The FPA annual Environmental, Health and Safety Summit was attended by EHS professionals and managers, at corporate and facility levels. For over 20-years, the FPA EHS Summit has become the best resource for regulatory updates and compliance guidance on regulatory issues relevant to the flexible packaging industry. It continues to be an excellent forum for FPA members and non-members to network with each other, share best practices, and interact with U.S. EPA and OSHA representatives, and industry professionals. The presentations with significant “take-home value” and the opportunity to meet with regulators, has made the Summit a great success. The attendees feel the conference is “time well spent” as it helps them develop and focus on compliance strategies that work.
In all, including both Safety and the Environment, there were a total of 22 presentations. The representatives from EPA and OSHA, law firms and industry consultants volunteered their time to present at the Summit on topics that help flexible packaging industry professionals improve compliance processes. A few sessions were given by FPA member companies sharing their experiences dealing with facility compliance and permitting at the state and federal levels. These presentations and Case Studies are exceptionally valuable to plant managers and EHS coordinators.
FPA ENVIRONMENTAL AND SAFETY COMMITTEE IN ACTION
The FPA Environmental and Safety Committee met a day before the 2½ -day Summit and all conference registrants were invited to attend. During the committee meeting, FPA staff reviewed the quarterly Environmental Issues Index that includes a summary of relevant regulatory issues and FPA focus. To maximize the benefits of each presentation, members were encouraged to develop questions for presenters. The process helped to enhance the take-home value and answer questions that may not have been asked during the summit.
Although all eight presentations at this day long Safety Conference had relevance to attendees, the session on “Recent developments at OSHA” was particularly important. It summarized OSHA’s thinking on revising the Process Safety Management Standard under President Obama’s Chemical Security Executive Order and filling the gaps left by the court’s MEER decision (stored flammables in “atmospheric tanks”) that was favorable to the industry. FPA intends to monitor developments and submit formal comments when it is proposed.
When it comes to implementing the Electrical Safety Work Practices and the revised 2015 NFPA 70E Standard, it was emphasized that a cultural shift for management and site staff will be needed to achieve the mandated safe work environment. Other topics discussed were the data-sharing requirements following the audiograms, OSHA’s Injury and Illness Prevention Program, the development of plans to mitigate combustible dust exposure, and managing the contractor safety from operational and legal perspectives.
The Environmental section of the Summit was a 1½ day program. It began with a key note from EPA’s Region IV Director of Enforcement who shared the Federal EPA program priorities for 2015 and 2016, providing unique insights on agency funding and how EPA Regional Offices prioritize their programmatic goals.
EPA’s Deputy Associate Assistant Administrator for Environmental Justice (EJ) presented an overview of the publicly available EJ screening tool used in developing the environmental and demographic indicators. The agency uses the EJ indicators to determine further action to protect the health of communities over-burdened by pollution. The industry involvement with communities is critical as EPA begins to integrate environmental justice into the Agency’s programs, policies and activities.
The recently promulgated “Definition of Solid Waste Rule” and Industrial Wipes Rule were the focus of a presentation given by Tracy Atagi of the EPA Office of Resource Conservation and Recovery. FPA has been engaged in the rule development since its beginning and this interactive session was of immense value to FPA members.
The impact of digital printing on sustainability, assessing migration and chemicals of concern in flexible packaging, end-of-life options for non-recycled packaging waste, best practices for managing the recyclables, and keeping resin pallets out of marine environment were other topics presented.
The Assistant Director, Bureau of Consumer Protection, Federal Trade Commission updated the audience on FTC “Green Guides” which the agency is aggressively using to protect consumers against misleading and deceptive environmental claims. It was communicated that packaging manufacturers may have a fiduciary duty but are not responsible for labeling claims they print for their customers.
The content rich presentations, opportunity to dialog with presenters and including Case Studies in the agenda are all seen as contributing to the overall success of the Summit.
The 2016 FPA Environmental, Health and Safety Summit is planned for January 26-27, 2016, at the TradeWinds Island Grand Resort, St. Petersburg Beach, FL. Registration will open in fall 2015.
Ram K. Singhal, Vice President, Technology & Environmental Strategy, Flexible Packaging Association