U.s. Ehs Legal Requirements Summary List_0
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Directions Identifying legal and other voluntary requirements and their applicability to your operation is a difficult task. It requires in-depth knowledge of regulations. Consider hiring a professional consultant for this activity. 1 When evaluating the recycler's legal and other requirements, include the following: Local Health & Safety State/Provincial Emergency Planning Federal/National Storm Water Management International Waste Water Air Pollution Waste Hazardous Waste Recycling Privacy Laws Data Breach Notification Transportation 2 Consider each regulatory category on each row. If it does not apply, then hide or delete the row. 3 Add any regulations, laws, or other commitments made by the company to the list on a new row. 4 Identify who has primary responsibility for ensuring the company is in compliance with each legal requirement. 5 Identify any training required by the legal requirement. 6 Identify the operational controls that have been implemented to meet the legal requirement. I.e. written procedures, signage, engineering controls, PPE, etc. 7 Identify any monitoring activities that have been implemented to meet the legal requirement. For example, the forklift pre-use inspection checklist. 8 Identify any reports that are mandated by each legal requirement 9 This list should be reviewed by an experienced legal auditor during your required legal compliance audit to determine if it is complete and accurate.
EHS Legal and Other Requirements Summary List United States TYPE DESCRIPTION Air Emissions Emissions of Regulated Air Pollutants Emissions of Regulated Air Pollutants
Stormwater Discharge
Stormwater Discharges
REGULATION 40 CFR 51, 52 and 70 - Air Permitting LIST STATE REQUIREMENT
40 C.F.R. 122.6 Clean Water Act
Stormwater Discharges Hazardous and Hazardous Waste - Identification and Listing Universal Wastes FEDERAL
LIST STATE REQUIREMENT 40 CFR 261.2-261.4 Resource Conservation and Recovery Act (RCRA)
Requirements on the control of stormwater from municipal and industrial www.epa.gov stormwater discharges. The stormwater program is under the NPDES (National Pollutant Discharge Elimination System) part of the Clean Water Act. The regulation is meant to reduce the amount of pollutants entering streams, lakes and rivers as a result of runoff from residential, commercial and industrial areas. A National Pollutant Discharge Elimination System (NPDES) Permit is required for the point source discharges of facility surface water to surface waters of the 'State'. 261.2 - Definition of solid waste www.epa.gov 261.2 - Definition of hazardous waste 261. 4a 13&14 - Scrap metals and circuit boards are excluded from hazardous waste classifications.
40 CFR 261.11 Resource Conservation and Recovery Act (RCRA)
Facilities must identify and document whether their waste is classified as hazardous or non-hazardous using RCRA-defined waste classification codes.
www.epa.gov
Hazardous Waste
40 CFR 262.12 Resource Conservation and Recovery Act (RCRA)
Facilities must obtain a EPA hazardous waste ID number.
www.epa.gov
Universal Waste
40 C.F.R. 273 Subp’s. A, B and F
www.epa.gov
CRT Final Rule
40 CFR Parts 9, 260, 261, and 271
Standards for the Management of Universal Waste including Waste management, Labeling, Accumulation, Training, Release Response, Transportation, Record Keeping. Covers fluorescent bulbs, lead acid batteries and lithium batteries. "A cathode ray tube (CRT) is the glass video display component of an electronic device (usually a computer or television monitor). This final rule streamlines management and exporting requirements for recycling of used CRTs and glass removed from CRTs under the Resource Conservation and Recovery Act (RCRA). The amendments exclude these materials from the RCRA definition of solid waste if certain conditions are met. The rule is intended to encourage recycling and reuse of used CRTs and CRT glass."
www.epa.gov
Resource Conservation and Recovery Act (RCRA)
"This final rule adds mercury-containing equipment to the federal list of universal wastes regulated under the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations. Handlers of universal wastes are subject to less stringent standards for storing, transporting, and collecting these wastes. EPA has concluded that regulating spent mercury-containing equipment as a universal waste will lead to better management of this equipment and will facilitate compliance with hazardous waste requirements."
Disposal of PCBs Final Rule
40 CFR 761 Resource Conservation and Recovery Act (RCRA)
Standards for storing, accumulation, disposal, reporting and clean up of PCB wastes containing greater than 50 ppm but less than 500 ppm of PCB material.
www.epa.gov
Management of Lead Acid Batteries
40 CFR 266.80 Resource Conservation and Recovery Act (RCRA)
Standards for handling, storing, labeling, disposal and clean up of lead acid batteries.
www.epa.gov
Management of Used Oils
40 CFR 279 Resource Conservation and Recovery Act (RCRA)
Standards for storing, labeling, disposal and clean up of Used Oil.
www.epa.gov
SREA Criteria for Recycling Transactions
42 USC 9627
Required recordkeeping to qualify for the Superfund liability exemption for recycling transactions.
www.epa.gov
40 CFR 761
Standards for labeling, storing, disposal, spill procedures, clean up, record retention, reporting (annual log) of PCB wastes. PCB waste must be disposed of within one year from the date taken out of service.
www.epa.gov
Notification of PCB Activity is required for a generator with onsite storage facility.
www.epa.gov
Discarded Mercury-Containing Equipment Final Rule
TSCA Federal Disposal of PCBs Final Rule
40 CFR Parts 260, 261, 264, 265, 268, 270, and 273
Resource Conservation and Recovery Act (RCRA)
EPCRA
REGULATION LOCATION www.epa.gov
Hazardous Waste - Criteria for Listing
Resource Conservation and Recovery Act (RCRA)
Superfund
REQUIREMENT SUMMARY Standard for air permitting requirements, including air permit application, permit limits, required monitoring, and reporting and record keeping requirements. State Air Pollution Control Requirements for classification of air pollution sources, registration, permitting, monitoring, inspections, maintenance, reporting and record keeping.
