NEW EPA PROPOSAL WILL CHANGE CLEAN WATER ACT REPORTING REQUIREMENTS FOR SET CLIENTS

The hazards posed by combustible dust are often underestimated until it's too late. These fine particles, when suspended in the air under certain conditions, can lead to catastrophic explosions, resulting in severe injuries, fatalities, and the destruction of buildings. For example, a tragic incident occurred in a metal processing plant where a combustible dust explosion resulted in the loss of several lives and substantial property damage. This serves as a stark reminder of the potential dangers lurking in what might seem like harmless dust accumulations. While the Occupational Safety and Health Administration (OSHA) has yet to establish a specific standard for combustible dust, it recognizes the severity of these hazards through its National Emphasis Program (NEP) (CPL 03-00-008). This program aims to guide inspections targeting industries known for frequent or severe dust-related incidents, including agriculture, chemical manufacturing, and recycling operations. OSHA also provides valuable guidance materials to help businesses understand and mitigate these risks. What Qualifies as Combustible Dust? Combustible dust can come from a variety of sources, including both organic and metallic materials. These are finely divided particles such as: Metal dusts, including aluminum, magnesium, and some iron forms. Wood dust. Carbon-based dusts like coal and carbon black. Organic dusts from sugar, flour, paper, rubber, soap, and dried blood. Dusts generated from human and animal food processing. Textile fibers and dust. These materials may seem innocuous in larger chunks, but as dust, they can burn rapidly and explosively under the right conditions. The Dynamics of Dust Explosions A combustible dust explosion is more complex than a typical fire. It requires five elements— known as the "dust explosion pentagon": Oxygen (from air) Heat (from an ignition source) Fuel (the combustible dust itself) Dispersion (a cloud of dust particles in a sufficient quantity and concentration) Confinement (an enclosed or semi-enclosed space) If any element of this pentagon is missing, an explosion cannot occur. However, once ignited, the dust cloud can lead to rapid and violent combustion, often manifesting first as a primary explosion within process equipment or enclosed spaces, followed by secondary explosions as additional dust is disturbed and ignited. Preventative Measures and Safety Programs To effectively manage these risks, OSHA recommends conducting thorough hazard assessments that cover: Materials handled. Operations conducted, including by-products. All spaces, even those less obvious. Potential sources of ignition. Implementing a written combustible dust safety program is a best practice for any facility handling potentially explosive dusts. This program should: Define specific safety procedures tailored to the organization. Communicate and ensure understanding of these procedures among all employees. Outline steps to control dust, ignition sources, and potential damage, minimizing injury and property damage risks. How SEA Can Assist You At Safety & Environmental Associates, Inc. (SEA), we understand the complexities of managing combustible dust risks. We offer comprehensive services tailored to your needs, including material testing, dust hazard analysis, hazard classification, and effective grounding techniques. Don't wait for an incident to remind you of the importance of dust safety. Contact SEA today to ensure your operations are safe and compliant. Together, we can create a safer working environment that protects both your workforce and your facilities. By Derek Jennings, President SEA

In a significant move to enhance public safety and environmental justice, the U.S. Environmental Protection Agency (EPA) announced on March 1, the finalization of amendments to the Risk Management Program (RMP). Dubbed the "Safer Communities by Chemical Accident Prevention Rule," this landmark regulation introduces the most protective safety provisions in history for chemical facilities, particularly targeting industry sectors with high accident rates. The rule is designed to shield at-risk communities, especially those in overburdened and underserved areas, from the devastating impacts of chemical accidents. EPA Administrator Michael S. Regan emphasized that this final rule is a vital component of the Biden-Harris Administration's commitment to advancing environmental justice by implementing stronger safety requirements for industrial facilities and new measures to protect communities from harm. Key Provisions of the Rule The final rule mandates more stringent measures for prevention, preparedness, and public transparency, with the aim of preventing accidental releases of dangerous chemicals that could lead to fatalities, injuries, property damage, or environmental harm. Key provisions include: Safer Technologies and Alternatives Analysis : Regulated facilities are now required to perform an analysis of safer technologies and alternatives. In some cases, they must implement reliable safeguard measures to reduce the frequency and severity of accidents. Empowering Workers: The rule advances employee participation, training, and decision making in facility accident prevention. It allows for process shutdowns in the event of a potentially catastrophic release and establishes a process for employees to anonymously report unaddressed hazards. Third-Party Compliance Audits: Facilities with a prior accident history must undergo third-party compliance audits and conduct root cause analysis investigations. - Enhanced Emergency Response: Facilities must ensure timely sharing of chemical release information with local responders and establish a community notification system for impending releases. Climate Change Considerations: Facilities are required to evaluate risks of natural hazards and climate change, including potential power loss, and increase transparency by providing access to RMP facility information for nearby communities. The Impact of the Rule The rule covers all 11,740 regulated RMP facilities across the country, with more rigorous requirements for a subset of facilities that are more accident-prone and pose the greatest risk to communities. According to EPA estimates, accidental releases from RMP facilities cost society more than $540 million each year. Approximately 131 million people live within three miles of RMP facilities, including 20 million who identify as Black or African American, 32 million as Hispanic or Latino, and 44 million who earn less than or equal to twice the poverty level. The rule will be published alongside a query tool which will allow people to access information for RMPs in nearby communities . The agency intends to update the tool in the coming months to allow visualization of climate change hazards, a request of several stakeholders. How SEA Can Help At Safety & Environmental Associates, Inc. (SEA), we understand the complexities of complying with evolving safety standards and regulations. Our team of experts is equipped to assist your company in updating your Risk Management Program to meet the new requirements set forth by the EPA. We offer comprehensive services, including safer technologies and alternatives analysis, employee training programs, third-party compliance audits, and emergency response planning. Don't wait until it's too late and EPA is knocking on your door. Contact SEA today to learn more about how we can help you comply with the new RMP rule and protect your business and the environment. Read more information on the rule visit EPA’s Risk Management Program rule website . By Derek Jennings