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Newsletter
Volume 154
August 1, 2016
2016 National Safety School - Register Today!
The 38th annual National, Agronomic, Environmental, Health & Safety School will be held on August 23-24, 2016 in Bloomington, Illinois at the Asmark Institute Agricenter. An outstanding lineup of national speakers has been confirmed to present, and this is one you won't want to miss! This year's keynote address will be given by the U.S. Chemical Safety & Hazard Investigation Board Chairperson, Vanessa Sutherland. Other speakers include Jeffrey Wanko, the Directorate of Enforcement Program with U.S. OSHA, who will cover RAGAGEP and Nancy Fitz with the U.S. EPA's Office of Pesticide Programs will discuss the WPS update and proposed changes for certified applicators. Other favorites speaking again this year will be Brian Bothast, OSHA Compliance Specialist, Tom Bray with J.J. Keller and Associates, and Dr. Fred Whitford, who will present sprayer cleanout techniques. A special Airbrakes 101: Components & Adjustments demonstration segment will be given by Mike Templeton, former Indiana State Trooper and surface transportation consultant. Please visit the website at naehss.org for further information and to register.
PSM Lawsuit Update: Yes or No Expected Soon
Did OSHA overstep their authority on July 22, 2015 when they rescinded the letter of interpretation that originally granted the "retail exemption" to our industry? ARA and TFI have petitioned the court asking simply for a "yes" or "no" to this question. We join the many who are anxiously awaiting to hear back from the court with their decision any day now. Stay tuned! We will pass along the news as soon as possible.
Backup Efforts to Restore the Retail Exemption Continue
Senators Heidi Heitkamp (D-ND) and Deb Fischer (R-NE) recently introduced a bill to force OSHA to scrap a July 2015 policy memo that ended the longstanding exemption of small retail stores from process safety management standards on the storage of anhydrous ammonia and require the agency to go through formal rule-making to re-interpret the exemption. Absent the impending opinion from the court, this is one of several actions designed to provide ag retailers relief.
Training Certificates Now Available in Spanish
Providing the proper training and qualifications for each new employee at the time they enter the workplace is essential today, so we have translated the video-based training test questions to better serve your Spanishspeaking employees. New questions for each of the training topics currently included in new hire and special order training kits have been translated and are now available in Spanish.
It's Time to Register With ResponsibleAg
More than 2,000 facilities have registered with the ResponsibleAg Certification Program, with 255 facilities already receiving their certification. We encourage you to register your facilities today and support the program. The explosion of the West, Texas retail facility in April 2013 marked a low point in the public and regulatory agencies perception of the fertilizer industry. The industry was criticized for not having an organized effort to assist retail dealers in understanding and complying with existing federal regulations. Help is in place now. For more information and to register, go to: www.responsibleag.org
Become a ResponsibleAg Auditor or Attend to Learn More....
We are seeing several organizations credential one or more of their employees to perform their own audits. Many others are signing up for the training to become contract auditors or to learn firsthand about ResponsibleAg - they want to see how it works - so they will be ready for their audit. More than 140 people have already participated in the training, with more than 88 choosing to become credentialed by ResponsibleAg. To become a ResponsibleAg auditor, the first step is to attend the training. Registration is open and two classes are offered per year. The September 13-16th class is almost full. The next class will be in February 2017. Click here to register.
Chemical Sector Security Summit Held in Alexandria, Virginia
The 10th Anniversary Chemical Sector Security Summit in Alexandria, Virginia was held on July 19-21st. High level officials at DHS spoke, including Deputy Secretary Alejandro Mayorkas and Under Secretary Suzanne Spaulding. Director of the Infrastructure Security and Compliance Division, David Wulf, spoke at length on the past, present and future of the Chemical Facilities Anti-Terrorisim Standards program, including a study that will commence in August on chemical precursors used with improvised explosive devices. Director Wulf said the study will also inform on future changes to the Ammonium Nitrate Security Program and would take approximately a year to complete. Billy Pirkle, Senior Director EHS for Crop Production Services and Bill Qualls, Executive Director of ResponsibleAg also presented on behalf of ResponsibleAg's role of safety and security in the ag industry.
New IL Anhydrous Ammonia Rules & Compliance Guide
The Illinois Department of Agriculture has finalized changes to the Illinois Anhydrous Ammonia rules, known as Part 215. The rules were effective on July 1, 2016, but there are many provisions in the rules that have a later effective date of December 31, 2020 to allow time for our industry to implement upgrades and facility changes in order to fully comply. To assist their members in understanding the major changes in these rules, the Illinois Fertilizer and Chemical Association (IFCA) has prepared a compliance guide that features various sections of the rules highlighted with photos and the corresponding compliance date pertaining to the different sections of the rule. A copy of the final rule, as well as the IFCA NH3 Compliance Guide, is available on the IFCA website at www.ifca.com.
