tighe & bond breakfast seminar series 2016

Breakfast Seminar Series

Environmental, Health & Safety Regulatory Updates

IntroductionsSeptember 20 Taunton MassSeptember 27 Framingham Mass

Wayne E. Bates, PhD, PE, Principal Engineer

Agenda

Firm Overview

■ Multi-disciplinary Consulting Firm Founded in 1911■ Full Service Capabilities: 280 Person Staff■ Employee Owned■ 8 Offices in MA, CT, NH and NY

Geographic Coverage

Tighe & Bond Full Service Capabilities

Civil Engineering

•Dams & Levees•Geotechnical Engineering

• Infrastructure•Land Use Planning•Low Impact Design•Parking & Circulation•Site Planning & Design

•Transportation

Environmental Consulting•Brownfields•Demolition & Asbestos/ Hazardous Materials

•Environmental Permitting & Planning

•Fuel Storage•Health & Safety•Regulatory Compliance

•Site Assessment & Remediation

•Wetlands and Ecological Services

Building Services •Geotechnical Engineering

•Electrical & Mechanical Engineering

•LEED Green Design•Owner’s Project Manager

•Structural Engineering

Technology •3D Modeling•GIS

Sustainability•Energy & Resource Conservation

•LEED Green Design•Low Impact Design•Renewable Energy

Environmental Engineering•Drinking Water•Solid Waste•Stormwater•Wastewater

Today’s Presenters

Bill Potochniak, PE Dave Horowitz, PE, CSP Doug Stellato

Brian DayJeff Bibeau, REM, TURPWayne Bates, PhD, PE

Today’s Program

■ Regulatory Experts■ Actively engaged in professional societies■ Regulatory awareness/involvement ■ Reputation with regulators■ History of helping clients ■ Breadth or expertise and certifications


EH&S Regulatory Updates

September 20 Taunton MassSeptember 27 Framingham Mass

David P. Horowitz, P.E., CSP, Project Manager

Slideshare: dphorowitzTwitter: @dphorowitzYoutube: dphorowitz

Tanks & Hazardous Materials Storage

Agenda – Regulatory Updates

■ Tanks and Hazardous Materials Storage■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health

Regulatory Updates – Tanks (Above ground)

■ 502 CMR 5.0– Tanks >10,000 capacity

storing any fluid other than water

– Regulation Changes» April 2015» Consistency with national

standards– EPA– West Virginia– New York

» 5 year versus 1 year permits

» Inspectors propose test protocol

Regulatory Updates – Tanks (Underground)

■ MassDEP’s new system for managing UST data– Requires the person responsible for updating the information to

submit a Proof of Identification (POI) form to MassDEP.

– We recommend creating an account first, then submitting the form – otherwise it will go into a pile of “orphan” forms and will likely take longer to be processed.

Planning for 2017– Tanks (underground)

■ Included in the January 2015 UST regulation update– Sumps & Spill Buckets - hydrostatic or

pressure testing no later than 1/2/2017

» Spill buckets need to be retested every 5 years

» Sumps are one-time tests

– Compliance Certifications due 18 months after a Third Party Inspection.

Top Five Things Regulators Look For

1. 18 month mid-cycle for certification (USTs)– 30 Day Return to Compliance

2. Managing sumps & spill buckets (USTs)

3. A/B/C Operator coverage (USTs)

4. Financial Assurance (USTs)5. Proposed inspection

protocols (ASTs)

Questions




Doug Stellato, Project Compliance Specialist

Hazardous Materials


■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health

Regulatory Updates – Hazardous Materials

■ Tier II Reporting– 10,000 pounds– EHS substances– Tier II Manager

■ Chemical Control Laws– Alphabet Soup of Regulations– Updated Frequently

■ TSCA– June 2016 Update– Evaluate existing chemicals– Risk-based safety standard– Improved public transparency

Planning for 2017– Hazardous Materials

■ Tier II – March 1, 2017– Tier II Manager upload of facility– Consultant Access

■ CA Prop 65– Updated frequently

■ SVHCs– Updated in June and December

■ Supply chain driven– Products imported into Europe– Conflict Minerals

■ Preparing or reviewing Safety Data Sheets– Section 15 information

Planning for 2017– Hazardous Materials

■ TSCA– New Inventory rule

» Proposed by December 2016» New rule by mid-2017» 10 years of reporting

– New chemicals approved prior to going to marketplace– Mercury compounds export ban September 2016– New review process will rely on chemical use


■ #1 Accurate Inventory– Inaccurate amounts can lead to issues with other programs

■ #2 Site Diagram– Shows location of each reportable chemical

■ #3 Up-to-date SDS– Purchased and manufactured substances

■ #4 Testing Data– For chemical concentrations

■ #5 Maintain Import & Export Records– Is a broker being used?

