation, and Liability Act. Superfund, as CERCLA is better known, is a huge, political morass of legalese that I hate to even get into. Suffice it to say that it earned its nickname ‘Superfund.’ If you’ve ever worked for a company that has been named as a PRP (Potentially Responsible Party) in a Superfund suit, you know what I’m talking about. It’s a behemoth, it’s ugly, and you don’t want to go there if you can help it. Really. Of all the lists out there the NPL (National Prioritites List) is not one any company wants to end up on.
The mantra of every environmental person worth their salt should be to MINIMIZE FUTURE LIABILITY. It’s the name of the game, because if you don’t, sometime, 20, 30 or more years down the road, it will come back to bite your employer right in the pocket book. Regardless of whether the bigwigs are interested in short-term goals, your view, as an environmental specialist, absolutely must be focused on the long-term liability of your actions.
CYA: Yeah, I know, everybody knows what that acronym means. Take it to heart. Document, document, document, if for no one else but yourself. I’ve been part of a discussion on LinkedIn recently discussing the documentation and investigation of incidents. “Our lawyer says not to do it.” Stupid, in every sense of the word in my opinion, whether you’re talking about issues related to employee safety, or environmental impact, or any other EHS issue that may come up.
Nobody is perfect – I’d argue that 100% compliance is an impossibility in the regulatory reality of the US. Just peruse the reams of regulations that are out there and tell me you can comply with the letter of the law at all times. But, that doesn’t mean that you don’t try to. Continuous improvement is the name of the game, and I think that’s why EHS ends up partnered with Quality so often. The goal should always to be to get a little bit better every day.
Alright, I know, I didn’t even scratch the surface of the environmental lingo, let alone OSHA. But this article is quite long enough. I’ll post another round of definitions in my next article. And probably another round after that. There is a LOT of ground to cover in EHS. If you are looking for a career that challenges you, this is the place to be.
If you have an area of particular interest that you would like me to address, please, leave a comment and let me know.
Monday, November 9, 2009
OSHA's Hot Topic: Combustible Dust
I was reading an article relating OSHA's Top 10 Safety Violations for 2009 and it struck me that there was no mention of an issue that I am certain ranks pretty high on OSHA's list of problems: Combustible Dust.
Who hasn't heard about the Chemical Safety Board's investigations regarding combustible dust? Since then, there have been numerous additional incidents contributed to combustible dust. OSHA reissued its Combustible Dust NEP in 2008 and Congress got into the act with the Combustible Dust Explosions and Fires Act of 2008. I'd definitely say that combustible dust is a hot topic for OSHA. So why isn't it in OSHA's Top 10 list?
Well, until OSHA develops it's own standard for combustible dust, it is citing employers on combustible dust issues under the General Duty Clause. As a result, combustible dust is invisible to a top ten list. However, in their Combustible Dust NEP Status Report OSHA found over 4900 violations during inspections conducted pursuant to the NEP. If you are a safety professional, and you have not yet read this report - DO SO NOW.
I have a client that has spent the last year addressing the violations with which they were cited under this NEP. We had discussed the issue previous to the inspection, but they were confident that their dust was non-combustible. Wrong. If you don't know, have your dust(s) tested to find out if it is combustible. If it is, you better start evaluating the hazards in your workplace and taking appropriate corrective actions. Itis going to take time, so get started now, and do your homework. Costs are high for corrective measures, but the costs of an incident are higher.
So, if you checked over OSHA's top 10 list and decided you were in good shape, think again. Combustible dust is a hot topic, and one you need to seriously evaluate in your workplace. OSHA has a decent resource page on combustible dust. NFPA 654 is the primary standard for general industry, and until OSHA develops their own standard, is likely the place to go for guidance. To keep up with the latest on combustible dust, visit the Combustible Dust Policy Institute blog.
Have you reviewed your workplace for combustible dust hazards?
Who hasn't heard about the Chemical Safety Board's investigations regarding combustible dust? Since then, there have been numerous additional incidents contributed to combustible dust. OSHA reissued its Combustible Dust NEP in 2008 and Congress got into the act with the Combustible Dust Explosions and Fires Act of 2008. I'd definitely say that combustible dust is a hot topic for OSHA. So why isn't it in OSHA's Top 10 list?
