It’s time to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses in your workplace. This is required for all U.S. employers, except those with ten or fewer employees or those whose NAICS code is in the set of low-hazard industries exempt from OSHA’s injury and illness recordkeeping requirements.

In addition, by March 2, 2019, establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. If employers in State Plan states (e.g. Washington) have questions about their obligation to submit injury and illness information, please contact your State Plan office.

Washington has seen a dramatic shift in oil transportation recently, both in the types of oil and in the locations where large quantities of oil are transported. These changes affect the risks associated with oil transportation. Many communities don’t have response resources for spills of oil or hazardous materials. To help solve this problem, the Washington State Department of Ecology provides equipment and training grants to emergency responders. These grants help local communities effectively prepare for and respond to spills.

Funding is available for the following entities:

• Washington counties, cities, and municipalities
• Other state recognized local governments
  • Ports
  • Public utility districts
  • Other special purpose districts (e.g., Clean Air Agencies, Fire Protection)
• Federally recognized tribal governments
• Washington state agencies

To be considered, the community the agency responds to must have a substantial threat of an oil spill or hazardous materials incident occurring in their jurisdiction. The grant is primarily intended to assist emergency responders in purchasing equipment they would not otherwise be able to purchase.

Grant applications will be accepted January 2, 2019 – March 6, 2019. See Ecology’s grant website for further information.

Restrictions on outdoor burning and the use of uncertified wood burning stoves and fireplaces begins at 10 a.m., Sunday, November 18, 2018. The ban will remain in place until further notice.

Spokane Regional Clean Air Agency is issuing the “Stage 1 Burn Ban” because concentrations of air pollutants are expected to increase putting residents at risk. Under a Stage 1 “yellow” burn ban: 

• The use of uncertified wood stoves, fireplaces, inserts and other uncertified wood-burning devices is prohibited in the Smoke Control Zone, unless they are a home’s only adequate source of heat.*
• EPA-certified wood stoves, pellet stoves and other certified wood-burning devices are allowed.
• All outdoor burning is banned throughout Spokane County.

* If you don’t have an adequate source of heat, contact Spokane Clean Air for an exemption. Click here for details.

After effectively being discontinued for almost a decade, the EPA declared May 15th the agency’s “renewed emphasis on encouraging regulated entities to voluntarily discover, promptly disclose, expeditiously correct, and take steps to prevent recurrence of environmental violations.” This renewed emphasis is consistent with the current EPA’s focus on improving compliance through mechanisms, including voluntary self-correction, that achieve environmental goals more quickly and in a less costly, adversarial and time-consuming manner than traditional enforcement means.

Some of the policy’s key incentives and areas of flexibility include: (1) the ability of new owners to enter into audit agreements that incorporate disclosure reporting that is appropriate to their unique situation; (2) the waiver of economic benefit penalties that otherwise might apply to delayed expenditures; and (3) more generous treatment of violations discovered through already legally mandated monitoring, sampling or reporting that would not normally be considered “voluntarily discovered” (such as testing pursuant to a Title V permit).

More info on the Audit Policy and the New Owner Policy can be found at: https://www.epa.gov/compliance/epas-audit-policy.

E-manifest, the U.S. Environmental Protection Agency’s national system for tracking shipments electronically, is set to go live at the end of June 2018. The e-Manifest requirements are effective in all states once the system goes live, including Washington.

What does this mean for generators, transporters, and receiving facilities?
Once the system goes live, receiving facilities will begin submitting all manifests (paper and electronic) to EPA.
Generators and transporters of dangerous waste will be able to create, edit, and sign their manifests electronically. They will also be able to view and print their own manifest copies and manifest status information.

Who will pay for this?
Receiving facilities will pay all fees associated with electronic manifesting.
However, receiving facilities may pass on the cost of the fees to their customers.

How much will this cost?
EPA will charge fees based on a sliding scale. Visit EPA’s website for more pricing information.  Using electronic manifests will be optional for the first few years. However, using paper manifests will be more expensive.

Where can I find more information about e-Manifest?
Visit EPA’s website for details and to keep updated on the latest developments.

Spray efficiency trainings are coming in 2018 to locations around Washington. Ecology and the Pollution Prevention Resource Center (PPRC) have scheduled afternoon and evening sessions in three cities. The workshops will run from 1-4 p.m. and 5-8 p.m., and will include dinner. Follow the links for address, directions, and registration info:

• May 23 in Spokane
• June 6 in Mount Vernon
• June 20 in Vancouver
• Tri-Cities (details to be determined)

Join PPRC’s email list to stay up-to-date on upcoming training opportunities.

Who should attend these trainings?

Any workers applying paint or coating to metal, plastic, or wood: auto body shops, parts manufacturers, or cabinet manufacturers.

Check out the Upcoming Events section of PPRC’s website for updated information on these and all workshops, including those currently in the planning stage.

Contact

Ken Grimm
206-352-2050 ext. 102
kgrimm@pprc.org

On March 13, 2018, the U.S. Environmental Protection Agency (“EPA”) released a guidance memorandum announcing a new policy to address NSR applicability –  facilities may now take into account emissions decreases in calculating whether a proposed project will trigger NSR in the first instance. Please note that it remains to be seen if Washington State will operate using this guidance.  Additional interpretation on this guidance can be found here.

Other key Clean Air Act changes recently included (1) change in the NSR program concerning the “actual-to-projected-actual” test stated that it would no longer “second guess” the pre-construction projection of a company unless there was a clear error (12/7/2017 memo) and (2) retraction of EPA’s “once-in-always-in” policy for the classification of major sources of hazardous air pollutants under section 112 of the Clean Air Act (1/25/2018 memo).