There's Value in Hand Holding
By Ted Polakowski, Sr. Vice President
We can all use some help and advice when implementing a new application or program. A little hand holding in the beginning can save weeks of frustration down the road -- not to mention the confidence that you and your organization are starting on the right track and set for long-term success. When you subscribe to our Applicability Review Tool (ART), Citation Technologies can offer you the consultative services you may need to successfully integrate our products with your compliance assurance and risk management activities.
It is with great pleasure that I introduce our first Citation Certified Facilitator, Ann Goulet. While employed by BP, Ann set in motion the very applications she will facilitate for Citation Technologies. As BP's Global HSSE Compliance Manager, Ann was responsible for helping several major business units achieve successful implementation of a Compliance Management System, in part by using the ART application.
By working with Ann, companies are able to develop solutions they may not have been able to achieve without her assistance.
Citation Certified Facilitators:
· Ensure key members or interests are represented
· Create a team dynamic
· Encourage dialogue
· Drive the ART implementation
· Draw on past experience to challenge answers
· Become involved in the process
· Assist in development of a high quality site legal registry
I can personally attest that the benefits of using a facilitator are astonishing. Not only is there a high quality applicability register generated, there is also a great deal of learning accomplished. The team then returns to the workplace with a much better understanding of their role in the compliance journey. A little hand holding in the beginning makes for a great start.
If you have time on Tuesday morning, I invite you to meet Ann at our ART Mexico webinar. We'll be explaining the benefits of using our Applicability Review Tool to create your custom applicable requirements register, a.k.a. site legal registry. I am confident it will be time well-spent. |
EPA to Strengthen Air Quality Standards for Sulfur Dioxide
For the first time in nearly 40 years, EPA is
proposing to strengthen the nation's sulfur dioxide (SO2) air quality
standard to protect public health. Power plants and other industrial
facilities emit SO2 directly into the air. Exposure to SO2 can
aggravate asthma, cause respiratory difficulties, and result in
emergency room visits and hospitalization. People with asthma,
children, and the elderly are especially vulnerable to SO2's effects.
Short-term exposures to peak SO2
levels can have significant health effects - especially for children
and the elderly - and leave our families and taxpayers saddled with
high health care costs," said EPA Administrator Lisa P. Jackson. "We're
strengthening clean air standards, stepping up monitoring and reporting
in communities most in need, and providing the American people with
protections they rightly deserve."
EPA is taking comment on a proposal to establish a new national
one-hour SO2 standard, between 50 and 100 parts per billion (ppb). This
standard is designed to protect against short-term exposures ranging
from five minutes to 24 hours. Because the revised standards would be
more protective, EPA is proposing to revoke the current 24-hour and
annual SO2 health standards.
EPA also is proposing changes to monitoring and reporting
requirements for SO2. Monitors would be placed in areas with high SO2
emission levels as well as in urban areas. The proposal also would
change the Air Quality Index to reflect the revised SO2 standards. This
change would improve states' ability to alert the public when
short-term SO2 levels may affect their health.
The proposal addresses only the SO2 primary standards, which are
designed to protect public health. EPA will address the secondary
standard - designed to protect the public welfare, including the
environment - as part of a separate proposal in 2011.
EPA first set National Ambient Air Quality Standards for SO2 in
1971, establishing both a primary standard to protect health and a
secondary standard to protect the public welfare. Annual average SO2
concentrations have decreased by more than 71 percent since 1980.
The public comment period will be open for 60 days after the
proposal is published in the Federal Register. The agency held a
public hearing on Jan. 5, 2010 in Atlanta. EPA must issue final
standards by June 2, 2010.
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Pack Trends for a New Year
By Ilya Leybovich from Industry Market Trends
Reduced consumer spending along with businesses' cost-cutting initiatives frequently put innovation efforts on the back burner throughout this difficult year. Yet the packaging industry has found ways to remain dynamic and reactive to shifting market needs. Here we look at some of the key packaging developments that have shaped the industry in 2009, as well as emerging trends that may play a significant role in packaging in the coming year.
Although 2009 was a difficult year for businesses across the board, a number of trends, particularly sustainable packaging, continue to exert a significant influence on the packaging field and are likely to guide pack strategies for the near future. Experts also cite some emerging concepts that are already gaining prominence in packaging as we make our way into 2010.