Well, until OSHA develops it's own standard for combustible dust, it is citing employers on combustible dust issues under the General Duty Clause. As a result, combustible dust is invisible to a top ten list. However, in their Combustible Dust NEP Status Report OSHA found over 4900 violations during inspections conducted pursuant to the NEP. If you are a safety professional, and you have not yet read this report - DO SO NOW.
I have a client that has spent the last year addressing the violations with which they were cited under this NEP. We had discussed the issue previous to the inspection, but they were confident that their dust was non-combustible. Wrong. If you don't know, have your dust(s) tested to find out if it is combustible. If it is, you better start evaluating the hazards in your workplace and taking appropriate corrective actions. Itis going to take time, so get started now, and do your homework. Costs are high for corrective measures, but the costs of an incident are higher.
So, if you checked over OSHA's top 10 list and decided you were in good shape, think again. Combustible dust is a hot topic, and one you need to seriously evaluate in your workplace. OSHA has a decent resource page on combustible dust. NFPA 654 is the primary standard for general industry, and until OSHA develops their own standard, is likely the place to go for guidance. To keep up with the latest on combustible dust, visit the Combustible Dust Policy Institute blog.
Have you reviewed your workplace for combustible dust hazards?
Saturday, September 12, 2009
An Environmental Engineer's Journey
I apologize (to anyone who is listening) for the lengthy hiatus from this blog. Alas, life intrudes and I just haven't had anything interesting to blog about. That got me thinking: is there really anything about environmental work that is truly 'interesting?' Hmmm, why did I get into this field again?
I suppose it was vague ideas about making the world a better place to live . . . oh, that and it was definitely a leading edge career choice when I was in college. There wasn't even an 'environmental' engineering degree in those days. Sure you could get an 'environmental' subdiscipline with a Civil Engineering degree - which meant that basically you could design and run wastewater treatment plants - but that really didn't trip my trigger.
At the time, I was far more interested in environmental contamination and remediation. That could have something to do with growing up next door to the Chemical Corridor of Ashtabula, Ohio (once a booming part of the US war infrastructure), and having an NPL site almost in my back yard (Fields Brook). I suppose, too that the idea of carving out what I thought, in my young idealism, I needed in order to do 'real' environmental work held a certain appeal to my non-conformist side. I guess that's why I ended up in Agricultural Engineering at Ohio State (now called the Department of Food, Agricultural and Biological Engineering). At least there, they let me carve out my own path towards an engineering degree. I ended up in the soil and water engineering subdiscipline. For my MS, I did my thesis work on groundwater contaminant transport.
Of course, I was better off than my predecessors in the environmental field, who learned their job entirely on the fly (not to say that I didn't learn most of the real environmental work on the fly, mind you). Now there are degrees in Environmental Engineering. I've actually taken several courses toward a MS in Environmental Engineering through Findlay University. What I wouldn't have given to have some of these courses at the beginning of my career!
But back to my initial question, what is interesting in the Environmental field? Well, actually, looking back on my career, I've done some pretty neat stuff. My first job out of college was with a consulting firm. I got to do investigative drilling, and evaluate the results to determine the remediation path forward. When I moved back to Ashtabula County, Ohio, I got to be involved in some of the early work of the Ashtabula River Project, an innovative approach to cleanup coordination for the Ashtabula River Area of Concern (downstream of the Fields Brook NPL site) that has now been modeled in other places.
I worked at another facility where they treated hazardous waste (my introduction to a RCRA facility), and worked for several years on the program monitoring the contamination at old inactive units, and helping to develop the remedial action plans. Now, years later, as a consultant, I am actually witnessing those plans comes to fruition.
I also worked at a DOE decommissioning project. While I learned A LOT about environmental regulations while working on that project, I also vowed that I would NEVER work for the government again. Long story, probably mostly politically-incorrect, so I won't relate it here. While there, I did get to do some actual remediation project management work on one of the operable units associated with Fields Brook (not related to the DOE project, mind you). Completing the PCB cleanup, and certifying closure of the unit was probably one of my proudest achievements as an Environmental Engineer.
