By Adam R. Young and Meagan Newman
On June 1, 2015, federal OSHA released an Interpretation Letter requiring that employers train employees on the laundering requirements of fire retarding (FR) and arc-rated clothing.
The question, submitted to OSHA by the United Association of Plumbers and Pipefitters, sought OSHA’s enforcement position on the Personal Protective Equipment (PPE) Standard, 29 C.F.R. §
Continue Reading OSHA Says You Should Train Employees on How to Do Their Laundry
By Brent I. Clark, Adam R. Young, and Craig B. Simonsen
Federal OSHA has recently revised and re-published its “General Industry Digest” (Digest). OSHA 2201-08R 2015.
The Digest gives an overview of OSHA’s general industry standards to aid employers, supervisors, workers, and safety and health professionals in achieving compliance.
The Digest provides summaries of the “standards
Continue Reading OSHA Updates “General Industry Digest”
By Patrick D. Joyce and Philip L. Comella
Today, the U.S. Environmental Protection Agency issued two proposed rules lowering the threshold at which landfills must control methane gas emissions.
For active landfills, EPA proposes to reduce the threshold from 50 metric tons of non-methane organic compounds annually to 34 metric tons. As a practical matter, this means that roughly 100
Continue Reading EPA Proposes Significant Change to Controlling Landfill Gas Emissions
Philip Comella, in a recently published article, writes about how everyone in the landfill gas industry knows how contracts are a necessary evil.
The parties understandably focus on the engineering aspects of the design; how many wells and engines to install; how to increase or extend gas production; how the gas production translates into revenue; the status of carbon
Continue Reading Avoiding Disputes Down the Road: The Top Ten Problems With Landfill Gas Contracts
By Brent I. Clark and Craig B. Simonsen
OSHA has just published a Standard Interpretation (Interpretation) to provide guidance on the enforcement of the Process Safety Management (PSM) Standard’s “recognized and generally accepted good engineering practices” (RAGAGEP) requirements, including how to interpret “shall” and “should” language in published codes, standards, published technical reports, recommended practices, and similar documents.
By Brent I. Clark and Craig B. Simonsen
OSHA and its sister agency the National Institute for Occupational Safety and Health (NIOSH) have just released a “Hazard Alert” on Worker Exposure to Silica During Countertop Manufacturing, Finishing and Installation.
We had previously blogged about NIOSH’s “Hazard Alert” for Worker Exposure to Silica During Hydraulic Fracturing. In addition,
Continue Reading Hazard Alert on Worker Exposure to Silica in Countertop Manufacturing Industry
The U.S. Environmental Protection Agency (EPA) today released a proposed rule that would update air standards for new municipal solid waste landfills (landfills). 79 Fed. Reg. 41796 (July 17, 2014).
The Whitehouse had, earlier this year, issued an update to President Obama’s Climate Action Plan “Strategy to Reduce Methane Emissions.” The update specified that in the
Continue Reading EPA Proposes Updated Methane Limits for New Municipal Landfills and Requests Comment on Whether and How to Update Emissions Guidelines for Existing Landfills
By James L. Curtis and Craig B. Simonsen
Members of the U.S. Senate Committee on Health Education Labor and Pensions, including sixteen Senators, have asked the Occupational Safety and Health Administration to extend its extended public comment period on its Notice of Proposed Rulemaking on Occupational Exposure to Crystalline Silica for a full ninety days.
We had previously blogged on
Continue Reading Senators Ask OSHA to Consider the Fracking Industry Economy and to More Fully Extend the Comment Deadline for Proposed Silica Worker Exposure Hazards Rule
By James L. Curtis and Craig B. Simonsen
The Occupational Safety and Health Administration has extended the public comment period for an additional forty-seven days on the Notice of Proposed Rulemaking on Occupational Exposure to Crystalline Silica. 78 Fed. Reg. 65242 (Oct. 31, 2013).
We had previously blogged on the significant OSHA proposal that is intended to lower worker exposure
Continue Reading OSHA Extends the Comment Deadline for Proposed Silica Worker Exposure Hazards Rule
By James L. Curtis and Craig B. Simonsen
The Occupational Safety and Health Administration has just proposed a rule that is intended to lower worker exposure to crystalline silica, which it claims “kills hundreds of workers and sickens thousands more each year.” 78 Fed. Reg. 56274 (September 12, 2013). The proposal is aimed at curbing lung cancer, silicosis, chronic obstructive
Continue Reading OSHA Proposes Silica Worker Exposure Hazards Rule