The Sustainability Imperative
As with last year's top pack trends, sustainability remains a driving force in packaging, with increasingly more businesses across the sector incorporating eco-friendly thinking into their packaging and processes.
According to an annual survey from Packaging Digest, 41 percent of packaging companies said they are very familiar with sustainability issues, compared to 21 percent in 2007. In addition, 68 percent of survey respondents in November claimed sustainable packaging efforts have increased in the past year, while only 4 percent said they have seen a decrease.
Approximately two-thirds of the survey's 1,012 respondents said that consumer demand from both retailers and customers is driving the focus on eco-friendly packaging. The use of recycled or recyclable materials were listed as high priorities in sustainability initiatives, as were better collection and recovery methods, improvements in education and training, and development of new materials.
"[S]ustainability has evolved into a mainstream commitment," the Packaging Machinery Manufacturers Institute (PMMI) explained in a packaging trends report last month. "Sustainable practices encourage sales by addressing consumers' interest in 'greener' products, and by reducing waste and conserving resources, they often generate cost savings."
The PMMI cites five primary sustainability categories: utility conservation, source reduction, recycled content, recyclability and renewable materials. Conserving water by removing it from the conveyor lubrication process and saving energy by installing power-consumption monitoring tools on packaging equipment are two of the methods gaining usage in this field.
Similarly, reducing waste by implementing closed extrusion systems in label production and replacing key materials with more easily recyclable compounds, such as swapping mixed polymer laminates for polyester in lidstock, are also methods gaining traction in the move toward sustainable packaging, PMMI notes.
"This movement toward biodegradable and compostable materials is definitely an established trend. We'll see that continue," John R. Burke, president of the Foodservice and Packaging Institute, told QSR Magazine. "On the plastics side, what you have going on is not so much plastic versus paper but a plastic resin versus another plastic resin or polystyrene versus polypropylene. You have to try to get a share of the market wherever you can grab it."
Emerging Trends
Sustainability is not the only concept expected to play a key role in packaging innovations in the coming year. In a recent report titled Consumer Packaged Goods Trend Predictions for 2010, market and trend analysis firm Mintel listed several emerging packaging ideas expected to influence the industry in the near future. Among them:
Symbol Overload - Consumers want to see information on their products, but some forms, such as nutritional facts, come across as confusing or cluttered. For this reason, more manufacturers will introduce simple, clean front-of-package information.
Local Expands - Buying only local goods may be impractical, but many consumers prefer packaging that signals a product as being from a place that is at least recognizable. As a result, more companies are working to broaden the definition of "local."
Simple into Special - More stylish packaging is expected to make purchasing day-to-day goods like juice or soap feel more enjoyable.
Color-coding - More manufacturers are forecast to apply color-coded packaging to make shopping for retail goods easier.
"Post-recession, we don't expect manufacturers to reinvent the wheel. Instead, we predict 2010's new products will give shoppers something familiar paired with something new to better satisfy their needs," Lynn Dornblaser, new products expert for Mintel, said in an announcement of the findings. "[W]e expect today's familiar megatrends - health and wellness, convenience, sustainability - to get a fresh, new makeover for 2010."
Innovation Through Design
Financial concerns remain a high priority for packaging firms, but difficult conditions may also be driving new design trends. According to a September survey from Food Engineering Magazine, 28 percent of packaging companies are introducing new packaging designs and installing new equipment in an effort to increase market share through the downturn.
"A poor economy poses an opportunity for innovative companies to differentiate themselves while the rest of the market is holding back," the survey says. (See Innovate Through the Downturn)
An ongoing design development involves reducing the amount of secondary packaging, such as over-wrap or excessive packaging film, both for consumer convenience and to save on materials costs. For example, Amazon.com recently added new toys to its "frustration-free" packaging program designed to simplify the difficulty of opening gifts during the holiday season.
Streamlined, clutter-free packaging design is becoming a widespread goal, particularly as companies pay closer attention to consumer needs in a period of reduced demand and spending. "Package design should start with the realization that 'clutter' is the universal reality of the shopping experience. It is necessary to break through the clutter to generate shoppers' interests, so clean, simple designs are best. Physical packaging that extends usage and stands out will also help keep your brand top of mind," Shikatani Lacroix DesignLounge explained in a November whitepaper.
Lastly, using "attitudinal" packaging to show that a company has a commitment or purpose beyond simply profiting from its sales is likely to be a key feature of future pack designs.