My foray into industrial environmental management was also frought with excitement, especially working for a reinforced plastic composites manufacturer (right around the time the Quad W MACT came out). There was a huge learning curve there, and the work was never really boring, but it was extremely demanding. If you've ever worked in industry, you know that in general it is always about efficiency. Unfortunately, I was doing the work of two people, with no end in site, and a sh**-load of 'new' work coming down the pike.
It definitely takes a dedicated person to become a career industrial environmental manager. I have since struck out on my own, and offer support services to those poor, over-worked, and generally over-looked environmental managers, many of whom are also tasked with managing the safety program. It is a career choice filled with challenges, and in the challenges are significant opportunities.
In fact, there are always new rules and regulations coming out, presenting new challenges, and new opportunities to demonstrate the rewards that environmental stewardship can have for a company. It is in facing these challenges head-on, and making the case for the business oppotunities present in the challenges that the excitement of an environemtnal management career reside.
Yes, the environemntal field is interesting - endlessly so!
So, does anyone else care to share their journey in the environemental field? I'd love to hear YOUR story!
I suppose it was vague ideas about making the world a better place to live . . . oh, that and it was definitely a leading edge career choice when I was in college. There wasn't even an 'environmental' engineering degree in those days. Sure you could get an 'environmental' subdiscipline with a Civil Engineering degree - which meant that basically you could design and run wastewater treatment plants - but that really didn't trip my trigger.
At the time, I was far more interested in environmental contamination and remediation. That could have something to do with growing up next door to the Chemical Corridor of Ashtabula, Ohio (once a booming part of the US war infrastructure), and having an NPL site almost in my back yard (Fields Brook). I suppose, too that the idea of carving out what I thought, in my young idealism, I needed in order to do 'real' environmental work held a certain appeal to my non-conformist side. I guess that's why I ended up in Agricultural Engineering at Ohio State (now called the Department of Food, Agricultural and Biological Engineering). At least there, they let me carve out my own path towards an engineering degree. I ended up in the soil and water engineering subdiscipline. For my MS, I did my thesis work on groundwater contaminant transport.
Of course, I was better off than my predecessors in the environmental field, who learned their job entirely on the fly (not to say that I didn't learn most of the real environmental work on the fly, mind you). Now there are degrees in Environmental Engineering. I've actually taken several courses toward a MS in Environmental Engineering through Findlay University. What I wouldn't have given to have some of these courses at the beginning of my career!
But back to my initial question, what is interesting in the Environmental field? Well, actually, looking back on my career, I've done some pretty neat stuff. My first job out of college was with a consulting firm. I got to do investigative drilling, and evaluate the results to determine the remediation path forward. When I moved back to Ashtabula County, Ohio, I got to be involved in some of the early work of the Ashtabula River Project, an innovative approach to cleanup coordination for the Ashtabula River Area of Concern (downstream of the Fields Brook NPL site) that has now been modeled in other places.
I worked at another facility where they treated hazardous waste (my introduction to a RCRA facility), and worked for several years on the program monitoring the contamination at old inactive units, and helping to develop the remedial action plans. Now, years later, as a consultant, I am actually witnessing those plans comes to fruition.
I also worked at a DOE decommissioning project. While I learned A LOT about environmental regulations while working on that project, I also vowed that I would NEVER work for the government again. Long story, probably mostly politically-incorrect, so I won't relate it here. While there, I did get to do some actual remediation project management work on one of the operable units associated with Fields Brook (not related to the DOE project, mind you). Completing the PCB cleanup, and certifying closure of the unit was probably one of my proudest achievements as an Environmental Engineer.
My foray into industrial environmental management was also frought with excitement, especially working for a reinforced plastic composites manufacturer (right around the time the Quad W MACT came out). There was a huge learning curve there, and the work was never really boring, but it was extremely demanding. If you've ever worked in industry, you know that in general it is always about efficiency. Unfortunately, I was doing the work of two people, with no end in site, and a sh**-load of 'new' work coming down the pike.
