Current Information for
Christopher Haase:
Current Information for Christopher Haase: Christopher A. Haase (Chris Haase) Director of Environmental, Health and Safety. Environmentally Sensitive Solutions. Email: haase@neutralsolution.com Excerpts from (National artical by Christopher A. Haase) - Regulatory Management: Welcome to the Next Level By Christopher Haase/ Environmental Health and Safety Manager, companies have often passed safety to Hu man Resource (HR) departments and their environmental issues to outside consultants to save money. To be a player in this global economy, companies are doing everything they can to stay competitive. Prot ecting our greatest investments — people and the environment — is now becoming a recognizable competitive advantage. What does global economics have to do with environmental health and safety? More than you would think. It is imperative to your business that effective EHS training is planned wisely. All training has to merge into the daily operations. Integrating environmental health and safety program s into written operating procedures, policies, and trained skills can meet this objective. It is only when regulatory training is integrated into the daily routine that compliance assurance is obtainable . Many companies fall into the regulatory rut of training once a year, when it is required — not when it is needed — costing companies hundreds of hours in downtime. In the past, the environmental health and safety field, always had a backwards “what if” strategy. What if we are out of compliance? What if OSHA came knocking? What if that regulation passes? The “What if” has changed. What if we refine o ur waste material into a raw material? What if we integrate our safety training into existing training programs to increase efficiency and awareness? What if we could forecast environmental health and sa fety problems ahead and design them out? What if we turned our environmental health and safety department into a profitable department? In a regulated industry, a good environmental health and safety pro gram can be a huge competitive edge. Companies that live by regulations are also controlled by regulations. The financial decisions those companies make are sometimes only based on avoiding or just compl ying with regulations and not on the financial long-term benefits to their process. The original intention of all government regulations and policies is to protect workers, the environment and job securi ty by increasing efficiency, productivity and growth. The key is not making decisions based solely on complying with regulations, but working with the government to make better regulations based on good business decisions that benefit us all. Following this simple recipe can help any company create a successful environmental health and safety program. The overwhelming benefits and long-term cost saving s greatly outweigh the initial time and financial investment. The resources are out there to create an effective program. Economics, networking, solid infrastructure, competitive edge, dynamic: Does this sound like your company’s environmental, health and safety department? * The reality is that most company “safety” programs are administered by Human Resource staff, plant managers and team leaders that have minimal hazardous chemical, risk management, incident experience or emergency training. While most environmental professionals do not consider themselves to be “safety” managers, they receive more “safety” training during annual certification and review courses than anyone in their organization, making them “safety” expert by default. Excerpts from (National artical by Christopher A. Haase) Capit ol Gains? - Dealing With New Environmental Regs Joan Hustace Walker Similar to taking the SAT exam, new environmental legislation is creating many questions with uncertain answers for paint and coatings formulators. Last year's concerns have transformed into this year's proposed rules, with industry members paying close attention to two key issues: air quality controls developing in Northeastern states and the U.S. Environmental Protection Agency's (EPA) proposed listing of paint wastes. If 13 Northeastern states follow the Ozone Transportation Commission's (OTC) recommendation, architectural and indu strial maintenance (AIM) coatings sold in these states could be required to meet nearly the same stringent, and much contested, volatile organic compound (VOC) limits as California's Suggested Control Me asure (SCM) for AIM coatings. The OTC was created by the Clean Air Act Amendments to develop plans to curb ground-level ozone, a component in the creation of smog, in the following states: Connecticut, D elaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Virginia and Vermont. In June 2000, OTC signed a Memorandum of Underst anding (MOU) with the 13 states regarding the commission's efforts to develop a regional strategy and short-term priority control measures by early 2001. The model rule would be used as a template for th e states to use in adopting their own regulations. The OTC chose to adopt a model proposed by the Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Cont rol Officials (ALAPCO). The STAPPA-ALAPCO model set VOC limits for AIM coatings along the same lines as California's SCM. The proposed model rule was discussed with industry members in December 2000, and after "substantial stakeholder comments," a final model rule was released by OTC on March 28. "Although we didn't take all the recommendations we received, we did incorporate several important revisions that we think respond to the concerns of manufacturers and provide flexibility for the industry," said Bruce Carhart, OTC executive director. OTC set an effective date of Jan. 1, 2005 for the VOC conten t limit for all coatings categories. By placing the OTC dates after CARB's [California Air Resource Board] dates, manufacturers as well as states will have "an opportunity to take advantage of the lesson s learned in implementing those limits in California," Carhart explained. A second modification made to the proposed model rule was increasing the VOC content limit for industrial maintenance coatings f rom 250 to 340 grams per liter (g/l). OTC had previously proposed the lower limit along with a petition process for those manufacturers producing coatings that required a less stringent limit for perform ance reasons. In the California SCM, manufacturers of industrial maintenance coatings in specific areas of the Golden State (with low temperatures, high humidity and persistent fog) are allowed to petiti on for a less stringent limit. OTC related that it recognized these coatings are needed for essential public services, such as bridges, and industrial facilities, such as storage tanks, so the commission waived the petition process entirely and allowed a less stringent VOC content limit. "We're very pleased to see that they have recognized that the California 250 g/l limit is really too low for that cat egory," said Christine Stanley, vice president technology, Ameron Coatings. "We feel the 340 g/l limit is much more attainable." Additionally, the