Questions




Jeff Bibeau, REM – Principal Compliance Specialist

Toxics Use Reduction


■ Agenda– TURA Applicability– TUR Amnesty Expiration– New High Hazard Chemicals– 2017 TUR Action Items– Top 5 TURA Compliance Items

TUR Applicability

■ List of Reportable Chemicals■ Use, Process, or Manufacture > reporting

threshold■ 10,000 and 25,000 reporting threshold■ Annual reports due July 1st

■ TUR Plan Update due every 2 years July 1st

■ TURA fee due to DEP September 1st

TUR Amnesty

■ Mass DEP issued an enforcement amnesty effective April 9, 2015 thru June 30, 2016

■ Voluntary disclose past TUR reports (Form S) and plans

■ Companies maybe unaware of the TUR requirements or may have inadvertently missed reporting one or more chemicals

■ DEP will be conducting Desk-Top Audits

Regulatory Updates – TURA

■ 5 Chemicals that will be Higher Hazard Substances (HHS) reporting in 2017

■ HHS Threshold: 1,000 lbs for chemicals manufactured, processed, or otherwise used in a calendar year – dimethylformamide (CAS# 68-12-2)– toluene diisocyanates (listed as: 2,4-TDI [CAS# 584-84-9]; 2,6-

TDI [CAS# 91-08-7]; and TDI mixed isomers [CAS #26471-62-5])

– hydrogen fluoride (CAS# 7664-39-3) – cyanide compounds (Chemical Category N106) – 1-bromopropane (n-propyl bromide (CAS# 106-94-5))

Planning for 2017

■ Reporting Season

– File Form S reports to Mass DEP (July 1st)

– Issue TURA fee to Mass DEP (September 1st)


■ #1 Reporting– Review listed chemical usages (were reports filed)

■ #2 Planning– Review required TUR Plan elements and support documentation

■ #3 Plan Certification– Plan must be signed by a Certified Planner

■ #4 Report & Plan Documentation– Calculations, SDS, manifests, basis for assumptions

■ #5 Past Reporting Obligations– Review of past chemical usage

Questions




Jeff Bibeau, REM – Principal Compliance Specialist

Hazardous Waste


■ Hazardous Waste Determinations■ Hazardous Waste Management■ State Regulated Hazardous Waste■ 2017 Hazardous Waste Action Items■ Top 5 Hazardous Waste Compliance Items

Hazardous Waste

■ RCRA v. State of Massachusetts

■ Listed Wastes (A List in the Regulations) - or –

■ Characteristic Hazardous Waste exhibits one or more of the following characteristics:– Ignitability– Corrosivity – Reactivity– Toxicity

■ All businesses are required to perform a Hazardous Waste Determination on the waste they generate to identify whether or not that waste is hazardous.

– Initially and Re-evaluated Annually– Maintain a copy of these determinations

Hazardous Waste:The Nuts and Bolts

■ Large & Small Quantity Generator Status– LQG < accumulate HW for 90 days SQG < accumulate HW for 180 days

■ Labeling– All drums of HW must be properly labeled:

» CENTRAL ACCUMULATION AREA– Label must have accumulation start date

» SATELLITE ACCUMULATION AREA– Label should NOT be dated until drum is full– Only 1 drum per waste stream can be located in an area

■ Management– Keep drums closed at all times. Avoid the following:

» An open funnel is an open drum = penalty » An unlocked ring around a solids drum is an open drum = penalty

■ Disposal– Cradle to Grave

» Responsibility of proper disposal and recordkeeping is always on the GENERATOR, not the hauler

■ Universal Waste– Bulbs, Batteries, Ballasts, Thermostats, etc.

