At a recent meeting of the Safety Roundtable, hosted by the Small Business Administration, SGIA heard updates on regulatory issues impacting the specialty printing industry. Marc Freedman of the Coalition for Workplace Safety spoke on OSHA’s ongoing regulatory initiatives, including OSHA’s Request for Information on chemical permissible exposure limits (PELs), and OSHA’s proposed rule to require certain employers to submit their injury and illness reports electronically. Other issues raised included a principal change adopted by OSHA in the 2012 Hazard Communication Standard that state that requires the relabeling of a product within six months if significant new information results in a change in classification. For details on any of these issues, please contact SGIA’s Government Affairs Department at email@example.com.
OSHA has issued a proposed rule to clarify an “Employer’s Continuing Obligation to Make and Maintain an Accurate Record of Each Recordable Injury and Illness” for the entire 5 year period which an employer is required to keep the records.
In part this proposal is based on the outcome of the U.S. Court of Appeals case (Volks decision) where OSHA attempted to clarify that the duty to record an injury or illness continues for as long as the employer must keep records of the recordable injury or illness (the 5 year period). While this proposal does not request additional compliance requirements or records to be made, it goes beyond the established statue of not issuing citations beyond six months of when a violation occurred and has the real potential for additional citations and fines to be issued for an administrative task and no benefit to safety.
SGIA has submitted comments to OSHA opposing this proposed rule and requested it be withdrawn. If you would like a copy of the comments submitted, please contact firstname.lastname@example.org. SGIA’s government staff will be monitoring the activity surrounding this proposal and will report any new developments.
On September 30th, Marci Kinter, SGIA's Vice President - Government & Business Information, in conjunction with representatives from the Great Lakes Graphics Association and Flexographic Technical Association, formally signed the Green Tier Charter to help advance sustainable business practices within the printing industry while improving regulatory efficiency. Printing is a major business sector in Wisconsin with more than 1,000 facilities in operation.
The charter also identifies the linkage between the industry's national Sustainable Green Printing Partnership (SGP) certification program and Wisconsin's Green Tier program, making it simpler for printers to participate in both and laying out clear expectations for additional learning and sharing.
Green Tier is a voluntary program that recognizes and rewards environmental performance "that voluntarily exceeds legal requirements related to health, safety and the environment resulting in continuous improvement in this state's environment, economy, and quality of life." SGIA welcomes the opportunity to partner with the Wisconsin Department of Natural Resources as we work together to implement the charter's provisions.
The best time to prepare for an accident or emergency is before one happens. With the recent severe weather across the nation, hurricanes, flash floods, tornadoes, and fires, are forcing people to evacuate their homes and workplace sometimes without warning and when they least expect it. It may be time to review your emergency action plan and follow these basic points:
- Establish phone lists for key personnel and make sure they are up to date.
- Identify all possible emergencies and evacuation requirements
- Establish evacuation routes and procedures
- Plan for the loss of services of electricity, water, telephone, sewer, etc.
- Identify any operation or materials that could pose a danger to the public in the event of a disaster or emergency.
- Assign and train emergency shutdown teams if applicable.
- Establish a means to account for all employees once evacuated.
Ensure annual drills and training for all employees, especially new employees, and review the plan with employees at least annually for the most effective response
SGIA submitted comments to the Virginia Department of Environmental Quality on the proposed revisions contained in Article 57, Emission Standards for Industrial Solvent Cleaning Operations in Northern Virginia, Volatile Organic Compound Emissions Control Area, 8 hour Ozone Standard (Rule 4-57). SGIA's intent is to encourage adoption of a regulation that conforms with the industrial solvent cleaning regulations adopted by other states in the same geographic area. Promulgation of any regulatory controls, such as those proposed by the VA DEQ, should allow an industry sector to use the materials that are technologically compatible with their manufacturing process. The comments we offered seek to explore alternative means to promulgate the regulation that will result in environmental benefit without sacrificing an entire industrial sector.
SGIA, as with similar state regulatory proposals, recommended the that State adopt a VOC content limit of 4.2 pounds of VOC per gallon for industrial solvents used by screen printing facilities, and that cleaning operations associated with digital printing be exempt. For more information on this regulatory action, please contact Marci Kinter, Vice President - Government & Business Information at email@example.com.