EHS MANAGEMENT CURRENT ISSUES

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EHS MANAGEMENTCURRENT ISSUES

• ACUA Annual Meeting
• October, 2007

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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

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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

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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

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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

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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

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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

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Unintentional Injuries Leading Causes
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Motor Vehicle Deaths - 2003
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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)

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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)

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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

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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

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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

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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

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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

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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

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Chance favors the prepared mind.Louis
Pasteur
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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

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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

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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

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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

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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

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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

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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)

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SUSTAINABILITY

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

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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

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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

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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.

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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

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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.

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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

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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

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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

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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

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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)

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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)

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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