FPA Groups Assess OSHA, Nano Rules
OSHA’s plan to overhaul its Process Safety Management (PSM) regulations, and the EPA’s proposal to change reporting rules for nano materials were top agenda items at the most recent meeting of FPAs Environment and Safety Committees.
Here are specifics on government actions that will impact the flexible packaging industry in a number of areas:
Changes to PSM Regulations
OSHA’s PSM regulations could be changed as the agency intends to undo its Meer decision by including the flammables stored in atmospheric tanks when they are connected to a covered process. The change is driven by a Federal Executive Order to improve chemical facility safety and security; it stems from the catastrophic explosion at a West Texas fertilizer plant. OSHA’s Lisa Long, Acting Deputy Director for Standards and Guidance, detailed the agency’s current thinking to the FPA committees.
One action related to the issue is FPA’s decision to join a review panel created under auspices of the Small Business Administration (SBA). Bruce Lundgren and Taryyaba Waquar from SBA explained the Small Business Advocacy Review Panel concept. FPA decided to participate in the panel addressing PSM. FPA staff is following up to fully understanding and meet membership requirements.
Proposed Nano Reporting
John DiLoreto of European organization NanoReg cited the EPA’s April 6, 2015 proposed Reporting and Record Keeping Requirements for nano material. DiLoreto noted that while the rulemaking falls short of pre-manufacturing notification, its inventory notices of new uses could be so expansive that it regulates many ongoing uses of nano materials.
ISO 14001 Update
ISO’s 14001 program also made the agenda with the American Chemistry Council’s Dan Roczniak addressing ISO’s work to update the program. Concerns include the prescriptive nature of the updates. The International Labor Organization (ILO) seems to be trying to structure the standard into a legal framework for developing European and Asian countries, according to observers; they particularly see an emphasis on worker participation in the managerial decision-making process.
Toxic Substances Control Act (TSCA)
TSCA overhaul legislation has cleared both the U.S. House and Senate, and Mike Walls, Executive Vice President of the American Chemistry Council, expects to see legislation enacted by year’s end.
More OSHA and EPA Initiatives
Other items on the program include more information on OSHA programs. Marle Martinko of the Society of the Plastics Industry expanded on OSHA’s NEP program for Isocyanates.
From the EPA, Jessica Young and Jim O’Leary discussed details of the Hazardous Waste Generator Improvement program. Important to FPA members is the expected greater flexibility for episodic generation and waste consolidation including preparing a simplified contingency plan and emergency response.
For a detailed report on the committee proceedings, go to www.flexpack.org and click on “Meeting Presentations.”