OTC final model created a separate category for conversi on varnishes and used a VOC content limit of 725 g/l, which is consistent with the federal AIM rule. Conversion varnishes are used in the hardwood floor finish market and estimated by OTC to consist of a pproximately 3 percent of that market, with three manufacturers. The proposed VOC content limit had been 350 g/l, which OTC concluded was "not technologically feasible at this time." "The only issue that we have with the model is that we'd like to further discuss smaller coatings categories, and we feel we're going to need some higher limits," Stanley said. "It is our understanding that will happen at t he state level." However, the battle may not be over. The National Paint and Coatings Association (NPCA) is expressing technical arguments of this model, according to Steve Sides, vice president of envi ronmental health and international affairs for NPCA. "Even with good technical arguments, someone has to begin to accept them within the OTC and be a proponent of them. That's a tough thing to get." A fo urth change to the model is the effective date of the rule. The sell-through provisions were modified so products manufactured before the effective date can be sold after Jan. 1, 2005, OTC said. Recycled coatings will receive a break, too, Carhart said, with higher allowable VOC content limits than previously listed with the proposed model rule. The final model rule also includes an exemption of coating s in containers of one liter or less. "We've been trying to provide flexibility to the industry while at the same time, providing for a model rule that our states can use," he said. "The model rule that we have here has been developed over several years and many of our states are facing a federal regulatory deadline of October." What the OTC is trying to avoid, Carhart said, is a patchwork of regulation s that vary from state to state. "What we've heard is that manufacturers of commercial and consumer products would like to have consistency in regulatory limits, so we've tried to encourage consistency a nd avoid [the situation] where one state will do one set of limits and another state will do another set of limits." Carhart pointed out that the coatings model rule is only one of six released. "It is a part of a much larger package addressing sources of emissions," he explained. "Together, the models are intended to provide a set of guidelines that individual states can use to meet their own air qual ity needs." PAINT WASTE SCRUTINIZED How the proposed paint waste rule released by EPA in February will affect paint makers is still uncertain, as is the environmental benefit of the rule. "Certainly, som e waste streams that now are managed as non-hazardous wastes--not within the hazardous waste system--are going to get sucked into the hole that RCRA has as waste management under the current proposal," N PCA's Sides said. The proposed rule is based on concentration levels for certain chemicals in waste solids (acrylamide, acrilonitrile, antimony, methyl isobutyl ketone and methyl methacrylate) and waste liquids (acrylamide, acrilonitrile, antimony, ethyl benzene, formaldehyde, methyl isobutyl ketone, methyl methacrylate, methylene chloride, N-butyl alchohol, styrene, toluene and xylene). EPA estimates the economic impact on the coatings industry will be around $7.3 million annually. The impact on an individual facility would depend on the facility's waste, said Patricia Cohn, an EPA environmental prot ection specialist. "If the facility generated less than 40 tons per year of waste solids or less than 100 tons of waste liquids, it could use knowledge of the waste in order to make that determination," Cohn said. "If it's more than [those threshold levels], it would have to do testing." The fact that the listing is based on concentration levels is a significant difference with EPA's proposal, Cohn ad ded. "Industry representatives were very interested in a concentration-based approach because the waste from facility to facility can be so different, depending on what kind of paints are being made." Bu t because of the concentration-base approach, EPA has not been able to quantify the environmental benefits of the proposed rule. "We didn't go out and sample waste because we felt it would be very diffic ult to get samples that were going to be representative," Cohn explained. "So what we were trying to do was identify those constituents that are most likely to be in paint and that most likely pose a ris k at excessive levels. Because we don't have data on actually what's there and what levels it is at, we couldn't quantify the benefits." Cohn listed benefits of the proposed rule as "avoiding future risk s to human health and the environment by ensuring that any wastes that have concentrations exceeding the listing level will be managed properly as hazardous waste." The other benefit is waste minimizati on. "Raw materials are such a large cost for paint manufacturers anyway," Cohn said, "there's an advantage to make sure you're not letting those things get away to the extent possible." Christopher Haase , environmental health and safety manager, ESS Corp, said EPA's proposed rule includes some "nasty things, chemicals that scare even consumers." He added that "if this were already in your paint, you sho uld have been handling it as a listed hazardous material as it was, under the law. I think EPA is trying to clarify that." "However, there are some big costs associated with that," warned Haase, adding t hat the proposed rule may cause facilities currently recycling their wastes some problems. "If [EPA] says that my recycling or any industry's recycling effort is considered 'treatment' of hazardous mater ial, that would shut us down." Facilities that treat paint wastes require special permits and must follow other regulations to be in compliance. "EPA needs to support in-house recycling efforts and the waste should be categorized--not in house--but the minute it leaves the facility," Haase said. NPCA indicated there may be additional problems with the proposed rule. "The paint industry is already follo wing good management practices with the waste that it has," Sides said. "What's happening now is that EPA is looking at other waste streams and trying to draw them into the RCRA net on the basis of compo nents that they have surveyed are in our wastes. So our thrust is to look at the data collection and analysis EPA engaged in to be certain that the agency has properly called it." PAINT FEES? In a recent development, a proposal introduced in Minnesota and likely to be considered in California and other states involves imposing a special fee to cover recycling post-consumer architectural paints and coati ngs, or a mandatory "take-back" of leftover paint by the industry. "This is a critical issue," Sides said, expressing concern over waste management practices being mandated. "The view of the industry is that we sell these products to be used, not disposed of." Sides pointed to Canada, where industry is involved in the management of post-consumer paints with differing results. "They're having difficulty