DHS Temporarily Suspends Top-Screen, SVA Requirements
DHS issued a notice in the Federal Register since our last newsletter informing the public of their implementation of the improved tiering methodology for chemical facilities of interest regulated under CFATS. The notice temporarily suspends the requirement to submit Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased roll out of the new Chemical Security Assessment Tool (CSAT) 2.0 surveys.
CSAT 2.0 will consist of a more streamline CSAT Top-Screen, SVA and a Site Security Plan, that will allow the collection of the data necessary to process facilities through the new methodology. Chemical facilities will be notified to submit their Top-Screen using CSAT 2.0 beginning in September.
DHS is taking a multi-step approach to this implementation:
  1. DHS is temporarily suspending the Top-Screen and SVA submissions requirements as outlined in the notice.
  2. Replacement of the current CSAT surveys with the new streamlined version of the surveys.
  3. Reinstatement of the Top-Screen and SVA submission requirement.
DHS will individually notify facilities of the requirement to resubmit a Top-Screen using the new tool in a phased manner, however, facilities may choose to proactively resubmit a Top-Screen once the new tool is available and prior to the individual notification.
DOT Delays Implementation of Unified Registration System
Last week DOT said it is extending implementation of the final piece of the Unified Registration System (URS) to January 14, 2017 with a full compliance date of April 14th. The URS requires new carriers to provide census and data information prior to gaining operating authority and existing carriers to update the information every two years.
ARA Submits Comments on FMCSA Sleep Apnea Rulemaking
ARA recently submitted comments to DOT on the impacts of screening, evaluating and treating commercial motor vehicle (CMV) drivers for obstructive sleep apnea. For CMV drivers who are detected to have a respiratory dysfunction, such as obstructive sleep apnea, DOT currently recommends that medical examiners refer them for further evaluation and therapy.
In January 2015, DOT issued a bulletin to remind healthcare professionals on the agency's National Registry of Certified Medical Examiners of the current physical qualifications standard and advisory criteria concerning the respiratory system, specifically how the requirements apply to drivers that may have obstructive sleep apnea. Click here for a copy of the FMCSA bulletin.
ARA has gathered from its members that they are concerned about inconsistent sleep apnea screening procedures being imposed by certified medical examiners and the costs involved with sleep apnea tests. ARA members have been experiencing issues when their drivers go to renew their DOT medical cards. On many occasions the certified medical examiners are requiring the drivers to go for a sleep apnea evaluation due to their neck size, even though they have not experienced any previous health or sleep problems. Click here to review ARA's comments. Our thanks go to ARA for their efforts on this issue as DOT's actions have caused great confusion allowing, practically encouraging, physicians to overreact.
Court Upholds EPA Decision Not to Require Labeling of Pesticide Inert Ingredients
In the latest development in a decades-long dispute, a federal court in San Francisco, California upheld EPA's decision not to pursue rulemaking that would require pesticide labels to disclose many inert ingredients. Plaintiffs first requested this rulemaking in 2006 and have since filed three related lawsuits. Last week, the court recognized that the law does not require inert ingredients to be disclosed on the pesticide label and that EPA properly denied the request for rulemaking. Plaintiffs may appeal the decision to the Ninth Circuit. Our thanks go to CropLife America on their work on this issue.
NHTSA Releases Agricultural Equipment Lighting Requirement
The National Highway Traffic Safety Administration (NHTSA) recently issued a final rule that will require certain agricultural equipment to come fitted with lighting and markings for increased daytime and nighttime visibility. Previously, the safety agency did not consider agricultural equipment under its jurisdiction; however, under a 2012 law, the "Moving Ahead for Progress in the 21st Century Act" (MAP-21), NHTSA was forced to create the new safety standard. Under the rule, "tractors, self-propelled and non-self-propelled" agriculture equipment must be built with lighting and markings that meet the American Society of Agriculture and Biological Engineers (ASABE) standard 279.14. NHTSA is also defining the machinery covered by the regulation using the ASABE standard 390.4. New agricultural equipment must meet the requirement by June 22, 2017; however, no retrofits of existing equipment are being required under the final rule.
Tier II Updates Coming in 2018: Hazard Categories Will be Revised
EPA recently announced it is amending its hazardous chemical inventory reporting regulations due to the changes in the OSHA Hazard Communication Standard. Changes are required as a result of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which went into effect in 2012.