It definitely takes a dedicated person to become a career industrial environmental manager. I have since struck out on my own, and offer support services to those poor, over-worked, and generally over-looked environmental managers, many of whom are also tasked with managing the safety program. It is a career choice filled with challenges, and in the challenges are significant opportunities.
In fact, there are always new rules and regulations coming out, presenting new challenges, and new opportunities to demonstrate the rewards that environmental stewardship can have for a company. It is in facing these challenges head-on, and making the case for the business oppotunities present in the challenges that the excitement of an environemtnal management career reside.
Yes, the environemntal field is interesting - endlessly so!
So, does anyone else care to share their journey in the environemental field? I'd love to hear YOUR story!
Monday, July 20, 2009
Accounting and the Environment
“If all the accountants in the world were laid end to end – it would be a good thing.”
I used to tease my husband while we were in grad school with this quote. He was working toward a masters in economics, and at the time he was taking a series of honors accounting classes. His usual comeback was “I don’t want to be an accountant. I want to be the accounting boss. You have to understand what you manage.”
OK, entirely off-topic, right? Not really. There is a corollary to my husband’s philosophy: You cannot manage what you do not understand. Perhaps it is because I was in the throes of TRI (Toxic Release Inventory) report preparation that the topics of accounting and regulating came to mind. The vagaries of my interests tend to lead to some odd philosophical thoughts. This one caught my attention when it flitted through, and I decided that it was worth at least a brief essay attempt.
For those of you who do not know, TRI reporting is required every year for any industrial facility that ‘processes’ or ‘otherwise uses’ any of a list of 581 chemicals or 30 chemical categories above the reporting thresholds. If the threshold is exceeded, the facility must then account for what happened to that chemical through the facility processes that resulted in releases to each of the three environmental media:
• How much was emitted to the air?
• How much was released into surface water?
• How much was released to the land (i.e., managed in onsite waste management units or was sent off site for disposal)?
And my favorite: how much is projected to be released into the various environmental media in each of the next two years? Talk about polishing your crystal ball. After this past year, clients are quite uncertain about their production projections for the next month, let alone the next year!
Anyway, the data gathered is now submitted through the USEPA’s Central Data Exchange where it is compiled, validated, confirmed, and finally put out on TOXNET for perusal by the public. The TOXMAP feature is really quite interesting, and contains a phenomenal amount of data. You can, literally, see what is released in your back yard.
From an industry perspective, I know I anticipate the TRI reporting cycle with a dread akin to my annual visits to the OB/GYN (apologies to any male readers - you can insert dentist, if you prefer, but trust me, this analogy is more apt). It doesn’t matter how conscientious I am about my accounting practices, I always find something I’ve missed before. I spend so much time worrying about whether I’ve accounted for everything, I have little time, or energy, left over to actually make any headway on managing what I’ve measured, let alone understanding exactly why changes may have occurred.
Also, who selected the 581 chemicals and 30 chemical categories? Are these the worst, most toxic chemicals? Are there other chemicals that I should worry about? I always start with what I reported on the SERC (State Emergency Response Commission) report for the year, since its reporting requirements are much broader. But there isn’t always a lot of correlation, since the SERC reporting is based on the product, while the TRI reporting is based on specific chemicals, which may be in the products, some at low percentages. I also look at the air reporting, but it is done in even broader terms like volatiles and particulates (an exception being hazardous air pollutants, which generally do require individual emission tracking). In short, the TRI reporting really does end up being a process onto itself.
And while I applaud the collection and dissemination of data, I wonder, does it help to make our environment any cleaner? I fully adhere to the idea that you cannot manage what you do not understand (read as ‘measure’) but when has the measurement gone so far that we lose sight of the need to manage?
I finished the TRI reports for two clients on time (due July 1) – woot! For one client, I found a chemical that I missed last year. It’s a small percentage of a product, but they use enough of the product that the threshold was exceeded. We’ve made strides in reducing use of the nastier products at the facility. This particular one is really a fairly innocuous material, overall. It just happens to have a small percentage of a TRI chemical in it. Turned out that there was very little ‘released to the environment,’ but it was processed over the threshold so it has to be reported. Feels like the time I spent on this was a colossal waste.