maintaining what they call the transparent eco fee that the consumer pays," he noted. "Some of the provinces have decided they don't like the eco fee to be on the sales. They're requiring that the compa ny, the paint manufacturer, or retailer pay the fee and not charge the consumer overtly in the bill of sale. "What this does is create a lot of consternation in the pricing of the product. And they're n ot quite sure how to handle this issue from a regulatory standpoint," Sides said. "While the system was originally one that was quite acceptable to the industry in Canada, it is now being modified and mo ved in directions where it is becoming increasingly problematic. We don't want to have that kind of track roll down south of the border." ESS's Haase noted the recycling effort of cans and aluminum produ cts of the 1960s and 1970s "worked phenomenally well" and that a similar effort could work for paint cans and aerosols. "Tacking on a recycling fee that would give the consumer money back when the contai ner is returned to the vendor or a drop-off area would work," he said. "It's the deposit fee that makes [the consumer] come back for a reason. If consumers are willing to do it with recyclables, why woul dn't they be willing to do it with something hazardous to begin with?" Lean, Mean and Green Environmental excellence and process safety go hand-in-hand Link to: The U.S. Chemical Safety and Hazard In vestigation Board (CSB) recently approved several new recommendations to reduce the number of serious industrial accidents caused by uncontrolled chemical reactions. Both OSHA and EPA were called upon to issue new mandatory safety regulations under the Process Safety Management (PSM) standard and the Risk Management Program (RMP) rule, respectively. Some experts believe that the potential for a serious incident is higher today than ever before. In fact, the recordable injury rate of the top companies in the American Chemistry Council (ACC) has increased in recent years.FET is holding an “Environmental Health & Safety Update” focused on these principals. Summary Environmental professionals must become much more actively involved in the future of safety in order to achieve common goals. We still don't know all the answers, but we do know that root causes of both environmental and safety issues go hand in hand, putting the resolution to those problems in your hands. Haase, The Haase Family of Christoph er, Cheryl, Connor and allison Christopher Haase, The Haase Family, Chrsitopher Haase, Cheryl Haase, Connor Haase, Alan Haase. Christopher Haase - FET Health & Safety Chair. What's is a name? Christopher (Greek) ~ meaning ~ Bearing Christ ~ motivation ~ To make the best of what you have ~ character ~ Is law abiding ~ feelings ~ Needs to be needed ~ intelligence ~ You are noted for your creativity ~ spir itual ~ Is sure of their direction ~ nature ~ Does not like leaving things unfinished ~ inherent ~ You are known for your sense of humor Haase is a German Lowlands version of the English name Hare, which was the nickname for the fast runner, or a person of nervous or timerous nature. Other cognate forms are Hase (German); Haas, Haase (Low German); De Haese (Flemish); De Haas (Dutch); Haas (Jewish orname ntal). Hare is also found among the Irish as an Anglicized form of O hAichir , which meant " descendant of Aichear, " whose name meant fierce, sharp. Variations of the Irish name are Hair, Haire, O'Haire , O'Hare, O'Hagher, O'Hahir, O'Hehir. Baubiologie is the German discipline/philosophy of treating the living space as a whole entity. It roughly translates as biologically sensitive architecture. It take s into consideration the many different things that affect a persons daily living conditions that are directly related to the 'health' of the structure they live/work in. Current Information for Christop her Haase: Christopher A. Haase (Chris Haase) Director of Environmental, Health and Safety. Environmentally Sensitive Solutions. Email: haase@neutralsolution.com Excerpts from (National artical by Christ opher A. Haase) - Regulatory Management: Welcome to the Next Level By Christopher Haase/ Environmental Health and Safety Manager, companies have often passed safety to Human Resource (HR) departments an d their environmental issues to outside consultants to save money. To be a player in this global economy, companies are doing everything they can to stay competitive. Protecting our greatest investments — people and the environment — is now becoming a recognizable competitive advantage. What does global economics have to do with environmental health and safety? More than you would think. It is imperati ve to your business that effective EHS training is planned wisely. All training has to merge into the daily operations. Integrating environmental health and safety programs into written operating procedu res, policies, and trained skills can meet this objective. It is only when regulatory training is integrated into the daily routine that compliance assurance is obtainable. Many companies fall into the r egulatory rut of training once a year, when it is required — not when it is needed — costing companies hundreds of hours in downtime. In the past, the environmental health and safety field, always had a backwards “what if” strategy. What if we are out of compliance? What if OSHA came knocking? What if that regulation passes? The “What if” has changed. What if we refine our waste material into a raw mat erial? What if we integrate our safety training into existing training programs to increase efficiency and awareness? What if we could forecast environmental health and safety problems ahead and design t hem out? What if we turned our environmental health and safety department into a profitable department? In a regulated industry, a good environmental health and safety program can be a huge competitive e dge. Companies that live by regulations are also controlled by regulations. The financial decisions those companies make are sometimes only based on avoiding or just complying with regulations and not on the financial long-term benefits to their process. The original intention of all government regulations and policies is to protect workers, the environment and job security by increasing efficiency, pro ductivity and growth. The key is not making decisions based solely on complying with regulations, but working with the government to make better regulations based on good business decisions that benefit us all. Following this simple recipe can help any company create a successful environmental health and safety program. The overwhelming benefits and long-term cost savings greatly outweigh the initial t ime and financial investment. The resources are out there to create an effective program. Economics, networking, solid infrastructure, competitive edge, dynamic: Does this sound like your company’s envir onmental, health and safety department? * The reality is that most company “safety” programs are administered by Human Resource staff, plant managers and team leaders that have minimal hazardous chemical , risk management, incident experience or emergency training. While