40 CFR 761
Emergency Planning and Community Right-to-Know Reporting and Release Notification
40 CFR Parts 350 through 372 - SARA Title III Emergency planning and notification, community right to know reporting www.epa.gov requirements when hazardous chemicals (as defined by OSHA), hazardous substances (as defined by CERCLA) and extremely hazardous substances (EHS) exceed threshold planning quantities or reportable quantities (for releases). This facility does not store or use EHS. When the TPQ of any hazardous chemical or hazardous substance is exceeded, hazardous chemical inventory reporting is required. If a hazardous chemical or hazardous substance is release at or above the reportable quantity, release reporting is required. The State has adopted the federal requirements.
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40 CFR 110 and 355
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Shred Personnel
Dust Collection Procedure
Daily Magnehelic Gauge Reading Annual Report due by Jan 1st of every year.
Operations Manager
Shred Personnel
Dust Collection Procedure
Daily Magnehelic Gauge Reading Annual Report due by Jan 1st of every year.
Operations Manager
All Warehouse Personnel
Stormwater Pollution Prevention Plan
Monthly Stormwater Inspections. Annual Report due by Jan 1st of Quarterly stormwater sampling every year.
Operations Manager
All Warehouse Personnel
Stormwater Pollution Prevention Plan
Monthly Stormwater Inspections. Annual Report due by Jan 1st of Quarterly stormwater sampling every year.
Operations Manager
All Warehouse Personnel
Hazardous Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hazardous Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hazardous Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Universal Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
Notify US EPA of intent to export.
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Shipping Personnel
Downstream Due Diligence Procedure
Annual Review of records
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
EPCRA Procedure
Annual review of EPCRA procedure
Currently hazardous chemicals and hazardous substances are below TPQs; facility will continue to monitor incoming hazardous materials and applicability will be re-evaluated.
Operations Manager
All Warehouse Personnel
SPCC Plan
Annual review of SPCC Plan
As required by SPCC
www.epa.gov
Notification of PCB Activity
Spill Reporting Spill Reporting Requirements
RESPONSIBILITY Operations Manager
Requirements for reporting releases of oil and hazardous chemicals. The State www.epa.gov has adopted the federal spill reporting requirements.
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EHS Legal and Other Requirements Summary List United States TYPE DESCRIPTION Hazardous, STATE Standards for Hazardous Waste Management Universal and Industrial Wastes STATE
REGULATION
REQUIREMENT SUMMARY
REGULATION LOCATION
RESPONSIBILITY
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Operations Manager
STATE Standards for Used Oil Management
Operations Manager
STATE Universal Waste Management Operations Manager Electronics STATE Electronics Recycling Law Recycling Law STATE Operations Manager
TRANSPORT
Federal Motor Carrier Safety Regulations
CFR 49 Parts 382, 383, 387, 390-397, and 40 Requirements for transporters including; drivers drug and alcohol screening, Commercial Driver's License Standards; Requirements and Penalties, Federal Motor Carrier Safety Regulations; General and Qualifications of Drivers
STATE Transportation - Division of Motor Vehicles
Health and Safety FEDERAL
http://www.fmcsa.dot.gov
Requirements for transporters including: Commercial Driver's License Standards, vehicle registrations, Requirements and Penalties, medical evaluation, GVWR, motor vehicle safety, and financial responsibility. 49 CFR 173.185 (d)
Packaging requirements for lithium battery shipments.
Walking and Working Surfaces - Slips, Trips, & Falls
29 CFR 1910.21 to 1910.30
Verify that all places of employment, passageways, storerooms, and service www.osha.gov rooms are kept clean and orderly and in a sanitary condition. The floor of every workroom shall be maintained in a clean and, so far as possible, a dry condition. To facilitate cleaning, every floor, working place, and passageway shall be kept free from protruding nails, splinters, holes, or loose boards. Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repairs, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked. Protection requirements for floor openings, wall openings, open-sided floors, platforms, and runways, stair rails, portable step ladders, scaffolding,
Means of Egress - Exit Routes
Emergency Action Plan
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29 CFR 1910.23
29 CFR 1910.35 to 1910.37
29 CFR 1910.38
Transportation Procedure
Daily & Monthly Inspections
Add specific details as required, by type of license and vehicles
Operations Manager
All Transport Personnel
Battery Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Housekeeping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Fall Prevention Plan
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Emergency Action Plan
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Emergency Action Plan
Monthly Inspections
N/A
Operations Manager
Transport of Lithium Batteries
Fall Prevention
All Transport Personnel
Operations Manager
www.epa.gov
Open-sided floors or platforms 4 feet or more above adjacent floor or ground www.osha.gov level must be guarded by a standard railing (guardrail) or equivalent. Employees may work on an extension or step ladder up to the maximum working height of the ladder as specified by the ladder manufacturer. Requirements for emergency exits. Exit routes must be free and www.osha.gov unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. Each exit must be clearly visible and marked by a sign reading "Exit." and illuminated. If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to an exit sign must clearly be visible at all times. An emergency action plan must be in writing, kept in the workplace, and www.osha.gov available to employees for review. An emergency action plan must include at a minimum: 1) Procedures for reporting a fire or other emergency; 2) Procedures for emergency evacuation, including type of evacuation and exit route assignments; 3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; 4) Procedures to account for all employees after evacuation; 5) Procedures to be followed by employees performing rescue or medical duties; and the name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan. An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165. An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. An employer must review the emergency action plan with each employee covered by the plan.
