OSHA Director David Michaels has responded to PMPA’s letter challenging several aspects of the OSHA March 12, 2012 Memorandum on Employer Safety Incentive and Disincentive Policies and Practices. Link here: http://www.osha.gov/as/opa/whistleblowermemo.html

PMPA felt that the guidance document removed employer authorities and tools to assure they could meet their obligations to maintain a safe workplace. PMPA has summarized the Director’s comments. Employer’s rights to discipline and offer incentives are maintained. Positive Incentives for safety performance remain targeted by OSHA as potentially discriminatory and dissuasive of reporting injuries. Links to all documents are provided. For further information contact Miles Free gro.apmp@eerfselim.

Miles Free Letter 18 April 2012

David Michaels Letter 30 July 2012

OSHA Memorandum on Safety Incentive Disincentive Policies – Update

OSHA’s Hazard Communication Standard (HCS), first issued in 1983, was designed to ensure that employers provide information about potential health and physical hazards and associated protective measures to their workers. OSHA has just announced on March 20, 2012, a final rule updating OSHA’s Hazard Communication Standard to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals. Globally_Harmonized_System_Guide.

Employers must start training to understand the new label elements and Safety Data Sheets format by December 1, 2013. Resources to assist PMPA members with compliance to this new standard are provided here.

The State of Ohio is in the process of updating its Stormwater General Permit to match the Federal multi sector requirements. The new permit is 171 pages long and involves greatly increased testing and monitoring.

We urge you to give consideration to the NO Exposure Conditional Exclusion described in one of the attachments below. Attachments are provided for a review of SPCC plans, as well as the Stormwater Webinar and supporting documents presented by Barb Knecht of Hzw Environmental on September 20th.

(Note: Materials are prepared anticipating the State of Ohio’s Promulgation of the regulations. The SPCC materials and other resources may be appropriate for shops in other states for planning and forward looking activities.)