most environmental professionals do not consider themselves to be “safety” managers, they receive more “safety” training during annual certification and review courses than anyone in their organization, making them “safety” expert by default. Excerpts from (National artical by Christopher A. Haase) Capitol Gains? - Dealing With New Env ironmental Regs Joan Hustace Walker Similar to taking the SAT exam, new environmental legislation is creating many questions with uncertain answers for paint and coatings formulators. Last year's concern s have transformed into this year's proposed rules, with industry members paying close attention to two key issues: air quality controls developing in Northeastern states and the U.S. Environmental Prote ction Agency's (EPA) proposed listing of paint wastes. If 13 Northeastern states follow the Ozone Transportation Commission's (OTC) recommendation, architectural and industrial maintenance (AIM) coating s sold in these states could be required to meet nearly the same stringent, and much contested, volatile organic compound (VOC) limits as California's Suggested Control Measure (SCM) for AIM coatings. Th e OTC was created by the Clean Air Act Amendments to develop plans to curb ground-level ozone, a component in the creation of smog, in the following states: Connecticut, Delaware, the District of Columbi a, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Virginia and Vermont. In June 2000, OTC signed a Memorandum of Understanding (MOU) with the 13 states regarding the commission's efforts to develop a regional strategy and short-term priority control measures by early 2001. The model rule would be used as a template for the states to use in adopting thei r own regulations. The OTC chose to adopt a model proposed by the Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (ALAPCO). The STAP PA-ALAPCO model set VOC limits for AIM coatings along the same lines as California's SCM. The proposed model rule was discussed with industry members in December 2000, and after "substantial stakeholder comments," a final model rule was released by OTC on March 28. "Although we didn't take all the recommendations we received, we did incorporate several important revisions that we think respond to the co ncerns of manufacturers and provide flexibility for the industry," said Bruce Carhart, OTC executive director. OTC set an effective date of Jan. 1, 2005 for the VOC content limit for all coatings categor ies. By placing the OTC dates after CARB's [California Air Resource Board] dates, manufacturers as well as states will have "an opportunity to take advantage of the lessons learned in implementing those limits in California," Carhart explained. A second modification made to the proposed model rule was increasing the VOC content limit for industrial maintenance coatings from 250 to 340 grams per liter ( g/l). OTC had previously proposed the lower limit along with a petition process for those manufacturers producing coatings that required a less stringent limit for performance reasons. In the California SCM, manufacturers of industrial maintenance coatings in specific areas of the Golden State (with low temperatures, high humidity and persistent fog) are allowed to petition for a less stringent limit. O TC related that it recognized these coatings are needed for essential public services, such as bridges, and industrial facilities, such as storage tanks, so the commission waived the petition process ent irely and allowed a less stringent VOC content limit. "We're very pleased to see that they have recognized that the California 250 g/l limit is really too low for that category," said Christine Stanley, vice president technology, Ameron Coatings. "We feel the 340 g/l limit is much more attainable." Additionally, the OTC final model created a separate category for conversion varnishes and used a VOC cont ent limit of 725 g/l, which is consistent with the federal AIM rule. Conversion varnishes are used in the hardwood floor finish market and estimated by OTC to consist of approximately 3 percent of that m arket, with three manufacturers. The proposed VOC content limit had been 350 g/l, which OTC concluded was "not technologically feasible at this time." "The only issue that we have with the model is that |
Christopher A. Haase (Chris Haase)
Director of Environmental, Health and Safety
Environmentally Sensitive Solutions
Email:
haase@neutralsolution.com
Company Information
Environmentally
Sensitive Solutions, Inc. (ESS), a leading manufacturer of environmentally
friendly, neutral pH cleaning products, has won the 2004 Wisconsin Governor’s
Excellence in Environmental Performance Award. This prestigious award is given
to companies whose products and efforts excel in protecting the environment and
reducing hazardous waste. Other winners of this award include GE Medical
Systems, S.C. Johnson, Rockwell Automation, General Motors Truck, Target
Corporation, Green Bay Packaging, and Placon Corporation.
Established in 1993, ESS has produced market leading neutral degreasers that
replace hazardous alkaline cleaners in industrial metal cleaning applications.
Unlike the hazardous cleaners they replace, ESS neutral products have a number
of worker safety and environmental advantages. In the last five years, ESS
neutral products have eliminated 80 million pounds of hazardous materials from
the environment.
The ESS mission is to improve the quality of life through the most innovative,
safety conscious, and environmentally safe products worldwide.
Go to www.neutralsolution.com for
more information.
Author of National Publication Articles
Listed as a Paint Industry Expert in 2000-2004 NPCA expert guide
Qualifications: Environmental Consultant for eight years, five years in field experience. Hazardous Materials Manager, Environmental Assessor, Confined Space Sup., HAZWOP, Sup., Environmental Auditor. Environmental Specialist, Incident Responder, EHS-Trainer. Hazardous Materials Manager, Lakeshore Tech. Cleveland, WI, MS (working) , Environmental Resource Management, Chadwick University, Birmingham, AL.
Subject Areas: Air Quality, Asbestos -- Removal, Abatement, In-Place Management, Lead-Based Paint Removal -- Abatement, Lead-Based Paint Removal -- In-Place Management, Clean Air Act Operating Permit Program, Disposal, EPA Regulation, Fire Protection, Hazardous Waste Disposal/Management, Product Safety, Recycling, Storm Water Permits
Regulatory Management: Welcome to the
Next Level
By Christopher Haase/
Environmental Health and Safety
|
What does global
economics have to do with environmental health and safety? More than you
would think. No longer can we move away from or bury our problems. The global
concerns about the environment and employee work conditions are forcing
companies to rethink and restructure. The ability to plan for future laws and
regulations can be overwhelming, and the financial and public relations consequences
that a company can suffer by being out of compliance are nearly crippling.
It’s not only about complying with regulations anymore — it’s about
planning and sustaining economic growth that is free from regulatory burden.
