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Compliance Technologies, Inc. (CTI)
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chimney of an industrial company a wake smoke. symbolic photo for environmental protection and ozone.
June, 2015

Welcome to CTI's Quarterly eNews communication that is packed with information on the latest workplace Health & Safety regulations, information, insights and compliance stories that may affect your company's day-to-day business.  Click the link to learn more about CTI's Team of Engineers, Trainers, Project Managers, and day-to-day operations professionals.  CTI Team
Toxic Release Inventory (Form R) Reporting Deadline is July 1, 2015

If you are among the companies required by Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) to report on chemicals deemed by EPA to be hazardous, be sure to file either your Form R or Form A reports by July 1st.   Failure to do so can be a doubly costly mistake as the consequence includes both fines (typically $20,000 to $40,000 per facilityplus the expenses of back reporting (usually an additional $2,000 to $6,000 per facility)! With so much at stake, why do companies fail to properly report?  Our experience indicates that even well-intentioned companies can overlook proper TRI Reporting due to:

  • Using old templates or calculations to erroneously conclude that the chemicals they manufacture, process and/or use never reach the threshold quantities, triggering the need to report. Note: This is an especially prevalent mistake since, until this year, no changes to the TRI List had been made in over a decade; in 2015, 11 new chemicals have been added to EPA's Consolidated List of Lists.  Learn More
  • Companies forget that the total amount of a TRI Chemical, including those contained in mixtures, must be added together to determine if the threshold quantity for that chemical has been exceeded.  Metal alloys and mixtures with hazardous components often get overlooked.
CTI will gladly assist with your TRI Reporting, even if you find you should have reported in the past or simply do not have the expertise to comply with the filing requirements.
Air Permitting
Does my business need an Air Permit or two or three?


Air Pollution Permits are required for air contaminant sources.  Some businesses may have a number of sources at its facility, even small businesses.   Each source requires a separate permit unless it is specifically exempted.

Do I need an Air Permit for my Business?

An Air Contaminant source is defined as anything that emits an air pollutant.  Listed below are four rules to assist in identifying an air contaminant source:
  • Something that has a stack, dust collector or vent.  Examples would be woodworking operations, grinders, & storage tanks.
  • A process that uses paints, solvents, adhesives, and inks.  Examples would be paint booths, printing operations, and solvent cleaning tanks.
  • A process that burns fuel (gas, oil or coal).  Examples would include boilers, furnaces & heating processors.
  • A process that produces visible dust, odors and / or smoke. This includes material handling operations, unpaved roadways, sand blasting operations, & incinerators.

Required Permits 


Most small businesses need what is called a permit-to-install and operate (PTIO).  This PTIO is required before installing and operating an air contaminant source.  A PTIO lasts between 5 - 10 years and is renewable.  Unless it is exempt, you need a PTIO for each air contaminant source at your facility. 


Not obtaining an Air Permit or installing an Air Contaminant Source without first obtaining a PTIO could result in fines and / or shut down of the air source until a PTIO has been obtained and fines paid.  Click here to learn more about Air Permits.


Importance of Injury Trend Analysis
Guest Article by Andy Lembach, Spooner, Inc.

Vice President of Business Development

We need to be compliant with OSHA. Got It!

We need to be compliant with EPA Standards.  Got it!

We have a safety program in-place and we're compliant with all the safety and environmental regulatory bodies, so why are we still having injuries? The answer may lie in the results of an injury trend analysis.

A local food manufacturer was in this same situation two years ago. They asked their third party administrator for workers'comp to perform an injury analysis.  The results showed that a number of minor and serious accidents were the result of slip and fall type injuries.  The company reviewed several options to prevent the injuries from happening in the future.  The company made it mandatory that all employees wear slip resistant shoes.  The company experienced a drop in OSHA recordable accidents related to falls and dramatically lowered their workers'comp related costs.

Ask your third party administrator (TPA) for workers' comp to assist your company in putting together an injury trend analysis.  You might be surprised to see that some of the injuries are to the same body part, same type of injury, or in the same department.  CTI and Spooner can develop solutions that will get you trending toward fewer copy cat injuries.

When you think regulations cannot get any more intrusive . . .
When it comes to Lawmakers, "bringing home the pork" has taken on a whole new meaning! Recently, a Missouri State Senator, Eric Schmitt, initiated a #porksteakrebellion when he discovered the EPA had funded a $15,000 University of California-Riverside study to look at the particulate emissions we breathe when grilling over an open flame.  Along with a drip tray, the proposed emission removal system would contain a specialized metal filter, a metal fan blade, a drive shaft and a power system with either automatic or manual control, according to the study. If these Engineering Controls prove ineffective, what's next?... BBQ PPE suits with accompanying full-face gas masks (for fumes and splatter)?

According  to Fox News, the EPA counters that" it doesn't intend to regulate people's backyard barbecues and the grant is part of EPA's 'National Student Design Competition for Sustainability Focusing on People, Prosperity and the Planet (2014)', which is a student-designed competition for sustainability".  What will they "cook up" next?