» Must be in a closed, labeled and dated container» Can accumulate for up to 1-Year

Hazardous Waste:The Nuts and Bolts

■ Good Condition■ Compatible with waste ■ Closed unless filling or dispensing■ Clear markings

– Content – Hazard Associated with the waste (waste oil = toxic)– Start Date Accumulation

Hazardous Waste:State Regulated

■ Very Small Quantity Generator of Waste Oil– Can accumulate 270 gallons indefinitely

■ Labeling– All drums of HW must be properly labeled:

» CENTRAL ACCUMULATION AREA– Label must have accumulation start date

» SATELLITE ACCUMULATION AREA– Label should NOT be dated until drum is full– Only 1 drum per waste stream can be located in an area

■ Management– Keep drums closed at all times.

» An open funnel is an open drum» An unlocked ring around a solids drum is an open drum

■ Disposal– Cradle to Grave

» Responsibility of proper disposal and recordkeeping is always on the GENERATOR, not the hauler

■ One Drip Rule– Saturated Rags and Wipes– One drop of oil from the rag = saturated rag = state regulated hazardous waste

Hazardous Waste:State Regulated

■ DEP policy #92-02-Waste Management Guidance for Industrial Wipers and Sorptive Materials Contaminated with Waste Oil

■ May be managed as a non-hazardous waste provided:– They do not contain free flowing oil (one drip rule)– They are used only for spills or leaks when collection of waste oil

is not practicable.

Hazardous Waste:The Manifest

■ If the hazardous waste shipment goes directly to a Massachusetts hazardous waste facility, the generator does not have to submit a copy to MassDEP. If the shipment goes directly to an out-of-state hazardous waste facility, the generator must submit a fully executed photocopy of Copy 3 to MassDEP within 30 days of receiving it from the designated facility. Send to:– MassDEP, Bureau of Waste Prevention

Attention: MANIFESTOne Winter Street, 7th FloorBoston, MA 02108

Planning for 2017

• Hazardous Waste Management = 100% compliance 100% of the time

• Weekly Inspections

• On-site accumulation limits (LQG=90 days; SQG=180 days)

• Submit copies of manifests for out-of-state shipments (30 days)


■ #1 Container Management– Label information, closed containers

■ #2 Generator Status– Monthly Generation limits and on-site accumulation time limits

■ #3 Manifests – Signed manifests received back from disposal facility

■ #4 Inspections– Documented inspections (time/date/full name)

■ #5 Central Accumulation Area– Line of demarcation, signage, emergency call list, fire

extinguisher

Questions




Timothy K. Kucab, CHMMDouglas A. Stellato

Air Quality


■ Agenda– Broad Regulatory Updates– Planning for 2017– Emergency Generators– Noise and Siting– Top 5

Broad Regulatory Updates

■ Plan Approvals– 1 Ton Actual De Minimis Exemption Records– CO2 Plan Approval Threshold

■ Source Registration– Small Source Exemption– Amend Reporting Deadlines

■ Engines and Turbines– Consistency with RICE NESHAP/NSPS

■ Solvent Metal Degreasing– High Precision Component Exemption

■ VOC and NOx RACT– Update RACT requirements (e.g., emissions

limitations, monitoring, recordkeeping)

Planning for 2017

■ Reporting Season– Semi-Annual / Annual Compliance Reports (January)– NESHAP/MACT Annual Updates (January, March)– Source Registration Reports (March, site specific)– Greenhouse Gas Reporting (March/April)

» Changes to MassDEP Reporting– Risk Management Program (Varies)

So You Operate a Generator…

New

Old

Emergency

Non-Emergency

Area Source

Major Source of HAP

Installation Date Generator Use Facility HAP

Emissions

Types of Requirements

■ Emergency– Monitoring – Recordkeeping – Operating Limitations– Fuel Requirements– Emissions Limitations

■ Non-Emergency– Controls – Performance Tests – Reporting– Notifications

Emergency Engines Nuts and Bolts

■ Emergency engines may operate for 100 hr/yr for any combination of the following:

■ maintenance/testing;■ emergency demand response ■ 50 hr/yr of the 100 hr/yr allocation can be used for:

– non-emergency situations if no financial arrangement

Emission Dispersion

■ “Good Engineering Practices”– No Shanty Caps or Egg Beaters– Vertical exhaust

■ Stack Height – Requirements May Vary– 10 Feet Above Nearest Roofline– If the stack is lower than 1.5 times the building height or lower

than the height of a structure that is within 5L of the stack (5L being five times the lesser of the height or maximum projected width of the structure) – MODELING REQUIRED

■ Other states have additional requirements

State Requirements

■ Individual Permits■ General Permits■ Permit-by-Rule■ Certifications

Siting Considerations

Siting Considerations

■ Impacts from Project– Sound Levels– Visual Impacts

Generator Housing

Generator Exhaust

Residence less than 25 feet away

Noise Considerations

■ Noise Policies – Sound Levels– Pure Tones

■ Zoning Specific Noise Provisions

■ Sound Level Monitoring

– Pre-Construction– Post-Construction– Ambient


■ #1 Recordkeeping– Every Permit Condition

■ #2 Reporting– Don’t Miss Deadlines

■ #3 Inspections– Document Required Inspections

■ #4 Non-Delegated Regulations– Local / State / Federal

■ #5 General Duty– Facility Condition

Questions




Bill Potochniak, P.E. Project Manager

Water & Wastewater

Agenda – Water & Wastewater

■ Review of regulatory updates■ Review of some regulatory considerations■ Planning for 2017■ What regulators are looking for■ Questions

Regulatory Updates

■ Stormwater (MS4)■ Legionella in Water Systems

Stormwater (MS4)

■ April 2016 – EPA adopted the new MS4 permit– Applies to local communities – Also applies to state-owned facilities

» Hospitals, colleges, universities

■ Effective July 1, 2017■ NOI Due September 29, 2017■ SW Management Plan Due July 1, 2018■ Challenges

– Need detailed site plans (GIS) – May require retrofit– Requires stormwater and outfall plan

Legionella in Water Systems

■ ASHRAE Standard (188)■ Establishes risk management requirements for building water

systems■ Not a regulation but a standard■ Finalized in 2015 ■ Challenges

– Look at hazardous areas (humidifiers, cooling towers) – Determine control locations– Monitoring– Record Keeping

■ ASHRAE also issued a guideline (referenced in 188) which provides useful information to help minimize legionella contamination

Regulatory Considerations

■ 314 CMR 12 – O&M & Pretreat. Standards■ 310 CMR 22.22 – Cross Connections■ 40 CFR 112– Oil Storage■ 257 CMR 2- Grading and Staffing of WW

Systems


■ 314 CMR 12 – O&M & Pretreat. Standards– Ensure O&M Plans contain the10 requirements– Ensure that treatment systems have been designed and

plans stamped by a PE– Ensure that treatment systems have been designed to meet

standards outlined– Review the federal categorical standards outlined in 40 CFR


■ 310 CMR 22.22 – Cross Connections– Ensure that backflow preventers are present on water lines

and are inspected twice a year– Have spare parts kits available


■ 40 CFR 112– Oil Storage– Storage of more than 1,320 gallons of oil aboveground– In containers 55 gallons or larger– Includes vegetable oils (kitchens)– Includes transformers (even if you don’t own them)– Annual training is required– Routine visual inspections– Updates every five years (or if major changes)


■ 257 CMR 2 – Grading & Staffing– Ensure that your system is Graded with the DEP

http://www.mass.gov/eea/docs/dep/water/approvals/year-thru-alpha/w/wtpgrade.pdf

– Grading is based on the unit operations and system complexity, if changes to system must re-grade

– Staffing plans must be updated when operators change



Planning for 2017

■ Develop capital improvement plans for wastewater upgrades

■ Review wastewater discharge permit renewal dates

■ Review how process changes can impact WW systems

Planning for 2017

■ SPCC Plan Review■ MS4 Gap Analysis■ Legionella

Things Regulators Look For

1. Wastewater permits– Adherence to definition of industrial wastewater– Discharges from industrial washers (sterilization equipment,

cage washers, bottle washers)– Nutrient levels and loads

2. Wastewater treatment systems– Up-to-date O&M manuals– Up-to-date staffing plans with licensed operators– Up-to-date process flow diagrams

3. SPCC plans– Outfalls and tributary areas are identified– Methods of isolating a release identified– Fill ports located and spill pathways provided