Many companies focus on the fact that they are in compliance with regulations
and not on the reality that the company is still at risk of being out of
compliance in the near future. That is why it is no accident that profitable
companies typically pave the road to the next generation of environmental
health and safety programs. ISO-14000 is not only a new generation of
environmental programs — it is becoming an industry standard. This corporate
focus has also resulted in a new generation of environmental health and
safety professionals. |
|
Environmental Health and Safety Professionals
Designing in-house programs that evolve with your business and
regulations is crucial. The process of implementing a successful
environmental health and safety program may be more familiar to business
owners than they realize. A solid program is very similar to a small business
plan. Why would business owners want to be involved? For the same reason
owners are involved in business plans: because they are financially liable. |
|
Step
1: Strategic Planning
If your company is
already using a quality assurance program, similar to ISO, this transition
will be easy to obtain. If not, don’t panic. Starting from scratch on a solid
environmental health and safety program can be a financially beneficial
process for most corporate strategic planning committees. When your committee
members discover how many OSHA, EPA, DOT, DNR and state regulatory programs
are required for your industry, they will understand why this is a company
concern, not just a concern of the environmental health and safety
individual.
During strategic planning, your organization should implement a
compliance assurance program (CAP) (see Figures). The basic principal of a
CAP outlines what regulations apply to your company and how compliance is
met. This can be done using a corporate matrix or a flow chart outlining
permits, reporting and training requirements. It is imperative to your
business that the CAP defines what to do if your environmental health and
safety manager is not available. The involvement of a consultant or your
state regulatory agency may be required at this step. If the laws and
regulations that apply to your business are not precisely calculated, tens of
thousands of dollars could be wastefully spent on non-applicable training and
in-house regulatory programs. Worse yet, by misinterpretation of the law,
your company could be set up for a severe violation. Baseline compliance
audits are offered by most state agencies and UW extensions at no cost.
However, consultants can offer baseline audits and assistance with getting
your program started for under a $1,000 for most small businesses. |
|
Step
2: Budgeting
There are more than 11
OSHA applicable programs to general industry alone. Without even adding EPA
or DOT training, this could be 10–80 hours of training a year, ranging from
basic office staff awareness to plant manager responders. It is imperative to
your business that effective training is planned wisely. All training has to
merge into the daily operations. Integrating environmental health and safety
programs into written operating procedures, policies, and trained skills can
meet this objective. It is only when regulatory training is integrated into
the daily routine that compliance assurance is obtainable. Many companies
fall into the regulatory rut of training once a year, when it is required —
not when it is needed — costing companies hundreds of hours in downtime.
Worse yet, employee retention and comprehension of all the applicable
training programs is nearly impossible when training
is conducted in this manner. Without employee retention and comprehension,
these programs will not be worth the paper they are written on.
Manufacturing involvement is a necessity to your in-house program’s success. Manufacturing could inadvertently compromise regulatory compliance on a daily basis if every employee is not trained on general awareness. Don’t make it an option; write policies that protect people and your company. This does not require a lot of extra training. Employee training should be focused on policies that do not compromise regulatory compliance, what is wrong, and how to correct or report it. Manufacturing managers have to understand the importance of a quality regulatory program. Manufacturing training should be applied with the same diligence and priority as preventive maintenance. Before a new process is brought online, it is tested and fine tuned for optimal performance. People should be treated with equal importance. People, like a process, need to be tested and fine tuned for optimal performance. Manufacturing training must be conducted based on compliance and deficiencies. If people have to be trained anyway, why wouldn’t it be done before they go online? Without constant support and feedback from manufacturing, programs will not evolve or become streamlined. There is no perfect recipe during implementation. Feedback provides the ingredients that refine good programs into great ones.
Purchasing should be integrated into your hazardous materials (Hazmat) programs. Purchasing agents have a better understanding of what measures and balances are required to track improvements and deficiencies. Inventory control is an inherent quality used in both Hazmat management and warehouse management. Both Hazmat management and warehouse management require prior knowledge of the physical state, quantity and location of raw materials that are ordered. The physical state and quantity in which a material is initially being handled or ordered could have a substantial affect on how the material is regulated. If your purchasing department was aware that ordering of raw material as a liquid compared to a powder could remove a regulated status or eliminate the material as a hazardous waste, they would want to be involved. Purchasing managers can also help with the economics of short-term disposal options versus long-term treatment solutions. Finding best source options for hazardous materials is a never-ending process; you need all the help you can get.
Using a warehouse
management vender rating system on disposal facilities and consultants will
ensure consistency and performance. When it comes to compliance, consistency
is extremely important.
Other warehouse management systems that incorporate cycle counting and
shortage reports are the heart of a hazardous waste minimization program. Why
duplicate efforts? If you have a current system that works, use it. If
warehouse management systems can be used to predict and track usage of
materials months ahead of schedule, why couldn’t those same systems be used
to predict and track how much hazardous waste will be generated? Knowing this
gives companies the ability to design and implement waste-reduction programs
before the waste begins. The basic integration environmental management and
warehouse management typically saves companies thousands of dollars on
disposal, hazardous materials handling, and personnel involvement. It could
also save hundreds of hours wasted on environmental tracking and reporting. |
|
Step
3: Forecasting
Don’t reinvent the wheel — the solutions are out there. And finding help has never been easier or more financially feasible. The whole world is involved through the Internet. Universities, nonprofit organizations and most regulatory agencies have “low profile” out-reach consultant programs that are free of charge. Accessing this global repository of information is the real advantage of the Internet. When used effectively, the Internet can be one of the most efficient sources of environmental health and safety information, as well as a vehicle for regulatory communication and reporting. It can deliver instant access to professionals and regulators ready to answer your questions on any topic. It can provide real-time discussions, economic solutions, thousands of free periodicals, regulations, or more importantly, draft and proposed regulatory forums all to your desk, wherever, and whenever, you want it.