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EHS Legal and Other Requirements Summary List United States TYPE
DESCRIPTION Fire Prevention Plan
Hearing Conservation
Hazardous Materials
REGULATION 29 CFR 1910.39
29 CFR 1910.95
29 CFR 1910.101 to 1910.126
Personal Protective Equipment, and Hazard Assessments 29 CFR 1910.132-139
Respiratory Program
Lockout/Tagout Program
Medical Services and First Aid
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29 CFR 1910.134
29 CFR 1910.147
29 CFR 1910.151
REQUIREMENT SUMMARY REGULATION LOCATION A fire prevention plan must be in writing, be kept in the workplace, and be www.osha.gov made available to employees for review. Minimum elements of a fire prevention plan. A fire prevention plan must include: 1)A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard; 2) Procedures to control accumulations of flammable and combustible waste materials; 3) Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials; 4) The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and 5) the name or job title of employees responsible for the control of fuel source hazards. An employer must inform employees upon initial assignment to a job of the fire hazards to which they are exposed. An employer must also review with each employee those parts of the fire prevention plan necessary for self-protection.
Protection against the effects of noise exposure shall be provided when the www.osha.gov sound levels exceed those shown in Table G-16 . (90 dBA over an eight hour TWA.) When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of Table G-16, personal protective equipment shall be provided and used to reduce sound levels within the levels of the table Requirements for handling hazardous materials including compressed gas and www.osha.gov flammable and combustible liquids. Each employer shall determine that compressed gas cylinders under his control are in a safe condition to the extent that this can be determined by visual inspection. Compressed gas cylinders, portable tanks, and cargo tanks shall have pressure relief devices installed and maintained in accordance with Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963, which is incorporated by reference as specified in Sec. 1910.6.
Application. Protective equipment, including personal protective equipment www.osha.gov for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact. The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall: 1)Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment; 2) Communicate selection decisions to each affected employee; and, 3) Select PPE that properly fits each affected employee. The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
A respirator shall be provided to each employee when such equipment is www.osha.gov necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, which shall include the requirements outlined in paragraph (c) of 29 CFR 1910.134. The program shall cover each employee required by this section to use a respirator. This standard covers the servicing and maintenance of machines and www.osha.gov equipment in which the energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy. Employer shall establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees. The employer shall ensure the ready availability of medical personnel for www.osha.gov advice and consultation on matters of plant health. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
RESPONSIBILITY
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Operations Manager
All Warehouse Personnel
Fire Prevention Plan
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hearing Conservation Program
Annual Audiograms Testing
N/A
Operations Manager
All Warehouse Personnel
Hazardous Material Training
N/A
N/A
Operations Manager
All Warehouse Personnel
PPE Procedure
Enter details, as determined by required PPE
N/A
Operations Manager
All Warehouse Personnel
Respiratory Protection Program
Annual Fit Testing
N/A
Operations Manager
All Warehouse Personnel
Lockout/Tagout Program
Annual Inspections
N/A
Operations Manager
All Warehouse Personnel
Emergency Action Plan
Annual review of Emergency Action Plan
N/A
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EHS Legal and Other Requirements Summary List United States TYPE
DESCRIPTION Fire Protection - Portable Fire Extinguishers
Compressed Air
Material Handling and Storage
Powered Industrial Truck Program
Machine Guarding
REGULATION 29 CFR 1910.157
29 CFR 1910.169
29 CFR 1910.176
29 CFR 1910.178
29 CFR 1910.211 to 1910.219
REQUIREMENT SUMMARY REGULATION LOCATION The employer shall provide portable fire extinguishers and shall mount, locate www.osha.gov and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. The employer shall assure that portable fire extinguishers are maintained in a fully charged and operable condition and kept in their designated places at all times except during use. Portable fire extinguishers shall be provided for employee use and selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use. The employer shall be responsible for the inspection, maintenance and testing of all portable fire extinguishers in the workplace. Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting.
This section applies to compressed air receivers, and other equipment used in www.osha.gov providing and utilizing compressed air for performing operations such as cleaning, drilling, hoisting, and chipping. Every air receiver shall be equipped with an indicating pressure gage (so located as to be readily visible) and with one or more spring-loaded safety valves. The total relieving capacity of such safety valves shall be such as to prevent pressure in the receiver from exceeding the maximum allowable working pressure of the receiver by more than 10 percent. All safety valves shall be tested frequently and at regular intervals to determine whether they are in good operating condition.
Where mechanical handling equipment is used, sufficient safe clearances www.osha.gov shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked. Storage of material shall not create a hazard. Bags, containers, bundles, etc., stored in tiers shall be stacked, blocked, interlocked and limited in height so that they are stable and secure against sliding or collapse. Storage areas shall be kept free from accumulation of materials that constitute hazards from tripping, fire, explosion, or pest harborage. Clearance signs to warn of clearance limits shall be provided. Safety requirements relating to fire protection, design, maintenance, and use www.osha.gov of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. The brakes of highway trucks shall be set and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with powered industrial trucks. The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation. Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely. An evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years.
Machine guarding shall be provided to protect the operator and other www.osha.gov employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices, electronic safety devices, etc. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.