Chemical manufacturers and importers are required to evaluate their chemicals according to the new criteria adopted by OSHA to ensure that they are classified and labeled appropriately. The changes affect the reporting requirements under sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). As a result, EPA was required to amend 40 CFR 370 by revising the existing hazard categories for hazardous chemical inventory form reporting (known as Tier II reporting) and for hazardous chemical list reporting. EPA is also making a few minor corrections in the hazardous chemical reporting regulations.
The final rule is effective June 13, 2016, and has a compliance date of January 1, 2018. Facilities are required to comply with reporting the new physical and health hazards on their Tier II inventory form for reporting year 2017 by March 1, 2018.
Heads Up! Annual Brake Inspection Blitz Set for September
Inspectors will be keying in on brake safety again this September when the Commercial Vehicle Safety Alliance's (CVSA) Brake Safety Week takes place September 11-17th. Across North America, law enforcement agencies will conduct inspections on commercial vehicles to look for out-of-adjustment brakes, and brake system and anti-lock braking system violations during the week. Specifically, CVSA says inspectors will be looking for "loose or missing parts, air or hydraulic fluid leaks, worn linings, pads, drums or rotors, and other faulty brake system components." Inspectors will also be checking ABS malfunction indicator lights to make sure they're in working order, CVSA says. Defective or out-of-adjustment brakes will result in the vehicle being placed out-of-service. In 2015, 12.3% of trucks inspected were placed out-of-service during Brake Safety Week.
Federal Wage and Labor Law Poster Updates
UTAH
Workers' Compensation (Effective date: Currently) - The state seal was removed, a reference to the Workers' Compensation law was added and a new web site link for information was added. These changes would normally be considered non-substantive, however the agency informed us that employers "should" have the most current version posted though they could not confirm whether or not a penalty would be levied for not doing so. Based on this, we are recommending that our clients update their posters to stay on the safe side. Projected availability: The week of August 1st. Click here to order.
VIRGINIA
Safety and Health (Effective date July 1, 2016) - The new notice, based on recently enacted legislation, notes the requirement to report all "injuries or illnesses that result in an in-patient hospitalization, amputation or loss of an eye" within 24 hours. Previously, these were listed as requiring reporting within 8 hours, whereas now only fatalities must be reported within 8 hours. Projected availability: The week of August 1st. This is a substantive change and an updated Virginia poster is required. Click here to order.
GEORGIA
Workers' Compensation Bill of Rights (Effective date July 1, 2016) - Previously, weekly benefits were capped at $550 and at $367 if the case leaves you capable of performing work with restrictions. Now the caps are $575 and $383 respectively. The maximum benefits for a widowed spouse with no children is increased to $230,000 from $220,000. Additionally, the new notice stipulates that all injuries occurring prior to June 30, 2013 are entitled to lifetime benefits, while those occurring after that date are capped at 400 weeks with the possibility of some catastrophic injuries still being entitled to lifetime benefits. Projected availability: Currently. This is a substantive change and an updated Georgia poster is required. Click here to order.
2016 Asmark Institute, Inc. This information is believed to be reliable by the Asmark Institute, however, because of constantly changing government regulations, interpretations and applicability or the possibility of human, mechanical or computer error, the Asmark Institute does not guarantee the information as suitable for any particular purpose.
2016 National Safety School - Register Today!
The 38th annual National, Agronomic, Environmental, Health & Safety School will be held on August 23-24, 2016 in Bloomington, Illinois at the Asmark Institute Agricenter. An outstanding lineup of national speakers has been confirmed to present, and this is one you won't want to miss! This year's keynote address will be given by the U.S. Chemical Safety & Hazard Investigation Board Chairperson, Vanessa Sutherland. Other speakers include Jeffrey Wanko, the Directorate of Enforcement Program with U.S. OSHA, who will cover RAGAGEP and Nancy Fitz with the U.S. EPA's Office of Pesticide Programs will discuss the WPS update and proposed changes for certified applicators. Other favorites speaking again this year will be Brian Bothast, OSHA Compliance Specialist, Tom Bray with J.J. Keller and Associates, and Dr. Fred Whitford, who will present sprayer cleanout techniques. A special Airbrakes 101: Components & Adjustments demonstration segment will be given by Mike Templeton, former Indiana State Trooper and surface transportation consultant. Please visit the website at naehss.org for further information and to register.
PSM Lawsuit Update: Yes or No Expected Soon
Did OSHA overstep their authority on July 22, 2015 when they rescinded the letter of interpretation that originally granted the "retail exemption" to our industry? ARA and TFI have petitioned the court asking simply for a "yes" or "no" to this question. We join the many who are anxiously awaiting to hear back from the court with their decision any day now. Stay tuned! We will pass along the news as soon as possible.
