OSHA Protecting Employees Against Avian Flu Hazards

News & Views


At the close of another busy year, our thoughts turn to those who have made our progress and success possible. Thank you! All of the associates of Compliance Technologies, Inc. sincerely wish you, your families, and coworkers a safe and healthful holiday season and a successful New Year.

OSHA Advises on Avian Flu

On November 14, 2006, OSHA issued a News Release regarding “New Guidance for Protecting Employees Against Avian Flu”. The guidance alerts employees and employers about the hazards of occupational exposure to avian influenza from infected birds, or “avian flu,” and provides practical recommendations on ways to avoid infection. The 76-page guidance document can be accessed from the OSHA web site at the following link:http://www.osha.gov/OshDoc/data_AvianFlu/avian_flu_guidance_english.pdf.

Hex Chrome Standard Now in Effect

Reminder: OSHA issued its new hexavalent chromium (CrVI) standard in May, 2006. The standard requires employers of 20 or more employees to have completed the initial exposure air monitoring by November 26, 2006. Employers with 19 or less employees have until May 30, 2007 to complete the exposure air monitoring. Facilities that exceed the new exposure limit (5.0ug/m3) must have engineering controls in place by May 31, 2010.

Air Toxics

On August 3, 2006, a newly amended statute became effective which identifies the requirements for reviewing new and modified air contaminant sources having air toxic emissions. Previously, Ohio EPA had an “Air Toxics Policy” which was used as guidance in reviewing permit to install and permit modification applications. This policy has now been incorporated into law. The amended statute also required Ohio EPA to promulgate a list of toxic air contaminants that would be regulated under this review requirement. On December 1, 2006, Ohio EPA’s list of 303 toxic air contaminants became effective in OAC 3745-114-01.

Title V Permit Fees for Reporting Year 2206

The Title V emissions fee for calendar year 2006 emissions is $41.02/ton. Fees are assessed on the actual amount of emissions of particulate matter, sulfur dioxide, nitrogen oxides, organic compounds and lead. Companies are required to submit a fee emissions report annually by April 15. Ohio subsequently invoices facilities upon receipt of the report.

Canadian Study Ranks Great Lakes Cities by Sewers

The Great Lakes Sewage Report Card was released November 29th by the Canadian group Sierra Legal Defense Fund. The report ranks 20 Canadian and American cities according to the effectiveness of their sewage collection and treatment systems and their resultant impact upon water quality. Cleveland ranked 19th with an overall grade of D+.

The Sierra Legal Defense Fund appears to be an environmentalist/activist group funded by significant groups, such as the Mott Foundation, J.P. Bickell Foundation, and the Eden Conservation Trust. It is reported to be Canada’s largest non-profit environmental law organization.

The Sierra group reports, not surprisingly, that the lowest-ranked cities are the oldest, and/or most industrialized cities that remain burdened with combined sewer systems (sanitary and storm water). These systems are overcome by large rainfalls and release poorly treated or untreated sewage through large overflows to nearby rivers and lakes.

An interesting detail reported in the study is that only 1% of the water in the Great Lakes leaves the basin each year through the St. Lawrence Seaway to the Atlantic Ocean. And, this 1% is replaced through rainfall, making the basin a closed system. What goes in, stays in.

As most of CTI’s industrial clients in NE Ohio know, the principal pollutants of concern to the sewage treatment plants include oils, metals, solids, and oxygen depleting substances. However, Sierra reports that new contaminants being discovered in the Great Lakes include pharmaceuticals and hormones, such as steroids and prescription/non-prescription drugs, as well as insect repellents and detergent metabolites. These items are indicative of residential and medical sources.

The Canadian group cites the Great Lakes Basin as a “political quagmire . . . of 2 countries, 8 states, a province, and hundreds of municipal and regional governments.” It would appear that this group will continue to put pressure on sewage system providers at political and legal levels, leading to increased scrutiny and compliance demands on all dischargers.

Some of the study’s rankings: Top Five Cities: Green Bay WI, Peel ON, Duluth MN, Thunder Bay ON, and Rochester NY. The Bottom Five Cities: Sudbury ON, Syracuse NY, Windsor ON, Cleveland OH, and Detroit MI. Read the study at: http://www.sierralegal.org/reports/great.lakes.sewage.report.nov.2006b.pdf.

Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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