Hand and Portable Power Tools
29 CFR 1910.241 to 1910.244
Each employer shall be responsible for the safe condition of tools and www.osha.gov equipment used by employees, including tools and equipment which may be furnished by employees.
Welding and Cutting - Hot Works
29 CFR 1910.251 & 252
Requirements for fire protection and prevention responsibilities of welders www.osha.gov and cutters, their supervisors (including outside contractors) and those in management on whose property cutting and welding is to be performed. Requirements include removal of hazards, availability of fire extinguishers and designated fire watchers. Before cutting or welding is permitted, the area shall be inspected by the individual responsible for authorizing cutting and welding operations. He shall designate precautions to be followed in granting authorization to proceed preferably in the form of a written permit.
Access to Exposure and Medical Records
000000416467170.xls Effective Date: 4-15-15
29 CFR 1910.1020
This section applies to each general industry, employer who makes, www.osha.gov maintains, contracts for, or has access to employee exposure or medical records, or analyses thereof, pertaining to employees exposed to toxic substances or harmful physical agents. Includes air monitoring, biomonitoring, MSDS sheets and respirator fit testing. Whenever an employee or designated representative requests access to a record, the employer shall assure that access is provided in a reasonable time, place, and manner. Records shall be kept for 30 years.
RESPONSIBILITY
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Operations Manager
All Warehouse Personnel
Fire Prevention Plan
Annual review of Fire Prevention Plan
N/A
Operations Manager
All Warehouse Personnel
Hazardous Material Training
N/A
N/A
Operations Manager
All Warehouse Personnel
Housekeeping Procedure
Monthly Inspections
N/A
Operations Manager
All Forklift Drivers
Forklift Training Program
Daily and Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Machine Guarding Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hand and Power Tool Procedure
Monthly Inspections
N/A
Operations Manager
All Hot Works Personnel
Hot Works Procedure
Hot Work Inspection Records
N/A
Operations Manager
All Warehouse Personnel
Access to Medical Records Procedure
Annual review of Access to Medical Records Procedure
N/A
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EHS Legal and Other Requirements Summary List United States TYPE
DESCRIPTION Blood Borne Pathogens
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REGULATION 29 CFR 1910.1030
REQUIREMENT SUMMARY REGULATION LOCATION If employees are reasonably exposed to blood or other potentially infectious www.osha.gov materials, the employer shall establish a written Exposure Control Plan designed to eliminate or minimize employee exposure. Requirements include: (1) an initial and updated exposure determination that evaluates the potential hazards involving bloodborne pathogens in the workplace (e.g., use of needles, razors or other sharps); (2) precautions for avoiding exposures including engineering and work practice controls, the use of personal protective equipment, etc.; (3) hazard communication for employees including use of biohazard signs/labels and annual/refresher training regarding potential hazards and safe/preventive work practices; and (4) recordkeeping.
RESPONSIBILITY
Operations Manager
TRAINING
All Warehouse Personnel
OPERATIONAL CONTROL
MONITORING
Bloodborne Pathogens Procedure Annual review of Bloodborne Pathogens Procedure
REPORTING
N/A
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Data Security Legal Requirements List TYPE Data Security Privacy Acts
DESCRIPTION
REGULATION NIST 800-88 Compliance
Financial Privacy Act
Gramm Leach Bliley - GLB
Financial Privacy Act
Sarbanes Oxley - SOX
Personal Health Privacy Act
Health Insurance Portability and Accountability Act - HIPAA
Privacy Act
USA Patriot Act
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Data Security Legal Requirements List TYPE
DESCRIPTION Educational Privacy Act
REGULATION Family Educations Rights and Privacy Act FERPA
Credit Privacy Act
Fair and Accurate Credit Transactions Act FACTA
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Data Security Legal Requirements List REQUIREMENT SUMMARY REGULATION LOCATION Must possess data security method of wiping and/or destruction compliant to csrc.nist.gov/nistpubs/800NIST 800-88 standards 88/nistp800-88-revl.pdf Requires that each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers' nonpublic personal information.
Operations Manager
Establishes national standards to protect individuals’ medical records and www.hhs.gov other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.
000000416467170.xls Effective Date:
Operations Manager
www.banking.senate.gov
Act is designed to oversee the financial reporting landscape for finance www.sec.gov professionals. Its purpose is to review legislative audit requirements and to protect investors by improving the accuracy and reliability of corporate disclosures. The act covers issues such as establishing a public company accounting oversight board, auditor independence, corporate responsibility and enhanced financial disclosure. It also significantly tightens accountability standards for directors and officers, auditors, securities analysts and legal counsel.
To deter and punish terrorist acts in the United States and around the world, to enhance law enforcement investigatory tools, and for other purposes.
RESPONSIBILITY
http://epic.org/privacy/terr orism/hr3162.html
Operations Manager
Operations Manager
Operations Manager
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Data Security Legal Requirements List REQUIREMENT SUMMARY Federal U.S. law that protects the privacy of student education records.