Outdoor Hazards


Protecting Workers from the Heat 

As we approach the summer months in many areas across the country, heat related illnesses become more common.  Workers in outdoor industries such as agriculture, construction, landscaping, and transportation face the greatest risks.  OSHA states that three simple steps should be taken on hot days - Water, Rest, and Shade.  These steps can have a huge impact on the health and well-being of all outdoor workers.  To learn more about heat related illnesses and hazards and what steps to take while at work, click on the link below:

Safety is Not Only  for the Workplace    
Health and safety register with goggles and earphones
June is  National Safety Month  and on June 9th the National Safety Council released  its annual list of states ranked by the rate of "unintentional injury-related deaths, which includes fatal poisonings, car crashes and falls (unrelated to workplace incidents).  Where you live can make a difference on these risks.  

Maryland, for the second straight year, had the lowest/best rate of 26.9 deaths per 100,000 people, far below the national average of 40.6.  West Virginia had the highest rate of 77.2 for the third time in four years, comprised largely of overdose deaths from opioid prescription painkillers.  Surprisingly perhaps due to its icy winters, Ohio ranked thirtieth with a 45.7 rate (still above the national average). 


Unintentional injury deaths have overtaken strokes as the fourth leading cause of deaths in the U.S. For more about the leading causes of unintentional injury death, visit nsc.org/statedeathrates.

Injury & Illness Recordkeeping & Reporting Requirements                                       


Do you know what is required under OSHA?

OSHA Recordkeeping regulations (29 CFR 1904) states that covered employers are required to prepare and maintain records of all serious occupational injuries and illnesses, using the OSHA 300 Log.  This log is important to employers, employees, and OSHA as it allows for the evaluation of a workplace, an understanding of industry hazards, and the implementation of work place protections to reduce and / or eliminate work place hazards.
Back on September 11, 2014, OSHA announced changes to the following:
  • List of industries that are exempt from requirements
  • List of severe work-related injuries & illnesses that all covered employers must report to OSHA
  • New requirements went into effect January 1, 2015
These new rules are intended to improve workplace safety and health through improved tracking of workplace injuries and illnesses.   Further info

CTI can assist with your company's OSHA Injury and Illness Recordkeeping & Reporting Requirements, including how to complete forms, types of operations that come under these rules, and types of injuries and illnesses that must be recorded.  Please contact us with any questions or for further details.

Kathy Grattino
Compliance Technologies, Inc.
In This Issue
Quick Links
Top 10 OSHA Citings of 2014
Storm Water Regulations
HazCom Deadlines for 2015 - 2016
June is Safety Month 
With all the outdoor activities and outdoor industries, be extra cautious on hot, humid days.

June 1, 2015

All manufacturers must NOW comply with new label/SDS requirements.


Dec 1, 2015

Distributors may not ship products without new GHS labels.


June 1, 2016

Employers must update alternative workplace labeling and HazCom programs, including re-training.


HazCom Effective Dates  

EPA Top 10 Violations 


1.  Hazardous Waste (RCRA) - No Inspections; Personnel Training; Emergency     Preparedness; Container Management; Marking/Labeling; Waste Determination; Used Oil; Universal Waste; Closure / Financial; Transporter Requirements; Satellite    Accumulation.


2.  Clean Air Act - Failure to Apply for a Permit.


3.  Clean Air Act - Failure to Comply with Recordkeeping Requirements.


4.  Clean Water Act - Failure to Follow Conditions of Permitted Discharge to a POTW (public owned treatment works).


5.  Clean Water Act - Failure to Develop and Implement a Storm Water Pollution Prevention Plan (SWPPP).


6.  Clean Air Act - Failure to Comply with Operating Permit.


7.  Clean Water Act - Failure to Develop and Implement a Spill Prevention, Control, and     Countermeasures Plan (SPCC).


8.  Clean Water Act - Failure to Provide Secondary Containment (Oil).


9.  Clean Water Act - Failure to Complete Inventory of Oil Storage in Tanks & Equipment (Oil).


10.  UST (RCRA) - Failure to Register USTs and/or Complete Recordkeeping.


CTI Celebrates 
25 Years!


 CTI has been serving Ohio companies since its inception in May,1990. The CTI staff is excited and proud of this great accomplishment and looks forward to serving our clients for many years to come.


The  Manufacturing News From Wire-Net  recently published a profile article on Compliance Technologies entitled "Twenty-Five Hazardous Years in business".  CTI is proud to have reached this landmark of service to our clients and wish to share the article with you.    Read the entire article   
CTI would like to thank Andy Lembach of Spooner, Inc. for providing the guest article on Trend Analysis Studies in our quarterly newsletter.
Thank You creative Sign
Questions for Andy?  Andy can be reached at Spooner, Inc. at 440-249-5214 or email him at alembach@spoonerinc.com.
Did you Know . . .

Respiratory Protection Training, Medical Evaluations and Fit Testing are required when:
  1. Initially (before using a respirator);
  2. Annually thereafter;
  3. When a change is made in the type/brand of respirator or cartridges;
  4. Repeat, as necessary, to ensure safe use

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