CTI ENewsletter - Summer  2016
August, 2016

Welcome to CTI's Quarterly ENewsletter  that is packed with information on the latest workplace environmental, health, and safety regulations, information, insights and compliance stories that may affect your company's day-to-day business.  Click the following link to learn more about CTI's Team of Engineers, Trainers, Project Managers, and day-to-day operations professionals.  CTI Team  
Required Testing of Emergency and Exit Lighting
Exit sign with lights on each side
Emergency lighting, including exit signage, is subject to a 30-second test every month and an annual 90-minute test to ensure that the system will function correctly in the event of an emergency. 
Did you know that you are required by law to have and regularly test emergency exit & emergency lighting systems? Do not take a chance with such serious matters; avoid serious liabilities and fines by having, maintaining and testing adequate exit and emergency lighting systems in your building(s). 

roof of the white house
TSCA - First Reform in 40 Years

On June 7, 2016, the Senate passed the House Amendments of the Frank R. Lautenberg Chemical Safety for the 21st Century Act  (HR 2576) which resolved a debate over preempting States from enacting their own requirements. Currently almost 30 states, led by California, have passed more than 100 laws regulating chemicals. The final version of HR 2576 will allow States an additional year to regulate some substances before EPA could preempt them.  EPA can then retain enacted state regulations and laws for chemicals, but temporarily stop new regulations while the agency is assessing a chemical's risks. The Bill was then sent to the President on June 14th  for signature which he signed into law June 22nd. 
OSHA Penalty Adjustments Took Effect August 1, 2016
In November 2015, Congress enacted legislation requiring federal agencies to adjust their civil penalties to account for inflation. The Department of Labor has now adjusted penalties for its agencies, including the Occupational Safety and Health Administration (OSHA).
OSHA's maximum penalties, which were last adjusted in 1990, have increased by 78%. Going forward, the agency will continue to adjust its penalties for inflation each year based on the Consumer Price Index.
The new penalties took effect as of August 1, 2016.  Any citations issued by OSHA after that date will be subject to the new penalties, if the related violations occurred after November 2, 2015.
The adjustments are intended to correct for inflation and, of course, give added incentive to address and correct any safety issues which still lurk in your operations. Not sure where or how to begin?  CTI will assist you with your OSHA compliance.  Just give us a call and let's get started before such penalty fees only add more cost to correcting the underlying safety issues.

Summer Heat Hazards
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2 ,630 workers suffered from heat illness and 18 died from heat stroke and related causes on the job in 2014. The bittersweet news is that those deaths are totally preventable, provided you provide enough water, rest breaks and shade (or a cool place) to allow workers to recover when the onset of heat exhaustion or heat stroke is likely.
OSHA has again kicked off its summer campaign to inform employers and  em ployees about the dangers of working in the heat. Their updated heat campaign webpage  provides illustrations of heat exhaustion and heat stroke, an animated video, and links to an updated heat safety phone app. OSHA's spokesperson, Kelly Schnapp, also noted in a recent White House webinar that "a majority of rec ent heat-related deaths investigated by OSHA involved workers
 on the job for three days or less - highlighting the need for employers to ensure that new workers become acclimated to the heat when starting or returning to work."
So, when the risks of extreme heat are high, so too should be your awareness of what to do to help your co-workers prevent heat-related illness. It will help them, and you, from becoming the "hot topic of the day"!

Will OSHA's new Record-keeping Regulations Improve Safety?
Much debate still exists about OSHA's final rule on record-keeping and, more importantly, on OSHA making that information public.  Here, again, are the facts (as first published in Industrial Safety & Hygiene News):
FACT: Under the new rule, all establishments with 250 or more employees in industries covered by the record-keeping regulation must electronically submit to OSHA injury and illness information from OSHA Forms 300, 300A, and 301. Establishments with 20-249 employees in  certain industries must electronically submit information from OSHA Form 300A only.
OSHA logo
The new requirements take effect August 10, 2016, with phased-in data submissions beginning in 2017. These requirements do not add to or change an employer's obligation to complete and retain injury and illness records under the  Recording and Reporting Occupational Injuries and Illnesses regulation .
AND THE INDUSTRY REACTION:   OSHA's new electronic recordkeeping rule is not ... Read more here...
Operations Excellence
Upping Your Game Up
Guest Author: Ty Haines
President of Manufacturing Solutions, LLC

It is relatively easy for each of us to see the places where our company is performing well - our time is rarely pulled to these areas. Most companies in business for years have pockets of excellence. The top management's challenge is to outperform the competition - at least in the eyes of the customer. Enter the Operations Excellence (OE) process to build the company to potential through appropriate combinations and integration of current business practices. It combines tools from many areas to improve the Customer experience both with internal and external customers. The continuous improvement Culture from ISO an Lean are leveraged to help drive a more robust business culture.
strategic plan image summary of article
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OE is un-simply the coordinated execution of our business best practices and learnings to date:  