The problem is that almost 130 million Internet users have proven that the Internet can be an addictive waste of time. And unfortunately, for that portion that is actually passed off as information, the vast majority of it is unedited, unreviewed data, mixed with personal speculation that no one has verified. The wrong information can lead to violations and the demise of a company’s environmental health and safety program. A good environmental health and safety manager is a great information manager that values solid information provided by regulatory and nonprofit organizations that are not financially or politically motivated.
The following websites
offer some of the best online information currently available at no cost to
the user. In the past, the
environmental health and safety field, always had a
backwards “what if” strategy. What if we are out of compliance? What if OSHA
came knocking? What if that regulation passes? The “What if” has changed. What if we refine our waste material into a raw material? What if we integrate our safety training into existing training programs to increase efficiency and awareness? What if we could forecast environmental health and safety problems ahead and design them out? What if we turned our environmental health and safety department into a profitable department?
In a regulated industry,
a good environmental health and safety program can be a huge competitive
edge. Companies that live by regulations are also controlled by regulations.
The financial decisions those companies make are sometimes only based on
avoiding or just complying with regulations and not on the financial
long-term benefits to their process. The original intention of all government
regulations and policies is to protect workers, the environment and job
security by increasing efficiency, productivity and growth. The key is not
making decisions based solely on complying with regulations, but working with
the government to make better regulations based on good business decisions
that benefit us all. Following this simple
recipe can help any company create a successful environmental health and
safety program. The overwhelming benefits and long-term cost savings greatly
outweigh the initial time and financial investment. The resources are out
there to create an effective program. Economics, networking, solid
infrastructure, competitive edge, dynamic: Does this
sound like your company’s environmental, health and safety department?
|
Cover Story
Capitol Gains? - Dealing With
New Environmental Regs
Joan Hustace
Walker
Similar to taking the SAT
exam, new environmental legislation is creating many questions with uncertain
answers for paint and coatings formulators. Last year's concerns have
transformed into this year's proposed rules, with industry members paying close
attention to two key issues: air quality controls developing in Northeastern
states and the U.S. Environmental Protection Agency's (EPA) proposed listing of
paint wastes.
If 13 Northeastern states follow the Ozone Transportation Commission's (OTC) recommendation, architectural and industrial maintenance (AIM) coatings sold in these states could be required to meet nearly the same stringent, and much contested, volatile organic compound (VOC) limits as California's Suggested Control Measure (SCM) for AIM coatings. The OTC was created by the Clean Air Act Amendments to develop plans to curb ground-level ozone, a component in the creation of smog, in the following states: Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Virginia and Vermont.
In June 2000, OTC signed a
Memorandum of Understanding (MOU) with the 13 states regarding the commission's
efforts to develop a regional strategy and short-term priority control measures
by early 2001. The model rule would be used as a template for the states to use
in adopting their own regulations. The OTC chose to adopt a model proposed by
the Territorial Air Pollution Program Administrators (STAPPA) and the
Association of Local Air Pollution Control Officials (ALAPCO). The
STAPPA-ALAPCO model set VOC limits for AIM coatings along the same lines as
The proposed model rule was discussed with industry members in December 2000, and after "substantial stakeholder comments," a final model rule was released by OTC on March 28. "Although we didn't take all the recommendations we received, we did incorporate several important revisions that we think respond to the concerns of manufacturers and provide flexibility for the industry," said Bruce Carhart, OTC executive director.
OTC set an effective date
of
A second modification made
to the proposed model rule was increasing the VOC content limit for industrial
maintenance coatings from 250 to 340 grams per liter (g/l). OTC had previously
proposed the lower limit along with a petition process for those manufacturers
producing coatings that required a less stringent limit for performance
reasons. In the California SCM, manufacturers of industrial maintenance
coatings in specific areas of the
"We're very pleased to
see that they have recognized that the
Additionally, the OTC final
model created a separate category for conversion varnishes and used a VOC
content limit of 725 g/l, which is consistent with the federal AIM rule.
Conversion varnishes are used in the hardwood floor finish market and estimated
by OTC to consist of approximately 3 percent of that market, with three
manufacturers. The proposed VOC content limit had been 350 g/l, which OTC
concluded was "not technologically feasible at this time." "The
only issue that we have with the model is that we'd like to further discuss
smaller coatings categories, and we feel we're going to need some higher
limits,"
However, the battle may not be over. The National Paint and Coatings Association (NPCA) is expressing technical arguments of this model, according to Steve Sides, vice president of environmental health and international affairs for NPCA. "Even with good technical arguments, someone has to begin to accept them within the OTC and be a proponent of them. That's a tough thing to get."
A fourth change to the
model is the effective date of the rule. The sell-through provisions were
modified so products manufactured before the effective date can be sold after
Recycled coatings will
receive a break, too, Carhart said, with higher
allowable VOC content limits than previously listed with the proposed model
rule. The final model rule also includes an exemption of coatings in containers
of one liter or less. "We've been trying to provide flexibility to the industry
while at the same time, providing for a model rule that our states can
use," he said. "The model rule that we have here has been developed
over several years and many of our states are facing a federal regulatory
deadline of October."
What the OTC is trying to avoid, Carhart said, is a patchwork of regulations that vary from state to state. "What we've heard is that manufacturers of commercial and consumer products would like to have consistency in regulatory limits, so we've tried to encourage consistency and avoid [the situation] where one state will do one set of limits and another state will do another set of limits."