REGULATION LOCATION RESPONSIBILITY https://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html
FACTA amended the existing Fair Credit Reporting Act providing consumers, companies, consumer reporting agencies and regulators with new tools to expand consumer access to credit, enhance the accuracy of consumer financial information, and help fight identity theft.
http://www.gpo.gov/fdsys/pkg/PLAW-108publ159/html/PLAW-108publ159.htm
000000416467170.xls Effective Date:
Operations Manager
Operations Manager
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TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
000000416467170.xls Effective Date:
ADDITIONAL NOTES
000000Page 11 of 12
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
000000416467170.xls Effective Date:
ADDITIONAL NOTES
000000Page 12 of 12
EHS Legal and Other Requirements Summary List United States TYPE DESCRIPTION Air Emissions Emissions of Regulated Air Pollutants Emissions of Regulated Air Pollutants
Stormwater Discharge
Stormwater Discharges
REGULATION 40 CFR 51, 52 and 70 - Air Permitting LIST STATE REQUIREMENT
40 C.F.R. 122.6 Clean Water Act
Stormwater Discharges Hazardous and Hazardous Waste - Identification and Listing Universal Wastes FEDERAL
LIST STATE REQUIREMENT 40 CFR 261.2-261.4 Resource Conservation and Recovery Act (RCRA)
Requirements on the control of stormwater from municipal and industrial www.epa.gov stormwater discharges. The stormwater program is under the NPDES (National Pollutant Discharge Elimination System) part of the Clean Water Act. The regulation is meant to reduce the amount of pollutants entering streams, lakes and rivers as a result of runoff from residential, commercial and industrial areas. A National Pollutant Discharge Elimination System (NPDES) Permit is required for the point source discharges of facility surface water to surface waters of the 'State'. 261.2 - Definition of solid waste www.epa.gov 261.2 - Definition of hazardous waste 261. 4a 13&14 - Scrap metals and circuit boards are excluded from hazardous waste classifications.
40 CFR 261.11 Resource Conservation and Recovery Act (RCRA)
Facilities must identify and document whether their waste is classified as hazardous or non-hazardous using RCRA-defined waste classification codes.
www.epa.gov
Hazardous Waste
40 CFR 262.12 Resource Conservation and Recovery Act (RCRA)
Facilities must obtain a EPA hazardous waste ID number.
www.epa.gov
Universal Waste
40 C.F.R. 273 Subp’s. A, B and F
www.epa.gov
CRT Final Rule
40 CFR Parts 9, 260, 261, and 271
Standards for the Management of Universal Waste including Waste management, Labeling, Accumulation, Training, Release Response, Transportation, Record Keeping. Covers fluorescent bulbs, lead acid batteries and lithium batteries. "A cathode ray tube (CRT) is the glass video display component of an electronic device (usually a computer or television monitor). This final rule streamlines management and exporting requirements for recycling of used CRTs and glass removed from CRTs under the Resource Conservation and Recovery Act (RCRA). The amendments exclude these materials from the RCRA definition of solid waste if certain conditions are met. The rule is intended to encourage recycling and reuse of used CRTs and CRT glass."
www.epa.gov
Resource Conservation and Recovery Act (RCRA)
"This final rule adds mercury-containing equipment to the federal list of universal wastes regulated under the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations. Handlers of universal wastes are subject to less stringent standards for storing, transporting, and collecting these wastes. EPA has concluded that regulating spent mercury-containing equipment as a universal waste will lead to better management of this equipment and will facilitate compliance with hazardous waste requirements."
Disposal of PCBs Final Rule
40 CFR 761 Resource Conservation and Recovery Act (RCRA)
Standards for storing, accumulation, disposal, reporting and clean up of PCB wastes containing greater than 50 ppm but less than 500 ppm of PCB material.
www.epa.gov
Management of Lead Acid Batteries
40 CFR 266.80 Resource Conservation and Recovery Act (RCRA)
Standards for handling, storing, labeling, disposal and clean up of lead acid batteries.
www.epa.gov
Management of Used Oils
40 CFR 279 Resource Conservation and Recovery Act (RCRA)
Standards for storing, labeling, disposal and clean up of Used Oil.
www.epa.gov
SREA Criteria for Recycling Transactions
42 USC 9627
Required recordkeeping to qualify for the Superfund liability exemption for recycling transactions.
www.epa.gov
40 CFR 761
Standards for labeling, storing, disposal, spill procedures, clean up, record retention, reporting (annual log) of PCB wastes. PCB waste must be disposed of within one year from the date taken out of service.
www.epa.gov
Notification of PCB Activity is required for a generator with onsite storage facility.
www.epa.gov
Discarded Mercury-Containing Equipment Final Rule
TSCA Federal Disposal of PCBs Final Rule
40 CFR Parts 260, 261, 264, 265, 268, 270, and 273
Resource Conservation and Recovery Act (RCRA)
EPCRA
REGULATION LOCATION www.epa.gov
Hazardous Waste - Criteria for Listing
Resource Conservation and Recovery Act (RCRA)
Superfund
REQUIREMENT SUMMARY Standard for air permitting requirements, including air permit application, permit limits, required monitoring, and reporting and record keeping requirements. State Air Pollution Control Requirements for classification of air pollution sources, registration, permitting, monitoring, inspections, maintenance, reporting and record keeping.
40 CFR 761
Emergency Planning and Community Right-to-Know Reporting and Release Notification
40 CFR Parts 350 through 372 - SARA Title III Emergency planning and notification, community right to know reporting www.epa.gov requirements when hazardous chemicals (as defined by OSHA), hazardous substances (as defined by CERCLA) and extremely hazardous substances (EHS) exceed threshold planning quantities or reportable quantities (for releases). This facility does not store or use EHS. When the TPQ of any hazardous chemical or hazardous substance is exceeded, hazardous chemical inventory reporting is required. If a hazardous chemical or hazardous substance is release at or above the reportable quantity, release reporting is required. The State has adopted the federal requirements.
