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Regulatory Update

Regulatory Update. Today’s Topics. January Meeting Recap/Update Enforcement News Wal-Mart MSHA Advanced Notice EPA – Clean Water Act (CWA) & EPD OSHA – Stone, Clay, Glass and Concrete Products Regulatory Inspection Protocols. January Update. Environmental PC MACT (Portland Cement)

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Regulatory Update

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  1. Regulatory Update

  2. Today’s Topics • January Meeting Recap/Update • Enforcement News • Wal-Mart • MSHA Advanced Notice • EPA – Clean Water Act (CWA) & EPD • OSHA – Stone, Clay, Glass and Concrete Products • Regulatory Inspection Protocols

  3. January Update • Environmental • PC MACT (Portland Cement) • Boiler MACT • RICE MACT (Reciprocating Internal Combustion Engine) • Stormwater Pollution Prevention (Issued April 2012) • Spill Prevention Control and Countermeasures • Safety • Global Harmonization System (GHS) • Site Specific Targeting Program 2012 (STS-12) • Active Local and National Emphasis Programs

  4. Enforcement News Introduction • Wal-Mart News • MSHA Advanced Notice • EPA – Clean Water Act (CWA) & EPD • OSHA – Stone, Clay, Glass and Concrete Products

  5. Enforcement News • Pleads guilty to federal environmental crimes • > $81 Million in fines • Improper handling of hazardous wastes at it’s retail stores • RCRA, FIFRA, CWA • In addition to fines they are required to develop and implement EMSs. Wal-Mart What can we take away from this?

  6. Waste Stream Identification • Profile Waste for a Hazardous Waste Determination • Generator Status Determination (CESQG, SQG, CESQG) • Onsite Management of Hazardous Waste • Proper Disposal Practices (Recycling?) RCRA Compliance How do we manage oil?

  7. Enforcement News • MSHA has drastically enlarged its interpretation of “advanced notice” to now include all communications at a mine that would alert others to MSHA presence. • Security Guards • “Capturing” mine phones and radios • Civil Penalties up to $200,000 per violation • Criminal Actions • Permissible Communication MSHA Advanced Notice

  8. Enforcement News • EPA and EPD Inspections • Clean Water Act Focus • Permit Issued in 2012. We have seen an increase in inspections. • Focused inspections on plan development and implementation Stormwater Pollution Prevention Inspections

  9. Enforcement News Major Group 32 Stone, Clay, Glass and Concrete Products SIC 3273 Ready-Mixed Concrete OSHA Inspections By the Numbers

  10. Regulatory Inspection Protocols Pre- Inspection Procedures • Welcome all inspectors to the facility • Seat them in a conference room, lobby and contact the appropriate representative. (Don’t delay them too long). • Ask for credentials • In OSHA’s case there will be a pre-inspection conference • Basis and scope of inspection • Complaint, accident, etc • Inspection process • Make a good impression

  11. Regulatory Inspection Protocols Records Review (OSHA 300, Programs, Training Records) Make sure everyone is wearing their PPE! Try and keep the same person with the inspector through the duration of the visit. Don’t be afraid to call a “Timeout” Route and duration of the inspection is determined by the inspector, but take them directly to the place of interest. Never leave the inspector alone Don’t volunteer information (uncomfortable silence is good) Inspection

  12. Regulatory Inspection Protocols Inspection (continued) Ensure employees know to be honest Take thorough notes, record EVERYTHING that happens If the inspector takes a photo, you should take the same photo Avoid estimates, you may be providing false information If you can correct a condition on the spot, do it. You still may be cited. Don’t be afraid to disagree, NICELY.

  13. Regulatory Inspection Protocols Closing Conference Description of apparent violations and conditions Provide records to the inspector Proposed penalties Penalty procedure Employer rights (informal conference, contest)

  14. QUESTIONS? www.orizonipe.com solutions@orizonipe.com Southeast Office 6300 Powers Ferry Rd. Suite 600–268 Atlanta, GA 30339-2919 phone: 678.274.9667 Southwest Office 28150 N Alma School Pkwy Suite 103-106 Scottsdale, AZ 85262 phone: 602.688.9667

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