EPA Form R – Toxic Release Inventory Report – 2013

Form R Reports are due July 1 for any chemicals used in 2012 that exceed reporting thresholds.  Because the complexity of the report, and the high demand for CDMS’s assistance in preparing the report, we do provide discounts for reports that are contracted early.   The largest discounts expire as early as March 1, so contact CDMS soon if you are interested in exploring us preparing this report for your facility.  For more information visit http://www.cdms.com/our-services/hazardous-material-regulatory-support/reporting-plans/tri-form-r-reports/

Global Harmonization System – Hazard Communication Changes

Don’t forget, Employees will be required to receive information and training on the new GHS System labeling and Safety Data Sheets by Dec 1, 2013.

CDMS can provide on site or online video options to meet this new training requirement.  Contact us to find out more about the most economical and effective way to address the requirements for your facility.

What is GHS

The GHS is an acronym for The Globally Harmonized System of Classification and Labelling of Chemicals. The GHS is an international system for standardizing and harmonizing the classification and labelling of chemicals.

It is a logical and comprehensive approach to:

?       Defining health, physical and environmental hazards of chemicals;

?       Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and

?       Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

Who does it Affected

?       Companies that use chemicals as part of the work activities

?       Companies that manufacture, import, and distribute chemicals

What are the Requirements

Who: Employers

Effective Completion Date: December 1, 2013

Requirement(s): Train employees on the new label elements and SDS format.

 

Who: Chemical manufacturers, importers, distributors and employers

Effective Completion Date: June 1, 2015 & December 1, 2015

Requirement(s):  Comply with all modified provisions of this final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

 

Who: All chemical manufacturers, importers, distributors and employers

Effective Completion Date: June 1, 2016

Requirement(s):  Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

 

Who: All chemical manufacturers, importers, distributors and employers

Effective Completion Date: transition period

Requirement(s):  Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.

 

 

Select this link to find out more about the our training or to convert your MSDSs to the new format SDS.

CERS/Electronic HMMP Reporting (Calif. Only) –Starting January 1, 2013

Most companies now must do all HMMP reporting electronically as submittal due dates come due this year.  Facilities will no longer be able to submit paper submittals.

CDMS can assist in uploading and maintaining information on the CERS (California Electronic Reporting System), or other Electronic System dictated by local CUPA’s.

Respiratory Protection Requirements

If you are offering Respirators to your employee, you must comply with Respirator regulatory requirements, including:

A written Respirator Plan on site

Annual Training and fit testing for all employees who wear a respirator

Medical clearance of all employees before they use respirators (can be done through written questionnaires)

OSHA requires respirators whenever exposure to hazardous materials exceeds OSHA Permissible Exposure Limits.
If there is a potential that exposure may exceed PELs, OSHA does require facilities to conduct air monitoring to determine actual exposure levels.
CDMS can provide air monitoring, develop respirator programs, conduct training and fit testing, and provide medical questionnaire evaluations.  Contact your local office for more information.

OSHA Log 300

Don’t forget to post your completed OSHA log 300 during the months of Feb-April.  It must be posted in a place that employees can see and have access to.