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Q&A: Fall Protection for a Ladder Enclosed in a Cage

Recently, we received the following question from a subscriber: I need to install a 30-foot fixed ladder as a secondary egress point for an underground pump station. There are two intermediary levels where a step-off will be required. What type of fall protection would be required if I enclose the ladder in a cage?

Prepare for an OSHA Rapid Response Investigation: How to Conduct a Root Cause Analysis Without Raising Red Flags

By: Valerie Butera, Esq. Although OSHA’s new reporting rule has been in effect for less than a year, it has caused some major changes in the way that OSHA operates. Since the new reporting rule went into effect on January 1, 2015, OSHA has received 200 to 250 reports of work-related deaths, inpatient hospitalizations, amputations, […]

TSCA Reform Bill Supported!

It appears that the U.S. Senate will approve the Frank R. Lautenberg Chemical Safety for the 21st Century Act (S. 697) before the end of 2015. The bill, which has the general support of the chemical industry and some major environmental groups, would amend many provisions of the 1976 Toxic Substances Control Act (TSCA). Under […]

State vs. Federal Container Rules

Do states follow the federal requirements for the management of containers used to store or accumulate hazardous waste? Yes. Why? Because they have to. Do some states have container rules that are stricter than the federal rules? Yes. Why? Because they can. Under RCRA, a state’s hazardous waste provisions must be as strict as the […]

Five Essential Elements of a Total Worker Health Program

Each year in the United States, about 4,500 workers die from work-related injuries, and more than 50,000 die from work-related illnesses. More than 3 million suffer nonfatal occupational injuries or illnesses; 2.8 million are treated in the emergency department; and 140,000 are hospitalized. The price tag to employers reaches $250 billion each year. Although employers […]

States Petition to Stay the Clean Power Plan

Promptly upon EPA’s publication of its Clean Power Plan (CPP) in the Federal Register, a coalition of 23 states requested that the U.S. Court of Appeals for the D.C. Circuit stay the rule and consider its petition for review. The CPP requires that states take actions to reduce emissions of carbon dioxide (CO2) from existing […]

Is it a Hazardous Material?

We ship empty methyl-ethyl ketone (MEK) containers by truck back to the supplier for refill. Must we classify them as Hazardous Material since the empty containers have only residual amount of MEK left in them, or is there an empty container exemption?

Models for a Reformed TSCA?

While the U.S. Congress does its annual dance about reforming the Toxic Substances Control Act (TSCA), the Government Accountability Office (GAO) took a look at some chemical programs alive and well in other countries. Was this an attempt to nudge Congress into action? Might a reformed TSCA look like any of these programs? Let’s take […]