Leader:
Keeping You Informed
This
is the inaugural issue of Leaderlink E-News™. Through this
newsletter, the professionals at The Leader Group will periodically
keep you abreast of new information, developing issues and
governmental programs related to the environmental, safety, industrial
hygiene and engineering fields. Also, we will keep you posted on
developments within Leader. In this issue you will find articles and
information on Mold, CERCLA cost recovery and other OSHA/EPA news.
Although this newsletter has been designed to be brief, you can
always obtain further information from anyone at Leader.
We
know that if you have the current information and updates specific to
your needs, you can make the informed decisions in your daily
responsibilities. There
are many sources of information out there in print and on the web;
however, you have to find them and extract the information from them.
This effort takes your valuable time and money. We hope that
Leaderlink E-News will make your job a little easier.
For
additional information visit our website at www.Leaderlink.com
The
affects of mold contamination in buildings have become an issue of
concern for EH&S professionals over the last several years.
Amazingly, there are no standards or regulations by USEPA or OSHA to
deal specifically with mold. Regardless of the scientific data and
opinions available, many will face mold problems because of the
concerns of employees and apartment dwellers and the burgeoning
litigious environment. Leader’s advice is: deal with the problem
immediately and follow a sound investigative methodology.
Mold
can grow on virtually any organic substance, as long as moisture and
oxygen are present. Molds can grow on foods, carpet, wood, paper, and
insulation. When excessive moisture accumulates in buildings or on
building materials, mold growth will almost always occur, particularly
if the moisture problem remains undiscovered or unaddressed. Molds
gradually destroy the materials they grow on. Molds can produce
allergens that can trigger allergic reactions or asthma attacks in
people sensitive to mold. Some molds produce toxic metabolites called
mycotoxins that can also adversely affect human health. Mycotoxins are
produced by molds during digestion. Generally, mycotoxins are
nonvolatile and inhalation exposure usually occurs only after
disturbance of a contaminated source. Symptoms of exposure to
mycotoxins include cold and flu-like symptoms, headache, nosebleeds,
dermatitis, and immune suppression. Potential health concerns are an
important reason to prevent mold growth and remediate any existing
indoor mold growth.
Leader
has conducted many mold investigations, assessments and cleanups for
residential and commercial properties. We work with insurance
companies, private businesses, property management companies, and
remediation contractors to assess potential mold contamination and
prepare protocols for safe removal and/or cleanup. Please contact Mary
Ellen Holvey, CIH in our Pittsford, NY office if you need further
information.
Did
you know that our capabilities include historical research and several
of our staff are accredited historical researchers with the National
Archives and Records Administration? We have conducted many hours of
research for corporate clients in CERCLA matters including our war
production cost recovery work. Historical research at a variety of
historical and agency repositories can be an invaluable tool for
determining response cost allocations at hazardous waste sites. We
also develop the information to tie the historical manufacturing data
to current contaminant issues in order to accurately allocate costs
among PRPs. In some cases, through exhaustive research, we are able to
identify and document the federal government as a PRP.
Due
Diligence & Phase I ESAs
For
any property transaction, the completion of a thorough Phase I
Environmental Site Assessment is highly recommended. Nowhere is this
truer than at gasoline station facilities.
It has been Leader's experience that some bypass the Phase I
ESA process at gasoline stations and jump right to the Phase II
investigation stage. This approach may actually result in
environmental liabilities at the Site not being identified and
addressed thoroughly prior to purchase. The same issues may apply to
manufacturing facilities with tanks. The new owner may be financially
responsible for environmental liabilities that were not identified and
addressed prior to purchase.
The
research conducted as part of the Phase I ESA process may identify
additional historical land uses at the Site, which may have negatively
impacted the Site. Examples
of this can include: historical building records or Sanborn Fire
Insurance Maps that depict waste oil USTs or a dry well present on
Site; or a dry cleaner with a history of releases that operated on the
adjacent upgradient property.
The
Phase I process may identify if the gas station facility ever provided
other automotive services, an approximate window of time these
activities occurred, and how that facility handled waste materials
such as used oil or solvents from the automotive repairs.
Additionally, some older gas stations also sold kerosene. The
historical review may identify the former location of the kerosene
tanks since they typically were located away from gasoline tanks.
It
is imperative that comprehensive research be conducted as part of the
due diligence review on property transactions. The Phase I ESA process
sets forth the standard upon which the research is conducted. A
properly administered Phase I ESA will identify potential sources of
contamination at a property regardless of the property's size and
current use.
Contact
Leader before your next property transaction.
We have conducted thousands of Phase I ESAs and environmental
due diligence reviews nationwide and internationally.
OSHA
News
Here
are some of the latest developments from the Occupational Safety and
Health Administration.
OSHA
Exceeds Inspection Targets; Penalties for Serious Violations Rise
The
Occupational Safety and Health Administration exceeded its inspection
goals for fiscal year 2002 and increased both the numbers of serious
violations and the penalties assessed for them.
During
FY2002, OSHA inspected 37,493 workplaces in the United States.
The targeted number of inspections for the fiscal year was
36,400. The average
assessed penalty for serious violations rose from $930 in FY2001 to
$977 in FY2002. The larger fine amounts are indicative of an increase
in more serious violations being discovered during OSHA inspections.
It is reported that serious violations of worker Health &
Safety regulations accounted for 70% of all OSHA violations found.
The
most frequently cited OSHA standards are also in the most hazardous
industries and areas with the highest potential for serious illness,
injury or death: scaffolding,
hazard communications, fall protection, respiratory protection and
lockout/tagout.
Leader
can assist your company with maintaining its regulatory compliance.
Feel free to contact any of our offices for additional information or
to schedule a facility Environmental, Health & Safety Audit.
Proposed
Rule on Hexavalent Chromium
OSHA
announced recently that it plans to go forward with proposed
rulemaking on occupational exposure to hexavalent chromium.
"The health risks associated with occupational exposure to
hexavalent chromium are serious and demand serious attention,"
said OSHA Administrator John Henshaw. "We are committed to
developing a rule that ensures proper protection to safeguard workers
who deal with hexavalent chromium."
Hexavalent
chromium is most commonly used as a structural and anti-corrosive
element in the production of stainless steel, iron and steel and in
electroplating, welding and painting.
Exposures to the metal have been linked to lung cancer, other
respiratory problems and dermatoses.
OSHA's
current permissible exposure limit for hexavalent chromium compounds
is set at 100 micrograms per cubic meter as a ceiling concentration;
the standard for construction is 100 micrograms per cubic meter as an
8-hour time-weighted average.
Exit
Routes Standard Revised
The
revised Exit Routes, Emergency Action Plans and Fire Prevention Plans
Standard became effective on December 7, 2002. The requirements for
exit routes have been rewritten in simple, straightforward, and easy
to understand terms. An
example of the simplification includes the use of the term Exit
Routes that replaces the previous term of Means
of Egress. The revised standard provides additional
compliance options for employers and building owners but does not
change the original regulatory obligations or the health and safety
protection provided by the original standard.
As
part of the development of the revised standard, OSHA evaluated the
National Fire Protection Associations' (“NFPA”) Life Safety Code
and determined that it provided comparable safety as that outlined in
the OSHA standard for exit routes. Therefore, employers and building
owners now can adopt the NFPA's Life Safety Code or the OSHA standard
for exit routes.
