Tech Forum 2012 Environmental, Health & Safety Regulatory Update

1. Tech Forum 2012Environmental, Health & Safety Regulatory Update Issues on the EPA and OSHA Horizon Fall Protection, Storm Water, Greenhouse Gasses, PM2.5, Definition of Solid Waste Revised Final Rule; Adhesion Study Presentation American Galvanizers Association 2012

2. OSHA • Walking Working Surface Standard to include Fall Protection Provisions • Personnel working Over 10 feet from the ground must meet fall protection provisions. (This includes fixed and mobile working platforms) • Already covered are open sided floor openings, crow’s nests, working on rails, walls, vents/louvers, etc over 10 ft from floor • Harness, lanyard, and anchor point over the head or prevention of falls greater than 3 feet. American Galvanizers Association 2012

3. OSHA National Emphasis Program • Workplaces with fatalities, and DART greater than 7.0 national average. • Crane operation, working under racked parts, material handling. • Have OSHA logs up to date (within the week) and review all existing programs (initial and date) for adequacy and audit consistent implementation on all levels. Make sure those not following protocol are disciplined in writing. This is a CYA for all. Employees should not be “at fault”, only supported. American Galvanizers Association 2012

4. Hazard Communication 1910.1200 has been “Globally harmonized” American Galvanizers Association 2012

5. Storm Water Progress • USEPA is requiring SIP’s from states that include • reduction in Combined Sewer Overflow events, • upgraded and updated infrastructure, • reduced pollutant loading. • 1. reduce effluent, remove water from waste water discharge AND storm flow contributions to city infrastructure, • 2. Reduce pollutant loading (concentrations and total mass), • 3. Implement effective BMP’s and source reduction from NON POINT SOURCES in addition to the traditional point sources. American Galvanizers Association 2012

6. Storm Water BMP’s • Containment around fueling stations • Spill Kits located proximal to potential spill/leak locations • >1320 gallons= SPCC plans • Preventative Maintenance Program to avoid spills, drips or leaks • Control garbage, debris and solids sources • Good Housekeeping • Raw materials contained, covered, transfer areas managed. American Galvanizers Association 2012

7. Storm Water Technology in use • Capture Process Water for reuse • Divert zinc containing water to onsite containment for storage and reuse • Capture storm water for treatment prior to discharge • Effective treatments • Source reduction • Filtration and pH adjustment • Chemical bonding • Ion exchange American Galvanizers Association 2012

8. Industry practices • Collecting fines from process, separate from storm water contact areas. • Keep zinc particles under cover and minimize track out on shoes, tires and parts. • Grind and brush and spray inside, near a dust collector • Collect water from process areas in sumps for processing or re-addition American Galvanizers Association 2012

9. Data Collection request • Storm water and process water data on the following metals • Cadmium • Chromium • Nickel • Copper • Lead • Zinc American Galvanizers Association 2012

10. Air Discharge Greenhouse Gas Emission Reporting Most states require major sources to report carbon equivalent emissions Minor sources will be added in by 2015 Emission exchange programs are proposed in several states, implemented in western climate states Permit conditions will incorporate fugitive emissions for PM and PM10 and PM2.5 Steel Pickling MACT-Does not apply to HDG Boiler MACT is under a regulatory STAY, do not report this fall. Keep data and calculations for when it goes back into effect. American Galvanizers Association 2012

11. Solid & Hazardous Waste Definition of Solid Waste Revision from 2008 has been re-written and re-issued. Provisions include: Initial determination of the material End use matters Document flow chart of decisions Document vendor use and quantities shipped Account for materials the same as every other raw material and product. (Beginning and ending inventory, storage rotation, storage inspections, QA samples etc) American Galvanizers Association 2012

12. DSW Flow Chart • Q1: Is the material a waste • Q2: Will the material be discarded • Q3: Is the material inherently waste-like • Q4: Will the material be used in a manner consistent with waste disposal methods? • See flowchart in 40 CFR 261.4 Appendix A American Galvanizers Association 2012

13. Audit Survival • Keep all docs in one folder on your computer • Scan in every form, training roster, inspection record, checklist, and certification. • Complete Job hazard analysis, job description, procedure reviews, weekly walkthrough records, correct problems immediately • Train your workforce, observe and correct behavior, document American Galvanizers Association 2012