European Environmental Directives and Regulations

 

The attached report provides an overview of The European System for Environmental Protection and details 5 European Directives and Regulations, End of Life Vehicles (ELV); Restriction of Hazardous Substances, (RoHS); Waste Electrical and Electronic Equipment (WEEE); Registration, Evaluation, and Authorization of Chemicals (REACH); and Packaging and Packaging Waste. Additional relevant material regarding European Union requirements on wood packing materials is provided as part of the Packaging and Packaging Waste report.

The impact of some of these directives has already reached our shores and companies, with End of Life Vehicles and RoHS already affecting the materials permitted and specified for use, and causing confused customers to turn to us, their suppliers, for clarity on these Directives. Leaded free-machining materials are still acceptable, though the details vary by Directive and end use. This is documented for each of the directives discussed and analyzed here.

The materials provided here are the results of lengthy research and technical analysis. They are not, and should not be considered legal advice. We have reviewed the technical requirements, and after careful analysis, have provided responses to potential customer questions on each of these Directives.

We are confident that the attached material will help you understand and successfully manage the growing number of environmental questions that we currently face coming out of the European Market. Please forward any comments, concerns, or new developments in this area to Miles Free, PMPA’s Director of Technology Services, gro.apmp@eerfm.

 

European Environmental Directives

 

OSHA’s Hazard Communication Standard (HCS)

 

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.

 

OSHA’s Global Harmonized Hazard Communication Standard Fact Sheet

 

2012 Toxic Release Inventory (TRI) Reference Documents

 

Below are the 2012 TRI reference documents for PMPA member companies. These materials will help you understand the requirements, explain the issues, and will help you to make the calculations needed for your Form R Reporting.

Any questions please contact Miles Free gro.apmp@eerfm

 

Toxic Release Inventory Guidelines

 

Example Threshold Calculation Worksheet

 

EPA TRI Web Links

New Stormwater Regulations (in Ohio) – Training Material Available

 

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.)

 

SPCC Training Compatibility Mode

 

Changes in General Industrial Storm Water Permit

 

Industrial Storm Water Draft

 

Industrial Storm Water Final

 

No Exposure Guidance

 

NOI Form September 2011

 

Lockout/Tagout Rules – OSHA Regulation

 

Originally published in January, 1990, PMPA’s Safety & Health Bulletin #192 acquaints you with Lockout/Tagout rules and regulations required by OSHA’s Control of Hazardous Energy Sources Standard, which became effective on January 2, 1990.

Please contact Miles Free, PMPA Director of Industry Affairs, for more information.

 

Lockout/Tagout – OSHA Regulation (REPRINT)

 

 PPE Hazard Assessment

 

Thursday May 08, 2008

Certification of PPE Hazard Assessment Is Required Under 29 CFR 1910.132

To certify PPE hazard analysis required under 29 CFR 1910.132, a PPE (Personal Protective Equipment Assessment) must be completed.

We are providing forms for use to identify hazards and the PPE required. We have reviewed a number of forms and formats and believe that these forms will help you make thorough and effective assessments. See Link below.

A job specific analysis can be undertaken, however many of our shops have reported success using a “Shop Operations” approach to identify hazards that all personnel in their shop face.

Here are some tips for your assessment based on my shop visits, review of OSHA citations for our industry, training and experience.

  • Slips and falls– Determine best footwear/soles for your environment
  • Pinchpoints– Especially when using cranes and straps to lift material
  • Lockout- tagout – Lock becomes workers PPE
  • Hand and portable tools – Safety glasses, long sleeves, steel toes
  • Abrasive wheel machinery – Safety glasses!
  • Flying chips – Safety Glasses
  • Overhead materials falling – Steel toes
  • Splashing of fluids – Safety glasses, long sleeves, protective aprons or other apparel if applicable.

 

One final note: It isn’t just metal chips, burrs, metal banding, or tools that can cut skin, I once had to transport an employee to the hospital for stitches from a paper cut from the paper we used to wrap steel bundles- 4” gash on forearm, job became long sleeve…

For further information and links to the OSHA Publications and regulations, see our article on page 17 in the April 2008 issue of Production Machining Magazine at: http://www.productionmachining.com/articles/personal-protective-equipment-and-the-precision-machining-industry.aspx

For Some Helpful OSHA websites see link below:

PPE Assessment Form

PPE Walkthrough Form

OSHA Websites