Questions




Brian F. Day, Senior Environmental Scientist

Hazardous Building Materials


■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health

Hazardous Building Material Assessments

Prepare Specs & Report of Findings

Find ALL Regulated Building Materials

• PRIOR to Renovation or Demolition

Investigate For:

• Asbestos• Oil/Hazardous Materials • Lead Based Paint• PCBs in Building

Materials

HBMA Inspection Types

– AHERA (Management Plans / 3 Year Inspections)

– OSHA (Hazard Communication) – Renovation / Demolition (Needed to Obtain Permits)

– Property Transfers / Purchases Serving Both Public and Private Sectors

Regulatory Requirements

The Watch Dogs– MassDEP

» Most Visible» Growing Enforcement Group» Control Contractors Work Methods » Levy Violations / Fines» Regional Variations / Interpretations

– MassDOS» Govern Licensure for Contractors and Consultants» Conduct Field Inspections / Mostly in Schools


– Environmental Protection Agency (EPA)» Create Federal Regulations and Standards» State Agencies Enforce EPA Regulations

– OSHA» Worker Protection» Hazard Communication » Building Inspections / Labeling


– AHERA» Governed by EPA / MassDOS» Regulates Asbestos in Schools» Inspections / Abatement Projects

■ Regulations have seen only minor changes in last several years

Planning for a Building Renovation/Demo?

■ Is your Building Subject to an Inspection?– Generally any structure (regardless of building age) requires a

survey– Used to confirm or deny the presence of asbestos, OHM etc.– Virtually all building materials are suspect for asbestos until

sampled ■ You should plan for the following:

– Use licensed, experienced asbestos inspectors– Provide inspector with drawings, plans, renovation / demolition

scope, previous inspection records and unlimited access to all areas of your building

– Prepare abatement specifications – Inspection is needed to secure renovation / demolition permits

Top Five Reasons You Need An HBMA

#1 – IT IS REQUIRED BY LAW


#2 – PROTECT THE ENVIRONMENT


#3 – PROTECT YOUR EMPLOYEES


#4 – CONTROL YOUR CONTRACTOR

#5 PROTECT YOUR POCKETBOOK!

Questions




David Horowitz, P.E., CSP - Project Manager

Alan Stratton, CSP - Project Manager

Safety & Health


■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health■ Auditing

Regulatory Updates – Safety & Health

■ Respirable Crystalline Silica

■ Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015

■ Recording and Reporting of Occupational Injuries and Illnesses regulations


■ Respirable Crystalline Silica– Issue Date: March 25, 2016 / Effective Date: June 23, 2016– Compliance Dates:

» Construction: June 23, 2017 / General Industry: June 23, 2018– Highlights:

» New P.E.L. of 50 µg / 8 hour shift(1/2 Prior Limit in General Industry / 5 times lower in Construction)

» New Action Level of 25 µg / 8 hour shift» Requires initial, in some cases follow-up, exposure monitoring» Requires engineering controls and work practices» Requires development of an Exposure Control Plan» Must consider designated list of controls


■ Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015

■ Translation: Higher OSHA Fines– Highlights:

» Serious $7,000 → $12,741 per violationOther Than Serious $7,000 → $12,741 per violation

» Failure to Abate $7,000 → $12,741 per day» Willful or repeat $70,000 → $124,709 per violation

» Effective August 1, 2016» First increase in over 25 years» Allows future increases by January 15 every year


■ Recording and Reporting of Occupational Injuries and Illnesses regulations– Highlights:

» Large Businesses (≥ 250 employees)– Electronically file OSHA 300/300A/301 forms with OSHA– Begins July 1, 2017

» Small (High Risk) Industries (20 – 249 employees)– By SIC Code (e.g., utilities, construction, manufacturing)– Electronically file OSHA 300A forms with OSHA– Begins July 1, 2017

» Injury / Illness data will be available to the public» Employers can not retaliate for injury reporting

– Automatic drug testing can be a form of retaliation» Electronic reporting is being challenged and may be modified

Planning for 2017– Safety & Health

■ Annual Safety & Health Requirements– Post OSHA 300A Log: Post from Feb 1 → through April 30– Initial Training:

» LoTo, Emergency Action Plan, HazCom, PPE, Hearing Protection…– Refresher Training:

» Annual: Hearing Protection, Respirators, Access to Medical Records…» 3-Year: Powered Industrial Trucks

– Mandatory Program Reviews:» Exposure Control Plan (BB Pathogens), Confined Space, LoTo….