I shouldn’t complain. This is what keeps me in business. But it irks me when it just seems like a bunch of busy work with no real benefit to the environment. Maybe that’s my general problems with the regulatory framework in the U.S. as a whole; a lot of busy work with little benefit; a self-sustaining bureaucracy that has lost touch with its intended purpose.
It is disheartening to me that picking up trash with my 4-year-old along the road feels more environmentally-relevant than performing my work as an environmental manager.
Go figure – literally.
I used to tease my husband while we were in grad school with this quote. He was working toward a masters in economics, and at the time he was taking a series of honors accounting classes. His usual comeback was “I don’t want to be an accountant. I want to be the accounting boss. You have to understand what you manage.”
OK, entirely off-topic, right? Not really. There is a corollary to my husband’s philosophy: You cannot manage what you do not understand. Perhaps it is because I was in the throes of TRI (Toxic Release Inventory) report preparation that the topics of accounting and regulating came to mind. The vagaries of my interests tend to lead to some odd philosophical thoughts. This one caught my attention when it flitted through, and I decided that it was worth at least a brief essay attempt.
For those of you who do not know, TRI reporting is required every year for any industrial facility that ‘processes’ or ‘otherwise uses’ any of a list of 581 chemicals or 30 chemical categories above the reporting thresholds. If the threshold is exceeded, the facility must then account for what happened to that chemical through the facility processes that resulted in releases to each of the three environmental media:
• How much was emitted to the air?
• How much was released into surface water?
• How much was released to the land (i.e., managed in onsite waste management units or was sent off site for disposal)?
And my favorite: how much is projected to be released into the various environmental media in each of the next two years? Talk about polishing your crystal ball. After this past year, clients are quite uncertain about their production projections for the next month, let alone the next year!
Anyway, the data gathered is now submitted through the USEPA’s Central Data Exchange where it is compiled, validated, confirmed, and finally put out on TOXNET for perusal by the public. The TOXMAP feature is really quite interesting, and contains a phenomenal amount of data. You can, literally, see what is released in your back yard.
From an industry perspective, I know I anticipate the TRI reporting cycle with a dread akin to my annual visits to the OB/GYN (apologies to any male readers - you can insert dentist, if you prefer, but trust me, this analogy is more apt). It doesn’t matter how conscientious I am about my accounting practices, I always find something I’ve missed before. I spend so much time worrying about whether I’ve accounted for everything, I have little time, or energy, left over to actually make any headway on managing what I’ve measured, let alone understanding exactly why changes may have occurred.
Also, who selected the 581 chemicals and 30 chemical categories? Are these the worst, most toxic chemicals? Are there other chemicals that I should worry about? I always start with what I reported on the SERC (State Emergency Response Commission) report for the year, since its reporting requirements are much broader. But there isn’t always a lot of correlation, since the SERC reporting is based on the product, while the TRI reporting is based on specific chemicals, which may be in the products, some at low percentages. I also look at the air reporting, but it is done in even broader terms like volatiles and particulates (an exception being hazardous air pollutants, which generally do require individual emission tracking). In short, the TRI reporting really does end up being a process onto itself.
And while I applaud the collection and dissemination of data, I wonder, does it help to make our environment any cleaner? I fully adhere to the idea that you cannot manage what you do not understand (read as ‘measure’) but when has the measurement gone so far that we lose sight of the need to manage?
I finished the TRI reports for two clients on time (due July 1) – woot! For one client, I found a chemical that I missed last year. It’s a small percentage of a product, but they use enough of the product that the threshold was exceeded. We’ve made strides in reducing use of the nastier products at the facility. This particular one is really a fairly innocuous material, overall. It just happens to have a small percentage of a TRI chemical in it. Turned out that there was very little ‘released to the environment,’ but it was processed over the threshold so it has to be reported. Feels like the time I spent on this was a colossal waste.