"[A]s retailers increasingly grow their share of own brand at the expense of rival brands, manufacturers will need to find a purpose beyond price to remain listed by retailers," the U.K.-based Design Council says. "These two factors point to brands having to use their packs to entertain and 'jolt' consumers out of their existing repertoires at point of purchase, and become far more stimulating than simply being a big logo on a box.
Reprinted with permission from ThomasNet.
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Federal Responsibility for Katrina FloodingThe news is two months old but still creating waves: a federal judge ruled in November that "gross negligence" by the Army Corps of Engineers was responsible for some of the flooding from Hurricane Katrina in 2005.
US District Judge Stanwood Duval Jr. said that the Corps was aware of, and had admitted, problems with the Mississippi River-Gulf Outlet but failed to fix them, and he awarded a total of $719,000 to a group of flood victims from New Orleans' Lower 9th Ward and St. Bernard Parish. It was the first time the government has been held responsible for any flood damage from Katrina, and the decision (which the government has said it will appeal) opens the door for other suits.
However, Judge Duval did draw a distinction between the damage resulting from the MRGO and other Katrina-related claims. He ruled in 2008 that under federal law, the Corps has immunity from damages caused by the failure of various flood-control structures. The difference in this case is that the MRGO is a navigation channel, not primarily a flood-control structure, and the immunity does not apply. He said essentially that the Corps' activities in the MRGO-such as failing to armor the channel's banks to protect against ship wakes and allowing saltwater to encroach on and destroy wetlands-contributed to the destruction of a section of levee. | |
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Happy New Year
by Regulation Rita
As a new year and a new decade begin, many of us turn our thoughts towards goals and resolutions to improve 2010. What about a goal of simplifying your job?
Give your EWS a "New Years Makeover": EWS (Early Warning Service) Notifications are the emails CyberRegs sends that use criteria you specify to alert you of changes you care about. Are you signed up? Is it time to fine-tune your search criteria? Hit "reply" on any EWS Notification, and it go directly to Customer Service; so let us know what adjustments you need.
Make sure your Document Display Settings are activated: Regulations are big; don't wait for your browser to load more information than you need. Change the setting to "Display single segments" and save your settings. Documents will display a table of contents first, and allow you to select what you need before loading the text.
Set your Bookmarks: Bookmarks are a great way to access documents quickly. Bookmark a menu, a document... all the way down to a Sub-Paragraph. What bookmark do I recommend most for 2010? The individual Parts (or Subparts) of the Clean Air Act you use.
Take advantage of your Quick Link - Take your most used bookmark, and set it as your Quick Link. By clicking on the small blue box to the left of your bookmark. From that point on, just click on your "Quick Link" button on your toolbar for your document to automatically load.
Schedule Training - Whether you're new to CyberRegs or you're an old pro at the site, there are always new things to learn about CyberRegs. We want to make sure you get the most out of the powerful tools you're being provided. Review our Training Schedule, or contact us to arrange a private session.
As always, we appreciate your business, and look forward to a safe and green 2010 with all of you.
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EPA
Fines Puerto Rico Air National Guard for Improperly Managing Underground Petroleum Storage Tanks
EPA has
issued a complaint to the Puerto Rico Air National Guard, part of the U.S. Air
Force, for improperly managing underground tanks used to store diesel fuel and
gasoline at its facility in Toa Baja. Leaking underground storage tanks pose significant threats to soil, surface
water and ground water. EPA cited the Puerto Rico Air National Guard
for failing to properly monitor its storage tanks for leaks and maintain
records of release detection for two underground storage tank systems; the
Agency is seeking a civil penalty of $154,353.
"Out
of sight does not mean out of mind when it comes to underground storage tanks,
which is why it is critical that facilities monitor their tanks and make sure
they are not leaking," said EPA Regional Administrator Judith Enck. "Given the
close proximity of the Air National Guard facility to the coastline, leaks from
its underground petroleum storage systems could have caused a serious
environmental problem."
The
Puerto Rico Air National Guard's Toa Baja facility is about 10 miles west of
San Juan and is located near the popular Punta Salinas Park. The two
underground storage tank systems at the facility are subject to the
requirements laid out under Puerto Rico's underground storage tank program. The
tanks have been emptied as the facility no longer requires a fueling station.
EPA's
complaint also cites the Puerto Rico Air National Guard for failing to give the
Puerto Rico Environmental Quality Board (EQB) required information about these
underground storage tank systems. EQB is responsible for implementing and
enforcing the requirements of the Puerto Rico Public Policy Act of 1970, which
set forth requirements for owners and operators of underground storage tank
systems.
