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EHS MANAGEMENT CURRENT ISSUES

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Title: EHS MANAGEMENT CURRENT ISSUES


1
EHS MANAGEMENTCURRENT ISSUES
  • ACUA Annual Meeting
  • October, 2007

2
Current Issues
  • Occupational Health Safety
  • Electrical Standard
  • PELs
  • Noise Exposure Std.
  • Motor Vehicle Safety
  • Radiation Safety
  • NRC Sources of Concern
  • Biosafety
  • Dual-Use research
  • Pandemic Flu planning
  • Select Agents
  • Other
  • DHS Chemical Facility Anti-Terrorism Standard
  • Greenhouse Gases
  • Sustainability
  • Proposed Emergency Response Plans for C/U
  • Environmental Due Diligence

3
On the job injuries - 2003
  • 138,988,000 workers in the US
  • 3,400,000 disabling injuries
  • 4,961 on the job fatalities
  • 2,158 fatalities attributed to motor vehicles
  • 3.2 deaths / 100,000 workers
  • 156.2 billion

4
Electrical Standard 1910 Subpart S
  • OSHA promulgated revised electrical standards
    (subpart S)
  • Effective date 8/13/07
  • PEOSH must adopt within 6 months (2/13/07)
  • Used NFPA 70E 2002 as guide
  • Utilities operation exempt (comply with power
    distribution std)
  • Work Practices vs. Installation
  • Predominantly, will affect how we do electrical
    work
  • Installations
  • Generally compliant
  • State DCA Codes
  • Must update installation if overhaul to equipment
    (similar to code upgrades for renovation
    projects)
  • Prohibition on using ground terminals/devices for
    any other purpose
  • Must label equipment
  • Magnitude, approach distance and hazard
    information

5
Requirements for Work Practices (Subpart S)
  • For any work on equipment w/ exposed live parts
  • Lo/To will eliminate need
  • Must assess task for hazard and need for PPE
  • How is up to employer
  • Shock and flash hazard analysis
  • PPE Equipment
  • Based on assessment
  • Gloves, eye/face protection, hearing protection,
    head protection, etc
  • PPE Clothing
  • May need to change uniform
  • Current clothing not adequate for all work
    performed
  • Provide rated shirts, pants, coveralls, jackets,
    etc.
  • GFCI required for all maintenance work
  • No 3/2 prong adapters

6
OSHA Permissible Exposure Limits
  • Concentrations of contaminants in air
  • 8 hour time weighted averages
  • Ceiling limits (not to be exceeded)
  • Exposure for a working lifetime
  • Current OSHA Standards not updated since 1969
  • Occupational vs. Non-occupational exposures

7
Motor Vehicles Safety 2005
  • Deaths 45,800
  • Disabling Injuries 2,400,000
  • Cost 247.7 billion
  • Vehicle mileage 2,967 billion
  • Registered vehicles 245,700,000
  • Licensed drivers 201,500,000

8
Unintentional Injuries Leading Causes
9
Motor Vehicle Deaths - 2003
10
Nuclear Regulatory CommissionSources of Concern
  • Orders for Increased Controls
  • Federal Register 70FR72128, December 1, 2005
  • NRC EA 05-090, November 2005
  • Requires increased security for certain materials
  • -Reduce the risk of unauthorized use, and
  • -Prevent malicious acts.
  • Required licensees to
  • -Control access at all times, and
  • -Limit unrestricted access to only approved
    individuals (trustworthy and reliable
    determination)

11
NRC Sources of Concern
  • NRC Regulatory Issue Summary 200714 (June 5,
    2007)
  • For individuals with unrestricted access
  • Fingerprinting
  • FBI Criminal history records check
  • Additional guidance to be issued in the Fall 2007
  • (Similar to Select Agent Rule)

12
NRC In the News
  • May 2007 - US Government Accountability Office
    fraudulently obtains an NRC license for 6 potable
    moisture density gauges
  • GAO alters NRC license to increase limits to
    allow the purchase of 45 gauges
  • Obtains quotes and gets promise of delivery of
    additional gauges
  • August 2007 NRC requires on-site inspection or
    in-office meeting for new license applicants
  • Caution on transfers of licensed materials

13
DUAL USE RESEARCH
  • National Science Advisory Board for Biosecurity
    (NSABB)
  • Dual Use Research defined as research with the
    potential to
  • Generate valuable scientific knowledge
  • Potentially used for nefarious purposes

