It’s Warming Up, Time to Review the Outdoor Heat Exposure Rules!

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Washington State Department of Labor & Industries’ (L&I) permanent rules for Worker Outdoor Heat Exposures went into effect July 17, 2023. With predicted warmer and drier seasons ahead, make sure you are protecting your employees in accordance with the standards.

The year-round standards apply when the action levels outlined in Table 1 – 52 degrees Fahrenheit for Non-Breathable clothing and 80 degrees Fahrenheit for all other clothing – are exceeded. Employers and employees should educate themselves on the triggering events and what actions must be taken to ensure worker safety. Some key aspects to consider include:

• Definitions
• Response to heat induced illnesses
• Information and Training program requirements
• Shade requirements
• Acclimatization guidelines

For more information, check out the Be Heat Smart (wa.gov) for access to the standards and resources such as posters, videos, and training materials.

* The Federal rulemaking for Heat Illness Prevention in Indoor and Outdoor work settings is currently in the Pre-rule stage of development.

April HAZWOPER Challenge

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Thank you for taking part in the Spring Environmental Monthly HAZWOPER challenge. By submitting correct answers to all 5 questions below on your initial attempt, you will be entered into our monthly drawing. This is an open book challenge. Please don’t hesitate to contact us if you have any questions.

Complete the form below to see results

2024 NEW OSHA 300A Posting and Reporting Requirements

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Hello 2024!  Did you know there are new requirements for companies to electronically submit workplace injury and illness data to OSHA?  There is and it’s also time to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses in your workplace.  Under the new rule, the following establishments have to submit electronically:

• Designated industries that had a peak employment of 100 or more employees during the previous calendar year that are listed in Appendix B to Subpart E of 29 CFR Part 1904.

• Establishments with 20 to 249 employees in certain industries listed in Appendix A to subpart E of 29 CFR Part 1904.

• Establishments with 250+ employees in industries that must routinely keep records.

If employers in State Plan states (e.g. Washington) have questions about their obligation to submit injury and illness information, please contact your State Plan office.

Your workplace Annual Summary must be posted from February 1st to April 30th. Electronic reporting is also due by March 2nd.

Click here for the PDF versions of the OSHA 300 forms series or here for an updated fact sheet on OSHA 300 reporting.

EPA to Modify Universal Waste Rule

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EPA announced in October 2023 that it intends to modify the Universal Waste regulations for waste lithium-ion batteries and solar panels. The proposal is an effort to support renewable energy by improving recycling and waste management.

Under the new rule, lithium-ion batteries would be separated from the “Universal Waste – Batteries” category to reduce the potential for fires. The new universal waste requirement for lithium-ion batteries would define improved storage and waste management methods.

Photovoltaic solar panels are not currently listed as a Universal Waste at the federal level but have been addressed or considered at the state level in places including, California, Hawaii, New York and North Carolina. EPA proposes to provide a clear, practical system for handling discarded solar panels.

Additional details on EPA’s Long Term Action can be found here. The Notice of Proposed Rulemaking (NPRM) is projected for June 2025. Stay tuned for further developments.

Permanent Wildfire Smoke Rule Coming Online!

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Washington State Department of Labor & Industries (L&I) has announced the new WAC 296-820 for Wildfire Smoke will be effective January 15, 2024 for all Washington employers. Washington has been operating under temporary emergency rules since 2021. The new regulation will apply year-round to aid employers in providing a safe work environment for their employees during wildfire smoke conditions.

Areas of Washington State have been devastated by wildfires and wildfire smoke from surrounding areas which have created hazardous working conditions. In the new guidance, employers and employees will find new guidance for worker protections based upon the Air Quality Index (AQI) which is available at Washington Ecology’s “Air Quality WA” or EPA’s “AirNow”, among others. The PM 2.5 AQI will trigger implementation of plans, training, and Personnel Protective Equipment (PPE).

For more information, check out the L&I Wildfire Smoke resource page for access to the new rule, plan templates, and training materials.

EPA’s Releases National Enforcement and Compliance Initiatives for Fiscal Years 24-27.

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EPA announced its selection of six priority areas as the National Enforcement and Compliance Initiatives (NECI).  The FY 2024-2027 NECIs are:

  • Mitigating Climate Change (new)
  • Addressing Exposure to PFAS (new)
  • Protecting Communities from Coal Ash Contamination (new)
  • Reducing Air Toxics in Overburdened Communities (modified)
  • Increasing Compliance with Drinking Water Standards (continued)
  • Chemical Accident Risk Reduction (continued)

Check out https://www.epa.gov/enforcement/national-enforcement-and-compliance-initiatives for more information on each of these initiatives.

Managing “Universal Waste” in Washington State

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Hazardous Waste is dangerous and must be managed as such, but generators can manage three types of waste under the “Universal Waste” regulations – Batteries, Mercury-Containing Equipment, and Lamps.

These wastes can be accumulated in larger quantities and for a longer period of time than regular hazardous waste. Provided that these waste streams are placed in containers that are structurally sound and prevent escape of toxic materials to the environment, and that the containers are labeled as “Used”, “Waste”, or “Universal Waste”, Universal wastes can be accumulated up to 1 year before being transported offsite. Universal waste is also exempt from counting towards your hazardous waste generator classification, can be excluded from annual hazardous waste reporting, and does not require a hazardous waste manifest for shipping (unless shipped with hazardous waste).

Washington State Generators can find the Universal Waste regulations in WAC 173-303-573 [effective 10/31/2020] and additional guidance on Ecology’s website here.

Note: For generators in other states, the federal Universal Waste regulations and guidance are available here.