I shouldn’t complain. This is what keeps me in business. But it irks me when it just seems like a bunch of busy work with no real benefit to the environment. Maybe that’s my general problems with the regulatory framework in the U.S. as a whole; a lot of busy work with little benefit; a self-sustaining bureaucracy that has lost touch with its intended purpose.
It is disheartening to me that picking up trash with my 4-year-old along the road feels more environmentally-relevant than performing my work as an environmental manager.
Go figure – literally.
Tuesday, July 14, 2009
Nature Always Rebuilds
It's been awhile since I updated. Life intrudes periodically, and the beginning of summer is usually when that happens. Once school is out, all five kids are underfoot, and it makes it hard to get work done, let alone anything extra. We took a wonderful vacation up to the family cabin on Tilden Lake in Ontario, Canada, and I was just looking at some of the pictures, and a topic came to mind that I decided to run with: nature rebuilds.
You see, this is my general problem with us humans; we're less interested in preserving the environment than we are in preserving the status quo. The honest to God truth is, the environment will do fine without us. It can rebuild, readjust, and recover from just about anything we humans can throw at it. It might look a little different, it might be less hospitable to us, and perhaps to other species, but it will go on.
As a testament to the tenacity and resilience of nature, consider the accompanying pictures, taken by my children during a canoe ride on Tilden Lake.
The second photo shows another strategy: rebuilding on the skeleton of the past. Here a dead,
felled tree actually creates the start of a new island in the lake, providing a platform for new life. Honestly, how can you not be impressed by the ingenuity of nature itself.
So, admit it you measley human beings, what you're really interested in is preserving YOUR EXISTING ENVIRONMENT, not in preserving the environment itself. I mean, let's be honest with ourselves here, who doesn't believe that nature will come up with another species to take our place if we screw this up?
You see, this is my general problem with us humans; we're less interested in preserving the environment than we are in preserving the status quo. The honest to God truth is, the environment will do fine without us. It can rebuild, readjust, and recover from just about anything we humans can throw at it. It might look a little different, it might be less hospitable to us, and perhaps to other species, but it will go on.
As a testament to the tenacity and resilience of nature, consider the accompanying pictures, taken by my children during a canoe ride on Tilden Lake.
The first
photo shows the rocky terrain of the area we visit. Tilden Lake is located in mid-Ontario province, where there is precious little soil. Highways have to be blasted through the landscape (a true wonder of human tanacity and ingenuity - really, I don't totally disdain my own kind). You can see in this first picture that the trees literally cling to the sides on the rocks, their roots reaching deep into the rock, and breaking it up to create their own 'environment' for life. It is truly amazing to see where things grow in this beautiful wilderness.
photo shows the rocky terrain of the area we visit. Tilden Lake is located in mid-Ontario province, where there is precious little soil. Highways have to be blasted through the landscape (a true wonder of human tanacity and ingenuity - really, I don't totally disdain my own kind). You can see in this first picture that the trees literally cling to the sides on the rocks, their roots reaching deep into the rock, and breaking it up to create their own 'environment' for life. It is truly amazing to see where things grow in this beautiful wilderness.The second photo shows another strategy: rebuilding on the skeleton of the past. Here a dead,
felled tree actually creates the start of a new island in the lake, providing a platform for new life. Honestly, how can you not be impressed by the ingenuity of nature itself.So, admit it you measley human beings, what you're really interested in is preserving YOUR EXISTING ENVIRONMENT, not in preserving the environment itself. I mean, let's be honest with ourselves here, who doesn't believe that nature will come up with another species to take our place if we screw this up?
Tuesday, June 2, 2009
Web of Life and the Human Bias
I found the following explanation on an educational web site developed by the University of Illinois Extension:
Web of Life: An ecosystem is made up of all the living animals and plants and the non-living matter in a particular place, like a forest or lake. All the living things in an ecosystem depend on all the other things - living and non-living for continued survival - for food supplies and other needs. In some ways, the actions and reaction that take place within an ecosystem are like a spider web - when one strand is broken, the web starts to unravel. What affects one part of an ecosystem, affects the whole in some way.