Petroleum releases from underground storage tanks can
contaminate water, making it unsafe or unpleasant to drink, pose fire and
explosion hazards, and can have short and long-term effects on people's health.
About 625,000 underground storage tank systems exist nationwide, and more than
375,000 leaking tanks have been cleaned up over the last decade.
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National Emission
Standards for Hazardous Air Pollutants for Area Sources: Chemical Preparations
Industry
EPA is promulgating national emissions standards for
control of hazardous air pollutants (HAP) from the chemical preparations area
source category. These final emissions standards for new and existing sources
reflect EPA's final determination regarding the generally available control
technology or management practices (GACT) for the source category.
This final rule was effective on December 30, 2009.
The
final rule contains several revisions and clarifications to the proposed rule
in response to public comments. The reasons for the following
changes in detail in the summary of comments and responses (section V of this
preamble):
*
Revised the definition of chemical preparation to mean a target HAP-containing
product, or intermediate used in the manufacture of other products,
manufactured in a process operation described by the NAICS code 325998 if the
operation manufactures target HAP-containing products or intermediates other
than indelible ink, India ink, writing ink, and stamp pad ink. Indelible ink,
India ink, writing ink, and stamp pad ink manufacturing operations are subject
to regulation under the paints and allied products area source rule (40 CFR
part 63, subpart CCCCCCC), not this rule.
*
Revised the emission standard for existing sources to include an alternative
standard of 0.03 grains per dry standard cubic foot (gr/dscf) particulate
matter (PM) concentration at the outlet of the control device as an alternative
to routing process vent streams to a control device with a 95 percent PM
reduction efficiency.
*
Added standards for new sources that require either routing process vent
streams to a control device with a 98 percent PM efficiency or meeting the 0.03
gr/dscf alternative standard mentioned above.
*
Revised the standards to include a mechanism that allows sources (which in
these standards means the collection of emission points from chemical
preparations operations) to demonstrate and certify that the process vent
streams in the chemical preparation operations at the facility will not exceed
PM concentrations of 0.03 gr/dscf. This revision is intended to significantly
reduce monitoring, recordkeeping and reporting requirements for sources that
have, or can establish, very small process emissions.
*
Revised the monitoring requirements to provide options for the use of bag leak
detection systems, audible parameter monitor alarm systems, or a continuous
parameter monitoring system (CPMS). We also removed the use of a continuous
emissions monitoring systems (CEMS) as an alternative to a CPMS, since we are unaware
of any existing chemical preparations area sources currently using CEMS to
monitor PM emissions, and do not expect any sources to operate a CEMS system to
monitor compliance with the final standards (see discussion in section
V.E.).
*
Clarified the averaging requirements for sources using a CPMS so that the
average is calculated on the basis of either a 24-hour rolling period or a
batch period (i.e., the period that equipment is processing a batch of
target HAP-containing materials), whichever is less.
*
Revised the reporting requirements to require only annual reporting if no
deviations occur, but semiannual reporting if a deviation occurred within the
reporting period.
*
Modified the inspection requirements for vent collection system ductwork that is
difficult or dangerous to access.
*
Revised the definition of "responsible official" to make it easier
for sources to identify the appropriate person at a chemical preparations
facility.
*
Clarified the definition of "chemical preparation" to specify that it
applies to target HAP-containing products or intermediates.
*
Revised the definition of "target HAP-containing" to clarify separate
minimum concentration levels for trivalent and hexavalent chromium compounds.
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EPA extending comment period for Solvent-Contaminated Industrial Wipes, 40 CFR Part 261
EPA will accept public comments on the Notice of Data Availability (NODA) published October 27, 2009 (74 FR 55163), until February 26, 2010 (74 FR 66259)
SUPPLEMENTARY INFORMATION: The subject of this notice is to extend the time to comment on a revised risk analysis for solvent contaminated wipes. The revised risk analysis was developed in support of a rule proposed on November 20, 2003 (68 FR 65586).
On November 20, 2003, EPA proposed to: (1) Conditionally exclude from the definition of solid waste industrial wipes contaminated with solvent and sent to laundries or dry cleaners for cleaning and reuse and (2) conditionally exclude from the definition of hazardous waste industrial wipes contaminated with solvent and sent to disposal.
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