Matt set a pretty high bar last week, summarizing his thoughts for what could be a tumultuous 2015 on the labor and employment front.  Now, it’s my turn to provide some thoughts for 2015 the EHS front.  I’m not sure I’d call all of these predictions, since we know that they’re out there – more like “stuff to watch out for.”

1. New OSHA reporting requirements take effect. As we discussed back in September, OSHA has updated its reporting and recordkeeping requirements. The changes became effective January 2, 2014.    It will behoove manufacturers to make sure they know the new rules, which can be found here.  Any inspections in 2015 will focus on this.

2. OSHA and Temporary Workers.  OSHA continues to emphasize the need for training for temporary workers, citing injury rates that are higher than for permanent employees. We discussed this issue in August.  Again, if you have temporary employees, expect inspections in 2015 to focus on them and their training.

3. Region 1 – Local Emphasis Program focused on Noise.  Falling into the “in case you missed it” category, OSHA’s Region I (ME, VT, NH, MA, RI, and CT) announced in October that it was renewing the local emphasis focused on noise.  Targeted inspections will focus on a variety of manufacturing sectors. Check your program, monitoring, audiometric testing and your training.

4.  Changes to hazardous waste rules.  EPA published final revisions to the “definition of solid waste” regulations in December 2014.  The definition of solid waste is used to determine whether a material is a “hazardous waste.”  These changes focus on the recycling of “hazardous secondary materials.” I’ll write more about this in my next post, but the key takeaway here is that recyclers of hazardous materials will now be required to have permits. It also changes requirements for generators.  As with all changes to federal hazardous waste regulations, these changes will not become effective in states that have been delegated the hazardous waste program (all New England states have) until those states adopt the changes as well.

5.  Climate Change and Adaptation.  In October 2014, EPA and the regions issued “Climate Adaptation Plans.”  Here are links to the Region 1 and Region 2 plans, as well as link to EPA’s Climate Change Adaptation page, which has program specific plans, as well.  The takeaway for manufacturers is that EPA recognizes that climate adaptation will affect both planning and enforcement – for example, previously unimpaired waters may become impaired, affecting the effluent limits in a permit.