14
Dual-Use Research of Concern
  • Enhance the harmful consequences of an agent or
    toxin
  • Impart resistance to clinically/agriculturally
    useful therapeutic agents or enable an
    agent/toxin to evade detection methods
  • Alter the host range or tropism of an agent/toxin
  • Increase the stability, transmissibility, or
    ability to disseminate an agent/toxin
  • Enhance the susceptibility of a host population
  • Disrupt immunity or effectiveness of an
    immunization
  • Generate or reconstitute a biological agent for
    which there are no known or widely available
    therapeutic interventions

15
NSABB Draft Guidance
  • April 2007
  • Proposes that individual researchers identify
    substantive dual use concerns and confer with
    local institutional bodies in managing risks
  • Consistent with NIH and BMBL philosophy
  • Practical Experiences in Dual-Use Review
  • (Science Vol.316, p. 1432-1433, 8 June 2007)
  • (1) Inform research community, and
  • (2) Ensure adequate technical expertise to
    evaluate protocols and concerns

16
Pandemic Flu Resources
  • http//www.pandemicflu.gov/plan/community
  • http//www.osha.gov/Publications/OSHA_pandemic_hea
    lth.pdf
  • http//www.coughsafe.com/index.html

17
Pandemic Flu Planning
  • State Department of Health
  • Pandemic Sheltering Group
  • Formed under EOC (includes Housing, Dining, Res.
    Life, etc)
  • Estimate need for food, shelter, quarantine, or
    medical isolation
  • Define current maximum surge capacity
  • Selection of suitable locations
  • Plan for provision with expectation of 40
    absenteeism
  • Ensure needed supplies
  • Sheltering plan as prototype for other situations

18
Chance favors the prepared mind.Louis
Pasteur
19
DHS Chemical Facility Standard
  • 6 CFR Part 27 Chemical Facility Anti-Terrorism
    Standards (Interim Final Rule)
  • Title 6 Department of Homeland Security
  • CFR Code of Federal Regulations
  • Chapter 1DHS, Office of the Secretary
  • Interim Final Rule published April 9, 2007

20
DHS Chemical Facility Standard
  • Basic Requirements
  • Submit a Top Screen if the facility possesses or
    plans to possess quantities in excess of the
    Appendix A list
  • w/in 60 days of publication of App. A list
  • DHS to rank the facility from Tier 1 (highest
    risk) to Tier 4 (lowest risk)
  • Complete and submit a Security Vulnerability
    Assessment (SVA)
  • w/in 90 days of written notification
  • Prepare and submit a Site Security Plan
  • w/in 120 days of written notification

21
DHS Chemical Facility Standard
  • Submit a Top Screen if the facility contains any
    chemical(s) in excess of the amount listed in the
    Appendix A.
  • Top Screen must be submitted w/in 60 days of the
    final publication of the list
  • Top Screen requires background information on the
    facility
  • Audit of buildings to determine quantities of
    chemicals
  • Designated person must enter information into
    the CSAT system
  • Certification by officer of the university to
    attest to the accuracy of the submittal

22
DHS CSAT Top Screen Questions
  • http//www.dhs.gov/xlibrary/assets/chemsec_csattop
    screenquestions.pdf (Questions)
  • http//www.dhs.gov/xlibrary/assets/chemsec_csattop
    screenusersmanual.pdf (Users Manual)
  • Top Screen security assessment tool to be used to
    determine if the facility presents a high level
    of security risk.
  • Background info on the facility (name,
    description, location, owner, security
    vulnerability assessment, etc.)
  • 80 page workbook, estimate of 30.3 hours to
    complete

23
DHS - Where are we now?
  • University Working group (six higher education
    associations)
  • Anticipated changes to Appendix A
  • Remove any amount thresholds
  • Remove some ubiquitous materials (acetone)
  • Clarify concentrations and mixtures
  • List separated into risk categories some
    chemicals may have thresholds for container size

24
SUSTAINABILITY
  • Components
  • Economic growth
  • Environmental integrity and performance
  • Social equity
  • ISO International Standards Organization
  • DJSI Dow Jones Sustainability Index
  • Global Reporting Initiative http//www.globalrepor
    ting.org/Home

25
SUSTAINABILITY
  • Environmental Performance (Eco-efficiency) and
    Environmental Reporting
  • Total GHG emissions (CO2)
  • Other GHG (CH4, N2O, HFC, PFC, SF6)
  • Total water use
  • Total energy consumption
  • Total waste generation
  • (www.theclimateregistry.org)

26
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27
SUSTAINABILITY
  • Economic Indicators (DJSI)
  • Codes of Conduct / Compliance / Corruption
    Bribery
  • Corporate Governance
  • Risk and Crisis Management

28
SUSTAINABILITY
  • Social Indicators (concept is evolving no
    current standard definition under ISO)
  • How does an organization establish internal
    procedures that create wealth and improve
    society?
  • Corporate Citizenship / Philanthropy
  • Labor Practices (Health and Safety)
  • Human Capital Development
  • Talent Attraction Retention