000000416467170.xls Effective Date: 4-15-15
40 CFR 110 and 355
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Shred Personnel
Dust Collection Procedure
Daily Magnehelic Gauge Reading Annual Report due by Jan 1st of every year.
Operations Manager
Shred Personnel
Dust Collection Procedure
Daily Magnehelic Gauge Reading Annual Report due by Jan 1st of every year.
Operations Manager
All Warehouse Personnel
Stormwater Pollution Prevention Plan
Monthly Stormwater Inspections. Annual Report due by Jan 1st of Quarterly stormwater sampling every year.
Operations Manager
All Warehouse Personnel
Stormwater Pollution Prevention Plan
Monthly Stormwater Inspections. Annual Report due by Jan 1st of Quarterly stormwater sampling every year.
Operations Manager
All Warehouse Personnel
Hazardous Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hazardous Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hazardous Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Universal Waste Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
Notify US EPA of intent to export.
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Shipping Personnel
Downstream Due Diligence Procedure
Annual Review of records
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Material Storage and Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
EPCRA Procedure
Annual review of EPCRA procedure
Currently hazardous chemicals and hazardous substances are below TPQs; facility will continue to monitor incoming hazardous materials and applicability will be re-evaluated.
Operations Manager
All Warehouse Personnel
SPCC Plan
Annual review of SPCC Plan
As required by SPCC
www.epa.gov
Notification of PCB Activity
Spill Reporting Spill Reporting Requirements
RESPONSIBILITY Operations Manager
Requirements for reporting releases of oil and hazardous chemicals. The State www.epa.gov has adopted the federal spill reporting requirements.
000000Page 2 of 12
EHS Legal and Other Requirements Summary List United States TYPE DESCRIPTION Hazardous, STATE Standards for Hazardous Waste Management Universal and Industrial Wastes STATE
REGULATION
REQUIREMENT SUMMARY
REGULATION LOCATION
RESPONSIBILITY
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Operations Manager
STATE Standards for Used Oil Management
Operations Manager
STATE Universal Waste Management Operations Manager Electronics STATE Electronics Recycling Law Recycling Law STATE Operations Manager
TRANSPORT
Federal Motor Carrier Safety Regulations
CFR 49 Parts 382, 383, 387, 390-397, and 40 Requirements for transporters including; drivers drug and alcohol screening, Commercial Driver's License Standards; Requirements and Penalties, Federal Motor Carrier Safety Regulations; General and Qualifications of Drivers
STATE Transportation - Division of Motor Vehicles
Health and Safety FEDERAL
http://www.fmcsa.dot.gov
Requirements for transporters including: Commercial Driver's License Standards, vehicle registrations, Requirements and Penalties, medical evaluation, GVWR, motor vehicle safety, and financial responsibility. 49 CFR 173.185 (d)
Packaging requirements for lithium battery shipments.
Walking and Working Surfaces - Slips, Trips, & Falls
29 CFR 1910.21 to 1910.30
Verify that all places of employment, passageways, storerooms, and service www.osha.gov rooms are kept clean and orderly and in a sanitary condition. The floor of every workroom shall be maintained in a clean and, so far as possible, a dry condition. To facilitate cleaning, every floor, working place, and passageway shall be kept free from protruding nails, splinters, holes, or loose boards. Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repairs, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked. Protection requirements for floor openings, wall openings, open-sided floors, platforms, and runways, stair rails, portable step ladders, scaffolding,
Means of Egress - Exit Routes
Emergency Action Plan
000000416467170.xls Effective Date: 4-15-15
29 CFR 1910.23
29 CFR 1910.35 to 1910.37
29 CFR 1910.38
Transportation Procedure
Daily & Monthly Inspections
Add specific details as required, by type of license and vehicles
Operations Manager
All Transport Personnel
Battery Shipping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Housekeeping Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Fall Prevention Plan
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Emergency Action Plan
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Emergency Action Plan
Monthly Inspections
N/A
Operations Manager
Transport of Lithium Batteries
Fall Prevention
All Transport Personnel
Operations Manager
www.epa.gov
Open-sided floors or platforms 4 feet or more above adjacent floor or ground www.osha.gov level must be guarded by a standard railing (guardrail) or equivalent. Employees may work on an extension or step ladder up to the maximum working height of the ladder as specified by the ladder manufacturer. Requirements for emergency exits. Exit routes must be free and www.osha.gov unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. Each exit must be clearly visible and marked by a sign reading "Exit." and illuminated. If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to an exit sign must clearly be visible at all times. An emergency action plan must be in writing, kept in the workplace, and www.osha.gov available to employees for review. An emergency action plan must include at a minimum: 1) Procedures for reporting a fire or other emergency; 2) Procedures for emergency evacuation, including type of evacuation and exit route assignments; 3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; 4) Procedures to account for all employees after evacuation; 5) Procedures to be followed by employees performing rescue or medical duties; and the name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan. An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165. An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. An employer must review the emergency action plan with each employee covered by the plan.