I have always been fascinated by this analogy for an ecosystem. In fact, no defined ecosystem exists independent of another, so the analogy can be extended to encompass all life on the planet. NASA has even extended this concept beyond our planet to encompass space.
The one part of the description above that I take issue with is the broken strand analogy. A spider web, our apt web of life analogy, does not unravel if one strand is broken, or even if two strands are broken. Spider webs, and life, are much stronger, and more resilient than that.
The final statement, that what affects one part of an ecosystem affects the whole in some way, is very true. If something changes, the entire system must adjust, or adapt, to that change. Sometimes the adjustments are catastrophic for other parts of the system, sometimes beneficial, but the change itself is unavoidable.
This brings us to what I call the human bias in the web of life: avoidance of change. Change is an inevitable part of life. Ecosystems, like all living organisms, rise and fall, but life goes on. Perhaps not as we currently know it, but life does go on.
I look at it this way, if change did not occur, we humans, as a species, would never have come into existence. And try as we might, there is no way we can exist on this planet and not have an impact on the system of life in which we live. It is a fallacy to think we can.
Change is inevitable. Adapt or die - as a species this is our 'choice.' Trying to maintain the status quo is an impractical strategy. Instead we need to explore ways to bring our way of living into harmony with the ever-changing world around us.
So what's my point. Let's take the greehouse gas (GHG) regulatory-behemoth-in-the-making that is the current hot environmental topic. Is counting GHGs and creating a cap-and-trade system going to help us to live in harmony within our ecosystem? I have my doubts. It seems more about accounting than anything else (see the GHG calculators available everywhere online). I am pleasently surprised at the increasing focus on developing renewable energy sources - wave generators, wind farms, current turbines - these are all examples of human ingenuity tapping into the living energy available all around us. Maybe GHG regulation will accomplish something in moving us closer to the ideal.
I truly hope so.
Web of Life: An ecosystem is made up of all the living animals and plants and the non-living matter in a particular place, like a forest or lake. All the living things in an ecosystem depend on all the other things - living and non-living for continued survival - for food supplies and other needs. In some ways, the actions and reaction that take place within an ecosystem are like a spider web - when one strand is broken, the web starts to unravel. What affects one part of an ecosystem, affects the whole in some way.
I have always been fascinated by this analogy for an ecosystem. In fact, no defined ecosystem exists independent of another, so the analogy can be extended to encompass all life on the planet. NASA has even extended this concept beyond our planet to encompass space.
The one part of the description above that I take issue with is the broken strand analogy. A spider web, our apt web of life analogy, does not unravel if one strand is broken, or even if two strands are broken. Spider webs, and life, are much stronger, and more resilient than that.
The final statement, that what affects one part of an ecosystem affects the whole in some way, is very true. If something changes, the entire system must adjust, or adapt, to that change. Sometimes the adjustments are catastrophic for other parts of the system, sometimes beneficial, but the change itself is unavoidable.
This brings us to what I call the human bias in the web of life: avoidance of change. Change is an inevitable part of life. Ecosystems, like all living organisms, rise and fall, but life goes on. Perhaps not as we currently know it, but life does go on.
I look at it this way, if change did not occur, we humans, as a species, would never have come into existence. And try as we might, there is no way we can exist on this planet and not have an impact on the system of life in which we live. It is a fallacy to think we can.
Change is inevitable. Adapt or die - as a species this is our 'choice.' Trying to maintain the status quo is an impractical strategy. Instead we need to explore ways to bring our way of living into harmony with the ever-changing world around us.
So what's my point. Let's take the greehouse gas (GHG) regulatory-behemoth-in-the-making that is the current hot environmental topic. Is counting GHGs and creating a cap-and-trade system going to help us to live in harmony within our ecosystem? I have my doubts. It seems more about accounting than anything else (see the GHG calculators available everywhere online). I am pleasently surprised at the increasing focus on developing renewable energy sources - wave generators, wind farms, current turbines - these are all examples of human ingenuity tapping into the living energy available all around us. Maybe GHG regulation will accomplish something in moving us closer to the ideal.
I truly hope so.
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