Carhart pointed out that the coatings model rule is only one of six released. "It is a part of a much larger package addressing sources of emissions," he explained. "Together, the models are intended to provide a set of guidelines that individual states can use to meet their own air quality needs."
PAINT WASTE SCRUTINIZED
How the proposed paint waste rule released by EPA in February will affect paint makers is still uncertain, as is the environmental benefit of the rule. "Certainly, some waste streams that now are managed as non-hazardous wastes--not within the hazardous waste system--are going to get sucked into the hole that RCRA has as waste management under the current proposal," NPCA's Sides said.
The proposed rule is based on concentration levels for certain chemicals in waste solids (acrylamide, acrilonitrile, antimony, methyl isobutyl ketone and methyl methacrylate) and waste liquids (acrylamide, acrilonitrile, antimony, ethyl benzene, formaldehyde, methyl isobutyl ketone, methyl methacrylate, methylene chloride, N-butyl alchohol, styrene, toluene and xylene). EPA estimates the economic impact on the coatings industry will be around $7.3 million annually. The impact on an individual facility would depend on the facility's waste, said Patricia Cohn, an EPA environmental protection specialist.
"If the facility generated less than 40 tons per year of waste solids or less than 100 tons of waste liquids, it could use knowledge of the waste in order to make that determination," Cohn said. "If it's more than [those threshold levels], it would have to do testing."
The fact that the listing is based on concentration levels is a significant difference with EPA's proposal, Cohn added. "Industry representatives were very interested in a concentration-based approach because the waste from facility to facility can be so different, depending on what kind of paints are being made."
But because of the concentration-base approach, EPA has not been able to quantify the environmental benefits of the proposed rule. "We didn't go out and sample waste because we felt it would be very difficult to get samples that were going to be representative," Cohn explained. "So what we were trying to do was identify those constituents that are most likely to be in paint and that most likely pose a risk at excessive levels. Because we don't have data on actually what's there and what levels it is at, we couldn't quantify the benefits."
Cohn listed benefits of the proposed rule as "avoiding future risks to human health and the environment by ensuring that any wastes that have concentrations exceeding the listing level will be managed properly as hazardous waste."
The other benefit is waste minimization. "Raw materials are such a large cost for paint manufacturers anyway," Cohn said, "there's an advantage to make sure you're not letting those things get away to the extent possible."
Christopher Haase, environmental health and safety manager, ESS Corp, said EPA's proposed rule includes some "nasty things, chemicals that scare even consumers." He added that "if this were already in your paint, you should have been handling it as a listed hazardous material as it was, under the law. I think EPA is trying to clarify that."
"However, there are
some big costs associated with that," warned Haase, adding that the
proposed rule may cause facilities currently recycling their wastes some
problems. "If [EPA] says that my recycling or any industry's recycling
effort is considered 'treatment' of hazardous material, that
would shut us down."
Facilities that treat paint wastes require special permits and must follow other regulations to be in compliance. "EPA needs to support in-house recycling efforts and the waste should be categorized--not in house--but the minute it leaves the facility," Haase said.
NPCA indicated there may be
additional problems with the proposed rule. "The paint industry is already
following good management practices with the waste that it has," Sides
said. "What's happening now is that EPA is looking at other waste streams
and trying to draw them into the RCRA net on the basis of components that they
have surveyed are in our wastes. So our thrust is to look at the data
collection and analysis EPA engaged in to be certain that the agency has
properly called it."
PAINT FEES?
In a recent development, a
proposal introduced in
Sides pointed to
"What this does is
create a lot of consternation in the pricing of the product. And they're not
quite sure how to handle this issue from a regulatory standpoint," Sides
said. "While the system was originally one that was quite acceptable to
the industry in
ESS's Haase noted the recycling effort of cans and aluminum products of the 1960s and 1970s "worked phenomenally well" and that a similar effort could work for paint cans and aerosols. "Tacking on a recycling fee that would give the consumer money back when the container is returned to the vendor or a drop-off area would work," he said. "It's the deposit fee that makes [the consumer] come back for a reason. If consumers are willing to do it with recyclables, why wouldn't they be willing to do it with something hazardous to begin with?"
Lean, Mean and Green
Environmental excellence and process safety go hand-in-hand
Link to: http://www.fetinc.org/FeatureArticle/Lean,%20Mean%20Green.htm
The U.S. Chemical Safety and Hazard Investigation Board (CSB) recently approved several new recommendations to reduce the number of serious industrial accidents caused by uncontrolled chemical reactions. Both OSHA and EPA were called upon to issue new mandatory safety regulations under the Process Safety Management (PSM) standard and the Risk Management Program (RMP) rule, respectively. Some experts believe that the potential for a serious incident is higher today than ever before. In fact, the recordable injury rate of the top companies in the American Chemistry Council (ACC) has increased in recent years.*
The reality is that most company “safety” programs are administered by Human Resource staff, plant managers and team leaders that have minimal hazardous chemical, risk management, incident experience or emergency training.
While most environmental professionals do not consider themselves to be “safety” managers, they receive more “safety” training during annual certification and review courses than anyone in their organization, making them “safety” expert by default.
In the FET organization we now see more and more professionals taking on the role of safety. These professionals are getting more involved in their own companies’ safety programs and decisions. This involvement is leading to a higher level of compliance and protection.
By relating the inherent principals applied to resolving environmental issues, these professionals are achieving equal Health and Safety results reducing injuries, risk exposure and incidents. The incentive is that this achievement is not only career rewarding, it is also personally rewarding knowing you have prevented people from injury, exposure and a potential lifetime of ailments.
This "Green chemistry" approach has been proven for years in the chemical industry to produce lower operating costs, reduce waste, eliminate injuries and increase profits.