000000Page 3 of 12
EHS Legal and Other Requirements Summary List United States TYPE
DESCRIPTION Fire Prevention Plan
Hearing Conservation
Hazardous Materials
REGULATION 29 CFR 1910.39
29 CFR 1910.95
29 CFR 1910.101 to 1910.126
Personal Protective Equipment, and Hazard Assessments 29 CFR 1910.132-139
Respiratory Program
Lockout/Tagout Program
Medical Services and First Aid
000000416467170.xls Effective Date: 4-15-15
29 CFR 1910.134
29 CFR 1910.147
29 CFR 1910.151
REQUIREMENT SUMMARY REGULATION LOCATION A fire prevention plan must be in writing, be kept in the workplace, and be www.osha.gov made available to employees for review. Minimum elements of a fire prevention plan. A fire prevention plan must include: 1)A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard; 2) Procedures to control accumulations of flammable and combustible waste materials; 3) Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials; 4) The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and 5) the name or job title of employees responsible for the control of fuel source hazards. An employer must inform employees upon initial assignment to a job of the fire hazards to which they are exposed. An employer must also review with each employee those parts of the fire prevention plan necessary for self-protection.
Protection against the effects of noise exposure shall be provided when the www.osha.gov sound levels exceed those shown in Table G-16 . (90 dBA over an eight hour TWA.) When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of Table G-16, personal protective equipment shall be provided and used to reduce sound levels within the levels of the table Requirements for handling hazardous materials including compressed gas and www.osha.gov flammable and combustible liquids. Each employer shall determine that compressed gas cylinders under his control are in a safe condition to the extent that this can be determined by visual inspection. Compressed gas cylinders, portable tanks, and cargo tanks shall have pressure relief devices installed and maintained in accordance with Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963, which is incorporated by reference as specified in Sec. 1910.6.
Application. Protective equipment, including personal protective equipment www.osha.gov for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact. The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall: 1)Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment; 2) Communicate selection decisions to each affected employee; and, 3) Select PPE that properly fits each affected employee. The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
A respirator shall be provided to each employee when such equipment is www.osha.gov necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, which shall include the requirements outlined in paragraph (c) of 29 CFR 1910.134. The program shall cover each employee required by this section to use a respirator. This standard covers the servicing and maintenance of machines and www.osha.gov equipment in which the energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy. Employer shall establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees. The employer shall ensure the ready availability of medical personnel for www.osha.gov advice and consultation on matters of plant health. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
RESPONSIBILITY
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Operations Manager
All Warehouse Personnel
Fire Prevention Plan
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hearing Conservation Program
Annual Audiograms Testing
N/A
Operations Manager
All Warehouse Personnel
Hazardous Material Training
N/A
N/A
Operations Manager
All Warehouse Personnel
PPE Procedure
Enter details, as determined by required PPE
N/A
Operations Manager
All Warehouse Personnel
Respiratory Protection Program
Annual Fit Testing
N/A
Operations Manager
All Warehouse Personnel
Lockout/Tagout Program
Annual Inspections
N/A
Operations Manager
All Warehouse Personnel
Emergency Action Plan
Annual review of Emergency Action Plan
N/A
000000Page 4 of 12
EHS Legal and Other Requirements Summary List United States TYPE
DESCRIPTION Fire Protection - Portable Fire Extinguishers
Compressed Air
Material Handling and Storage
Powered Industrial Truck Program
Machine Guarding
REGULATION 29 CFR 1910.157
29 CFR 1910.169
29 CFR 1910.176
29 CFR 1910.178
29 CFR 1910.211 to 1910.219
REQUIREMENT SUMMARY REGULATION LOCATION The employer shall provide portable fire extinguishers and shall mount, locate www.osha.gov and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. The employer shall assure that portable fire extinguishers are maintained in a fully charged and operable condition and kept in their designated places at all times except during use. Portable fire extinguishers shall be provided for employee use and selected and distributed based on the classes of anticipated workplace fires and on the size and degree of hazard which would affect their use. The employer shall be responsible for the inspection, maintenance and testing of all portable fire extinguishers in the workplace. Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting.
This section applies to compressed air receivers, and other equipment used in www.osha.gov providing and utilizing compressed air for performing operations such as cleaning, drilling, hoisting, and chipping. Every air receiver shall be equipped with an indicating pressure gage (so located as to be readily visible) and with one or more spring-loaded safety valves. The total relieving capacity of such safety valves shall be such as to prevent pressure in the receiver from exceeding the maximum allowable working pressure of the receiver by more than 10 percent. All safety valves shall be tested frequently and at regular intervals to determine whether they are in good operating condition.
Where mechanical handling equipment is used, sufficient safe clearances www.osha.gov shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked. Storage of material shall not create a hazard. Bags, containers, bundles, etc., stored in tiers shall be stacked, blocked, interlocked and limited in height so that they are stable and secure against sliding or collapse. Storage areas shall be kept free from accumulation of materials that constitute hazards from tripping, fire, explosion, or pest harborage. Clearance signs to warn of clearance limits shall be provided. Safety requirements relating to fire protection, design, maintenance, and use www.osha.gov of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. The brakes of highway trucks shall be set and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with powered industrial trucks. The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation. Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely. An evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years.
Machine guarding shall be provided to protect the operator and other www.osha.gov employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices, electronic safety devices, etc. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.
Hand and Portable Power Tools
29 CFR 1910.241 to 1910.244
Each employer shall be responsible for the safe condition of tools and www.osha.gov equipment used by employees, including tools and equipment which may be furnished by employees.
Welding and Cutting - Hot Works
29 CFR 1910.251 & 252
Requirements for fire protection and prevention responsibilities of welders www.osha.gov and cutters, their supervisors (including outside contractors) and those in management on whose property cutting and welding is to be performed. Requirements include removal of hazards, availability of fire extinguishers and designated fire watchers. Before cutting or welding is permitted, the area shall be inspected by the individual responsible for authorizing cutting and welding operations. He shall designate precautions to be followed in granting authorization to proceed preferably in the form of a written permit.