Backup Efforts to Restore the Retail Exemption Continue
Senators Heidi Heitkamp (D-ND) and Deb Fischer (R-NE) recently introduced a bill to force OSHA to scrap a July 2015 policy memo that ended the longstanding exemption of small retail stores from process safety management standards on the storage of anhydrous ammonia and require the agency to go through formal rule-making to re-interpret the exemption. Absent the impending opinion from the court, this is one of several actions designed to provide ag retailers relief.
Training Certificates Now Available in Spanish
Providing the proper training and qualifications for each new employee at the time they enter the workplace is essential today, so we have translated the video-based training test questions to better serve your Spanishspeaking employees. New questions for each of the training topics currently included in new hire and special order training kits have been translated and are now available in Spanish.
It's Time to Register With ResponsibleAg
More than 2,000 facilities have registered with the ResponsibleAg Certification Program, with 255 facilities already receiving their certification. We encourage you to register your facilities today and support the program. The explosion of the West, Texas retail facility in April 2013 marked a low point in the public and regulatory agencies perception of the fertilizer industry. The industry was criticized for not having an organized effort to assist retail dealers in understanding and complying with existing federal regulations. Help is in place now. For more information and to register, go to: www.responsibleag.org
Become a ResponsibleAg Auditor or Attend to Learn More....
We are seeing several organizations credential one or more of their employees to perform their own audits. Many others are signing up for the training to become contract auditors or to learn firsthand about ResponsibleAg - they want to see how it works - so they will be ready for their audit. More than 140 people have already participated in the training, with more than 88 choosing to become credentialed by ResponsibleAg. To become a ResponsibleAg auditor, the first step is to attend the training. Registration is open and two classes are offered per year. The September 13-16th class is almost full. The next class will be in February 2017. Click here to register.
Chemical Sector Security Summit Held in Alexandria, Virginia
The 10th Anniversary Chemical Sector Security Summit in Alexandria, Virginia was held on July 19-21st. High level officials at DHS spoke, including Deputy Secretary Alejandro Mayorkas and Under Secretary Suzanne Spaulding. Director of the Infrastructure Security and Compliance Division, David Wulf, spoke at length on the past, present and future of the Chemical Facilities Anti-Terrorisim Standards program, including a study that will commence in August on chemical precursors used with improvised explosive devices. Director Wulf said the study will also inform on future changes to the Ammonium Nitrate Security Program and would take approximately a year to complete. Billy Pirkle, Senior Director EHS for Crop Production Services and Bill Qualls, Executive Director of ResponsibleAg also presented on behalf of ResponsibleAg's role of safety and security in the ag industry.
New IL Anhydrous Ammonia Rules & Compliance Guide
The Illinois Department of Agriculture has finalized changes to the Illinois Anhydrous Ammonia rules, known as Part 215. The rules were effective on July 1, 2016, but there are many provisions in the rules that have a later effective date of December 31, 2020 to allow time for our industry to implement upgrades and facility changes in order to fully comply. To assist their members in understanding the major changes in these rules, the Illinois Fertilizer and Chemical Association (IFCA) has prepared a compliance guide that features various sections of the rules highlighted with photos and the corresponding compliance date pertaining to the different sections of the rule. A copy of the final rule, as well as the IFCA NH3 Compliance Guide, is available on the IFCA website at www.ifca.com.
DHS Temporarily Suspends Top-Screen, SVA Requirements
DHS issued a notice in the Federal Register since our last newsletter informing the public of their implementation of the improved tiering methodology for chemical facilities of interest regulated under CFATS. The notice temporarily suspends the requirement to submit Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased roll out of the new Chemical Security Assessment Tool (CSAT) 2.0 surveys.
CSAT 2.0 will consist of a more streamline CSAT Top-Screen, SVA and a Site Security Plan, that will allow the collection of the data necessary to process facilities through the new methodology. Chemical facilities will be notified to submit their Top-Screen using CSAT 2.0 beginning in September.
DHS is taking a multi-step approach to this implementation:
  1. DHS is temporarily suspending the Top-Screen and SVA submissions requirements as outlined in the notice.
  2. Replacement of the current CSAT surveys with the new streamlined version of the surveys.
  3. Reinstatement of the Top-Screen and SVA submission requirement.
DHS will individually notify facilities of the requirement to resubmit a Top-Screen using the new tool in a phased manner, however, facilities may choose to proactively resubmit a Top-Screen once the new tool is available and prior to the individual notification.