Industry leading companies rely on this "Green chemistry" to become more cost effective, reduce complex operation and simplify procedures to make operations easier and more reliable, thus, keeping safety simple and obtainable on all levels.
What can you do?
Focus on strengths
Use the strengths of the current “safety” staff and focus on resolution and improvement. If current “safety” staff is technically underdeveloped, send them out for certification and training. If safety is not your area of expertise, the best involvement may be a “supportive role” offering regulatory information, guidance and direction.
Be involved
EHS professionals need to be involved in the early stages of training; if not, personnel and process changes or opportunities to apply valuable principals will be lost. Even a “supportive role” in safety can have dramatic impact on improving an organization.
Stay current
Keep up-to-date on current OSHA regulations and industry safety practices that can help you and your organization. If you aren’t able to stay current, make sure someone in your organization is.
FET can help
On May 20th, FET is holding an “Environmental Health & Safety Update” focused on these principals.
Who will be presenting? (Please see full announcement for details)
OSHA, a top insurance company, a global manufacturing company, a leading safety consultant, a national engineering firm, the Council of EHS Certification, a leading edge defense supplier and industrial manufacturing leaders. Did we leave anyone out?
What are they presenting?
Overview of Regulatory Changes, Employee Orientation Training, Emergency Medical and Incident Response, EHS Assessments, Loss Control and MOD Reduction, Certification and Accreditation Overview, Five Minute Safety Meetings, Site Security and Personnel Control, and Personal Protective Equipment.
Who should attend?
Environmental, human resource, and manufacture managers, owners and anyone who is involved or wants to become involved in safety training, certification, leadership, and improvement.
Summary
Environmental professionals must become much more actively involved in the future of safety in order to achieve common goals.
We still don't know all the answers, but we do know that root causes of both environmental and safety issues go hand in hand, putting the resolution to those problems in your hands.
Christopher Haase
FET Health & Safety Chair
Seminar Details:
May 20th, “Environmental Health & Safety Update,” located at the Midway Hotel Milwaukee/Brookfield, 1005 S. Moorland Road, Brookfield, WI. This is a full day workshop dedicated to improving the safety of our membership.
*Information obtained from AIChE Safety and Health Division, www.shdiv.aiche.org
Clean, naturally
Business, environment not
incompatible, Mequon company finds
By JULIE LARRIVEE - GM Today Correspondent
MEQUON - Environmentally Sensitive Solutions, Inc. (ESS) of Mequon hopes to
make the world a cleaner, safer place.
"Our mission is to increase public awareness of what true environmentally
friendly cleaning products are and to make people aware that cleaning can be
done with more finesse and less brute force," says Matt Pliszka, ESS technical
service representative.
The company recently received a 2004 Governor’s Award for Excellence in
Environmental Performance. ESS was the only small company to be recognized.
The other seven recipients were large corporations.
Two important factors helped ESS earn the Governor’s Award: company products
have helped reduce by 83 million pounds the amount of hazardous materials and
waste emitted by their client’s businesses since 1997; and ESS has
significantly reduced or eliminated costs of wastewater treatment and/or
disposal for their customers.
In the process of manufacturing, Pliszka explains, the part or piece being
fabricated must be cleaned before it can go on to the next step. This process
cleaning means that the part is cleaned several times before it is finished.
The existing products used to clean away things like lubricants, processing
aids and buffing or drawing compounds were solvents that were highly alkaline,
caustic cleaners.
"Our products have a neutral ph - the same as water," he notes. "They will not
burn people’s skin. They aren’t corrosive to the metals being cleaned and they
aren’t hazardous."
Manufacturing companies were somewhat skeptical about the products - until ESS
proved that their products work and that they save the customers money.
"Most people these days are passive environmentalists," Pliszka says. "What we
had to show them was that they could save money by reducing the amount of
wastewater and by reducing the costs of industrial accidents. Their equipment
maintenance costs are lower and there are fewer rejected parts because the
parts get cleaner with our products."
The company wants to retain its small size - employees are "hands-on,
multitaskers," according to Pliszka - as they branch out into consumer
products. The first offering, a dishwasher detergent, will be available this
fall once the naming and labeling process is completed.
"In industrial cleaning, the whole purpose is to clean without human touch,"
Pliszka explains. "That’s exactly what your dishwasher does. Right now,
there’s no real gentle cleaner out there. What is available is harsh. The
purpose of the cleaner is to ‘chew’ the soil off. They are caustic and attack
both the soil and the surface.
"Our cleaner uses a ‘spatula effect’ where it works under the debris and lifts
it off with no harm to the surface. So, you’ll be able to put your fine china,
crystal and pots and pans in the dishwasher without damaging them."
More information about Environmentally Sensitive Solution can be found at
www.neutralsolution.com.
What's is a name?
Christopher
(Greek)
~ meaning ~
Bearing Christ
~ motivation ~
To make the best of what you have
~ character ~
Is law abiding
~ feelings ~
Needs to be needed
~ intelligence ~
You are noted for your creativity
~ spiritual ~
Is sure of their direction
~ nature ~
Does not like leaving things unfinished
~ inherent ~
You are known for your sense of humor
Haase is a German Lowlands version of the English name Hare, which was the nickname for the fast runner, or a person of nervous or timerous nature. Other cognate forms are Hase (German); Haas, Haase (Low German); De Haese (Flemish); De Haas (Dutch); Haas (Jewish ornamental). Hare is also found among the Irish as an Anglicized form of O hAichir , which meant " descendant of Aichear, " whose name meant fierce, sharp. Variations of the Irish name are Hair, Haire, O'Haire, O'Hare, O'Hagher, O'Hahir, O'Hehir .