29
Rutgers Sustainability Activities
  • University Sustainability Committee
  • Recyclemania
  • Sustainable Design criteria
  • Alternative Fuel Vehicles
  • Natural Gas
  • Biodiesel (B-20)
  • Sustainable Purchasing Program
  • Recycled paper
  • Green cleaning chemicals
  • Computers (EPEAT standard)
  • Furniture RFP

30
Greenhouse GasesNJ Executive Order No. 54
  • Greenhouse gas emissions reduction targets
  • Stabilization of emissions at 1990 levels by 2020
  • Reduction of emissions to 80 below 2006 levels
    by 2050
  • California and several other states have adopted
    similar requirements.

31
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32
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33
All Appropriate Inquiries
  • Phase 1 Environmental Site Assessments
  • Due Diligence for Property Transfers
  • EPA Part 312 Innocent Landowners, Standards for
    Conducting All Appropriate Inquiries
  • ASTM E1527-05 Standard Practice for
    Environmental Site Assessments Phase 1
    Environmental Site Assessment process

34
All Appropriate Inquiries
  • Objectives - to determine
  • Current and past property uses
  • Releases of hazardous materials
  • Waste management and disposal activities
  • Current and past corrective actions to address
    releases
  • Engineering controls
  • Institutional controls
  • Adjoining properties that have environmental
    conditions that could have impacted subject
    property
  • Evaluate potential financial impact on the
    property transfer.
  • Note, the property owner is liable for ALL
    environmental cleanup.

35
All Appropriate Inquiries
  • Purpose provide standards and practices for all
    appropriate inquiries pursuant to CERCLA.
  • Applicable to establish one of the following
    liability protections under CERCLA
  • The innocent landowner defense
  • The bona fide prospective purchaser liability
    protection
  • The contiguous property owner liability protection

36
AAI General Requirements
  • Inquiry by an environmental professional
  • W/in 180 days
  • Interviews of past/present owners and operators
  • Searches for recorded environmental cleanup liens
  • Reviews of federal, tribal, state, local govt.
    records
  • Visual inspection of the property and adjoining
    properties
  • Declaration by an environmental professional

37
BIOSAFETY ISSUES
  • Select Agent Program
  • Centers for Disease Control and Prevention (CDC)
    - HHS
  • Animal and Plant Health Inspection Service
    (APHIS) - USDA
  • Overlap agents
  • Particularly hazardous biological agents and
    toxins
  • Viruses (Ebola, Lhasa, Smallpox)
  • Bacteria (Anthrax, Botulinum)
  • Toxins (Tedrotoxin, Staph enterotoxins)
  • Requirements
  • Registration with CDC
  • Appoint Responsible Official
  • Restrict access to only approved individuals
  • Security
  • Inventory control
  • Biosafety Plan
  • Emergency Response Plan
  • Training

38
Select Agents
  • Recent Alleged Violations
  • Salk Institute for Biological Studies
  • Synthesized and possessed conotoxins in excess of
    limit (100 mg) w/o registering with CDC
  • Transfer violations related to possession of
    conotoxins
  • University of South Carolina
  • Failure to amend Registration
  • Inadequate security, biosafety, incident response
    plans
  • Failure to maintain training, inspection,
    inventory records

39
Select Agent News
  • Texas AM
  • 18 member CDC inspection team on site for 5 days
    in July 2007
  • CDC suspended all research operations w/ select
    agents
  • CDC concerns
  • Evidence of select agent work w/o prior approval
    by CDC (aerosol studies with brucella species)
  • Evidence of multiple occupational exposures not
    properly reported to CDC
  • One worker ill from Brucella
  • Three workers exposed to Coxiella burnetti (blood
    tests)

40
Select Agent News
  • Texas AM Alleged violations
  • Inventory control failure to account for 3
    vials
  • Research on developing antibiotic resistant
    strains w/o CDC approval
  • Failure to wear appropriate PPE
  • Unrestricted access w/o FBI approval (security
    risk assessment)

41
BIOSAFETY NEWS
  • Congressional Hearings on Biosafety labs
  • Germs, Viruses, and Secrets The Silent
    Proliferation of Bio-Laboratories in the United
    States
  • Rep. John Dingell (D-MI), Chair of the Committee
    on Energy and Commerce
  • Bart Stupak (D-MI), Chair of the Subcommittee on
    Oversight and Investigations
  • Hearing to begin on October 4, 2007
  • The potential human health risks involved in
    this kind of research dictate that we take a
    close look at whether these biosafety labs are
    being designed, constructed, and operated
    safely.
  • Focus on Biosafety Level 3 and 4 labs
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