– Annual Evaluations:» Audiograms, Respirator Fit Tests

– Process Changes:» Training, Program Updates, Hazard Reviews, PPE Assessments…


1. The common / obvious violations» OSHA Top 10 List» Visible - Low hanging fruit (Extension cords, No Written Programs, No Training...)

2. OSHA Exempt Facilities? Public Facilities?» Subject to Department of Labor Standards = Subject to OSHA standards

3. Federal / Local Emphasis Programs» Fall Protection, Fork Trucks, Amputations, Process Safety...

4. Employee Complaints & Injuries5. High Risk – High Injury Rate Facilities / Operations

Questions




Doug Stellato, Project Compliance Specialist

Compliance Tools – Chemical Inventories & Compliance Calendars

Agenda – Compliance Tools

■ Chemical Inventories■ Recordkeeping Databases■ Compliance Calendars

Compliance Tools – Chemical Inventories

■ Track materials stored & quantity used■ Used for multiple programs

– Tier II– Greenhouse Gas Reports– Source Registration– TURA reporting– TRI reporting– Chemical Control Laws

■ Accuracy is essential– Over-reporting– Under-reporting– Amended reports

Compliance Tools – Chemical Inventories

Materials ordered

Manufacturing

Products Manufactured

CAS #

CAS #

CAS #

Product Flow

CAS #

CAS #

CAS #

Information Needs

Receiving Dock

Shipping Dock

Compliance Tools – Recordkeeping

■ Track materials used and emissions■ Used for multiple programs

– Air Permit Reporting– Air Permit Recordkeeping– TURA/TRI applicability

■ Track all conditions of permit!– VOC/HAP concentration limits– VOC/HAP emissions– Annual reports

Compliance Tools – Recordkeeping

Compliance Tools – Calendars

■ Track “typical” and non-“typical” reporting deadlines

■ Track inspections or sampling– Hazardous waste– SPCC & SWPPP– Wastewater sampling

■ Track Employee Training– Hazardous waste– DOT– SPCC & SWPPP– Wastewater licenses

Compliance Tools –Calendars

Conclusions

■ Chemical inventory – key for material use, storage, and emission calculations– Establish systems at receiving dock– Use information for multiple regulatory programs– Regularly check and test data accuracy (3rd party)

■ Recordkeeping– Use data to generate compliance reports– Ability to export data for other uses and metrics tracking– Stay up to date on regulatory changes

■ Compliance Calendars– Use alerts and reminders– List applicable programs and frequency– List non-applicable programs with thresholds– Integrate inventory, recordkeeping and calendar

Questions




David P. Horowitz, P.E., CSP, Project Manager

Auditing


■ Tanks■ Hazardous Materials■ Toxics Use Reduction (TUR)■ Air Quality■ Water/Wastewater■ Hazardous Building Materials (HBM)■ Safety and Health■ Auditing

Reasons to Conduct an Audit

■ Manage risk■ Supply chain requirements■ Certification/Program requirements■ Employee turnover

Common Regulatory Visits

■ Department of Labor Standards – Public Works

■ Occupational Safety & Health Administration (OSHA) – Emphasis Programs

■ Environmental Protection Agency (EPA) – Risk Management Planning

Planning for 2017– Auditing

■ Internal Auditing– Checklists– In house– Outsourced

Planning for 2017– Auditing

■ Self Audit Policy – EPA

» eDisclosure– MassDEP– Timelines to disclose– Timelines to correct findings– Some relief from penalties

Department of Labor Standards

■ Common Audit findings at Public Works Facilities:

– Lock out/Tag out– Respiratory Protection Plan– Written PPE Certification

OSHA

■ Common Audit Findings at Industrial Facilities– 7 of 10 are general

industry– 3 of 10 are

construction

EPA

■ Common Audit Findings at Industrial Facilities– Risk Management Planning

» Process Safety Information (PSI)

» Signage» Management of Change

(MOC) issues» Employee Training

Questions