The OE improvement process is classic and compatible with Six Sigma's DMAIC and PDCA:
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  1. Assessment of present states in key areas of the business
  2. Gap Analysis
  3. Planning & Prioritization
  4. Training, as needed
  5. Implementation
  6. Verify improvement, support the changes
DMAIC: Define, Measur e, Analyze, Improve, Control
PDCA: Plan, Do, Check, Act

The usual driver for change is that the company is feeling pain in an area or two. The company allocates resources to determine the root cause, formulate corrections and initiate the change. Manufacturer Solutions, LLC is often called in to organize and supplement internal efforts. Past and present projects include restarting Lean, finding and fortifying gaps between Product Development and Production and helping managers better define and communicate expectations. These improvements may draw on resource expertise in organiz ation development, engineering, quality and management.
Many companies have started this improvement process by focusing efforts on a problem area, then another. This works but at some point it pays to examine the  company as a whole to optimize integration of techniques,  policies, culture and to isolate the remaining gaps for  improvement.

About the author: Ty Haines became President of Manufacturer Solutions, LLC in 2011. He served as VP Manufacturing at WIRE-Net leading services to over 500 manufacturers each year. He has a MS Engineering over a BS in Business. Experience began in Production in 1979, grew into Engineering & Development and added Quality Assurance in 1990. He has talked on topics from Competing with China to Lean to providing input to the US Congress. Mayor Jackson recognized and awarded his leadership on the City Operations Efficiency Task Force.

picture of samantha
CTI is pleased to announce a new addition to the EH&S consulting team. Samantha Slone has accepted the position of Business Coordinator with the company effective August 15, 2016.

As the Business Coordinator, Samantha's responsibilities will include assisting existing and new clients in:
  • Staying current on regulatory compliance through CTI's Newsletters, Blogs, and other marketing releases
  • Coordinating new and refresher training on OSHA, EPA, and DOT/IATA/IMDG regulations
  • Directing inquiries to the Consulting Specialist who can best respond to the customer's specific environmental or safety needs
  • Resolving any Accounting questions while processing invoices/payments in a timely manner
  • Providing excellent customer service

  • Coupled with an Accounting Degree from Maryland University College, Samantha's experience and a proven track record in customer service, accounting, business management, forecasting, and event scheduling will be valuable assets in meeting CTI's client needs. 

    Please join us in welcoming Samantha to Compliance Technologies, Inc. while letting her know how CTI can be of assistance to you.

    Samantha can be reached at 216-341-1800 ext 10 or by email at sslone@compliancetechnologies.biz
    In This Issue
    General Deadlines for Additional Reporting 
    in  2016
    June 1 - Sept 30, 2016

    Chemical Data Reporting (CDR) for Toxic Substances Control Act (CY 2012, 2013, 2014 & 2015)

    Final HazCom/GHS Deadline has passed (June 1, 2016)
    Still working towards GHS compliance? 
    Quick Links

    Top 10 UST Violations
    Top 10 OSHA Citings of 2015
    Did you Know . . . 

    Both new silica standards went into effect June 23, 2016. Industries have one to five years to meet most requirements. The extended time allows employers to provide medical exams to some workers, and gives hydraulic fracturing employers the opportunity to implement dust controls for the new PEL, OSHA states.  OSHA's new Permissible Exposure Limit (PEL) is half the previous limit for general industry and 5 times lower than the previous limit for construction. 
    7 Common Workplace Hazards 
    1. Working at height
    2. Poor housekeeping
    3. Electrical-Extension cords
    4. Forklifts
    5. Lockout/tagout
    6. Chemicals 
    7. Confined Spaces
    Read more here...
    EPA New Guidance Documents: 2016 CDR Reporting
    If your company imports or manufactures chemicals, you may be subject to Chemical Data Reporting (CDR) requirements under the Toxic Substances Control Act (TSCA). The next CDR reporting period is currently taking place from June 1 - Sept. 30, 2016, and will include the years 2012, 2013, 2014, and 2015.
    Companies who import or manufacture 25,000 pounds or more of a chemical in any of the calendar years 2012, 2013, 2014, and 2015 must report the import or production volumes to EPA for each of these years as well as processing and use information for 2015. However, if a chemical is subject to certain TSCA actions, the reporting threshold is lowered to 2,500 pounds.   
    Recently, the U.S. Environmental Protection Agency posted on its website new guidance documents    on CDR reporting thresholds and requirements for substances subject to certain TSCA actions.  Here you can find a clear explanation of the CDR requirements and thresholds along with a discussion of how the CDR requirements may be impacted when chemical substances are subject to certain TSCA actions. Still not sure?   Contact CTI and we can help.

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