Access to Exposure and Medical Records
000000416467170.xls Effective Date: 4-15-15
29 CFR 1910.1020
This section applies to each general industry, employer who makes, www.osha.gov maintains, contracts for, or has access to employee exposure or medical records, or analyses thereof, pertaining to employees exposed to toxic substances or harmful physical agents. Includes air monitoring, biomonitoring, MSDS sheets and respirator fit testing. Whenever an employee or designated representative requests access to a record, the employer shall assure that access is provided in a reasonable time, place, and manner. Records shall be kept for 30 years.
RESPONSIBILITY
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
Operations Manager
All Warehouse Personnel
Fire Prevention Plan
Annual review of Fire Prevention Plan
N/A
Operations Manager
All Warehouse Personnel
Hazardous Material Training
N/A
N/A
Operations Manager
All Warehouse Personnel
Housekeeping Procedure
Monthly Inspections
N/A
Operations Manager
All Forklift Drivers
Forklift Training Program
Daily and Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Machine Guarding Procedure
Monthly Inspections
N/A
Operations Manager
All Warehouse Personnel
Hand and Power Tool Procedure
Monthly Inspections
N/A
Operations Manager
All Hot Works Personnel
Hot Works Procedure
Hot Work Inspection Records
N/A
Operations Manager
All Warehouse Personnel
Access to Medical Records Procedure
Annual review of Access to Medical Records Procedure
N/A
000000Page 5 of 12
EHS Legal and Other Requirements Summary List United States TYPE
DESCRIPTION Blood Borne Pathogens
000000416467170.xls Effective Date: 4-15-15
REGULATION 29 CFR 1910.1030
REQUIREMENT SUMMARY REGULATION LOCATION If employees are reasonably exposed to blood or other potentially infectious www.osha.gov materials, the employer shall establish a written Exposure Control Plan designed to eliminate or minimize employee exposure. Requirements include: (1) an initial and updated exposure determination that evaluates the potential hazards involving bloodborne pathogens in the workplace (e.g., use of needles, razors or other sharps); (2) precautions for avoiding exposures including engineering and work practice controls, the use of personal protective equipment, etc.; (3) hazard communication for employees including use of biohazard signs/labels and annual/refresher training regarding potential hazards and safe/preventive work practices; and (4) recordkeeping.
RESPONSIBILITY
Operations Manager
TRAINING
All Warehouse Personnel
OPERATIONAL CONTROL
MONITORING
Bloodborne Pathogens Procedure Annual review of Bloodborne Pathogens Procedure
REPORTING
N/A
000000Page 6 of 12
Data Security Legal Requirements List TYPE Data Security Privacy Acts
DESCRIPTION
REGULATION NIST 800-88 Compliance
Financial Privacy Act
Gramm Leach Bliley - GLB
Financial Privacy Act
Sarbanes Oxley - SOX
Personal Health Privacy Act
Health Insurance Portability and Accountability Act - HIPAA
Privacy Act
USA Patriot Act
000000416467170.xls Effective Date:
000000Page 7 of 12
Data Security Legal Requirements List TYPE
DESCRIPTION Educational Privacy Act
REGULATION Family Educations Rights and Privacy Act FERPA
Credit Privacy Act
Fair and Accurate Credit Transactions Act FACTA
000000416467170.xls Effective Date:
000000Page 8 of 12
Data Security Legal Requirements List REQUIREMENT SUMMARY REGULATION LOCATION Must possess data security method of wiping and/or destruction compliant to csrc.nist.gov/nistpubs/800NIST 800-88 standards 88/nistp800-88-revl.pdf Requires that each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers' nonpublic personal information.
Operations Manager
Establishes national standards to protect individuals’ medical records and www.hhs.gov other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.
000000416467170.xls Effective Date:
Operations Manager
www.banking.senate.gov
Act is designed to oversee the financial reporting landscape for finance www.sec.gov professionals. Its purpose is to review legislative audit requirements and to protect investors by improving the accuracy and reliability of corporate disclosures. The act covers issues such as establishing a public company accounting oversight board, auditor independence, corporate responsibility and enhanced financial disclosure. It also significantly tightens accountability standards for directors and officers, auditors, securities analysts and legal counsel.
To deter and punish terrorist acts in the United States and around the world, to enhance law enforcement investigatory tools, and for other purposes.
RESPONSIBILITY
http://epic.org/privacy/terr orism/hr3162.html
Operations Manager
Operations Manager
Operations Manager
000000Page 9 of 12
Data Security Legal Requirements List REQUIREMENT SUMMARY Federal U.S. law that protects the privacy of student education records.
REGULATION LOCATION RESPONSIBILITY https://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html
FACTA amended the existing Fair Credit Reporting Act providing consumers, companies, consumer reporting agencies and regulators with new tools to expand consumer access to credit, enhance the accuracy of consumer financial information, and help fight identity theft.
http://www.gpo.gov/fdsys/pkg/PLAW-108publ159/html/PLAW-108publ159.htm
000000416467170.xls Effective Date:
Operations Manager
Operations Manager
000000Page 10 of 12
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
000000416467170.xls Effective Date:
ADDITIONAL NOTES
000000Page 11 of 12
TRAINING
OPERATIONAL CONTROL
MONITORING
REPORTING
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
All Data Destruction Personnel
Data Destruction Procedure
Annual Data Validaition
N/A
000000416467170.xls Effective Date:
ADDITIONAL NOTES
000000Page 12 of 12
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