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EVERYTHING EHST BLOG - September 2024

WORKER HEALTH & SAFETY

Emergency Preparedness and Communication

With 86% of employees reporting having experienced a workplace emergency, there's an increased focus on emergency preparedness. Employees are calling for better safety communication and greater transparency from employers regarding safety efforts. This trend emphasizes the need for improved emergency response training, clear communication protocols, and regular safety updates to ensure workers feel prepared and informed.

 

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ENVIRONMENTAL PROTECTION

Per- and Polyfluoroalkyl Substances (PFAS) Regulation

PFAS, often called "forever chemicals," have become a major concern for environmental practitioners. Key aspects include:

1. Developing and enforcing new regulations for PFAS in drinking water and consumer products

2. Assisting industries in finding alternatives to PFAS in manufacturing processes

3. Managing PFAS contamination in soil and water resources

 

The EPA has finalized new rules to regulate PFAS (per- and polyfluoroalkyl substances) under the Safe Drinking Water Act. On April 10, 2024, the EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS compounds. This regulation sets legally enforceable Maximum Contaminant Levels (MCLs) for these substances in drinking water:

§  PFOA and PFOS: 4.0 parts per trillion (ppt)

§  PFHxS, PFNA, and HFPO-DA (GenX): 10 ppt

§  A Hazard Index of 1 for mixtures containing two or more of PFHxS, PFNA, HFPO-DA, and PFBS.

 

The regulation will be effective 60 days after publication in the Federal Register. Water systems have:

§  3 years from the effective date (by 2027) to complete initial monitoring

§  5 years from the effective date (by 2029) to implement solutions if PFAS levels exceed the standards.

 

The EPA is making $1 billion available through the Bipartisan Infrastructure Law to help states and territories implement PFAS testing and treatment at public water systems and assist private well owners in addressing PFAS contamination. In terms of impact the EPA estimates that:

§  4,100 to 6,700 public drinking water systems (out of 66,000) will need to take action to reduce PFAS levels.

§  The regulation will reduce PFAS exposure for approximately 100 million people.

§  It will prevent thousands of deaths and reduce tens of thousands of serious PFAS-attributable illnesses over time.


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HAZMAT TRANSPORTATION

Regulatory Compliance and Updates

Staying compliant with evolving regulations remains a critical concern for hazmat professionals in particular adapting to new EPA regulations on PFAS (per- and polyfluoroalkyl substances)

 

The EPA has recently taken significant steps to regulate PFAS substances:

1. On April 19, 2024, the EPA announced a final rule designating two PFAS compounds - perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) - as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).

2. This designation will require reporting of releases of PFOA and PFOS that meet or exceed certain quantities to the National Response Center and appropriate state or tribal emergency response authorities.

3. The rule will take effect 60 days after publication in the Federal Register.

4. The EPA has also issued a PFAS Enforcement Discretion and Settlement Policy, indicating that it will focus enforcement efforts on parties that significantly contributed to PFAS contamination, such as manufacturers and industrial users of PFAS.

 

Impact on Hazmat Transportation Industry

While not directly addressing transportation, these new regulations will likely affect the hazmat transportation industry in several ways:

1. Increased reporting requirements for releases during transportation.

2. Potential liability for transporters involved in PFAS-related incidents.

3. Need for updated training and protocols to handle PFAS substances in accordance with new regulations.

4. Possible changes in packaging and handling requirements for PFAS-containing materials.

5. The Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) is conducting research related to PFAS and other emerging hazardous materials by exploring ways to reduce risks associated with hazardous materials transportation and identifying strategies for reducing PFAS and other harmful materials in packaging.

 

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EMERGENCY RESPONSE

Emergency Response and Incident Management in Transportation

Improving emergency preparedness and response capabilities continues to be a priority where professionals are discussing:

1. Enhancing training programs for first responders dealing with hazardous materials incidents

2. Developing more effective communication protocols during emergencies

3. Leveraging data analytics to identify trends and improve incident prevention strategies

These efforts aim to minimize the impact of potential accidents and ensure swift, effective responses to hazmat incidents

 

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