DOT Delays Implementation of Unified Registration System
Last week DOT said it is extending implementation of the final piece of the Unified Registration System (URS) to January 14, 2017 with a full compliance date of April 14th. The URS requires new carriers to provide census and data information prior to gaining operating authority and existing carriers to update the information every two years.
ARA Submits Comments on FMCSA Sleep Apnea Rulemaking
ARA recently submitted comments to DOT on the impacts of screening, evaluating and treating commercial motor vehicle (CMV) drivers for obstructive sleep apnea. For CMV drivers who are detected to have a respiratory dysfunction, such as obstructive sleep apnea, DOT currently recommends that medical examiners refer them for further evaluation and therapy.
In January 2015, DOT issued a bulletin to remind healthcare professionals on the agency's National Registry of Certified Medical Examiners of the current physical qualifications standard and advisory criteria concerning the respiratory system, specifically how the requirements apply to drivers that may have obstructive sleep apnea. Click here for a copy of the FMCSA bulletin.
ARA has gathered from its members that they are concerned about inconsistent sleep apnea screening procedures being imposed by certified medical examiners and the costs involved with sleep apnea tests. ARA members have been experiencing issues when their drivers go to renew their DOT medical cards. On many occasions the certified medical examiners are requiring the drivers to go for a sleep apnea evaluation due to their neck size, even though they have not experienced any previous health or sleep problems. Click here to review ARA's comments. Our thanks go to ARA for their efforts on this issue as DOT's actions have caused great confusion allowing, practically encouraging, physicians to overreact.
Court Upholds EPA Decision Not to Require Labeling of Pesticide Inert Ingredients
In the latest development in a decades-long dispute, a federal court in San Francisco, California upheld EPA's decision not to pursue rulemaking that would require pesticide labels to disclose many inert ingredients. Plaintiffs first requested this rulemaking in 2006 and have since filed three related lawsuits. Last week, the court recognized that the law does not require inert ingredients to be disclosed on the pesticide label and that EPA properly denied the request for rulemaking. Plaintiffs may appeal the decision to the Ninth Circuit. Our thanks go to CropLife America on their work on this issue.
NHTSA Releases Agricultural Equipment Lighting Requirement
The National Highway Traffic Safety Administration (NHTSA) recently issued a final rule that will require certain agricultural equipment to come fitted with lighting and markings for increased daytime and nighttime visibility. Previously, the safety agency did not consider agricultural equipment under its jurisdiction; however, under a 2012 law, the "Moving Ahead for Progress in the 21st Century Act" (MAP-21), NHTSA was forced to create the new safety standard. Under the rule, "tractors, self-propelled and non-self-propelled" agriculture equipment must be built with lighting and markings that meet the American Society of Agriculture and Biological Engineers (ASABE) standard 279.14. NHTSA is also defining the machinery covered by the regulation using the ASABE standard 390.4. New agricultural equipment must meet the requirement by June 22, 2017; however, no retrofits of existing equipment are being required under the final rule.
Tier II Updates Coming in 2018: Hazard Categories Will be Revised
EPA recently announced it is amending its hazardous chemical inventory reporting regulations due to the changes in the OSHA Hazard Communication Standard. Changes are required as a result of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which went into effect in 2012.
Chemical manufacturers and importers are required to evaluate their chemicals according to the new criteria adopted by OSHA to ensure that they are classified and labeled appropriately. The changes affect the reporting requirements under sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). As a result, EPA was required to amend 40 CFR 370 by revising the existing hazard categories for hazardous chemical inventory form reporting (known as Tier II reporting) and for hazardous chemical list reporting. EPA is also making a few minor corrections in the hazardous chemical reporting regulations.
The final rule is effective June 13, 2016, and has a compliance date of January 1, 2018. Facilities are required to comply with reporting the new physical and health hazards on their Tier II inventory form for reporting year 2017 by March 1, 2018.
Heads Up! Annual Brake Inspection Blitz Set for September
Inspectors will be keying in on brake safety again this September when the Commercial Vehicle Safety Alliance's (CVSA) Brake Safety Week takes place September 11-17th. Across North America, law enforcement agencies will conduct inspections on commercial vehicles to look for out-of-adjustment brakes, and brake system and anti-lock braking system violations during the week. Specifically, CVSA says inspectors will be looking for "loose or missing parts, air or hydraulic fluid leaks, worn linings, pads, drums or rotors, and other faulty brake system components." Inspectors will also be checking ABS malfunction indicator lights to make sure they're in working order, CVSA says. Defective or out-of-adjustment brakes will result in the vehicle being placed out-of-service. In 2015, 12.3% of trucks inspected were placed out-of-service during Brake Safety Week.
Federal Wage and Labor Law Poster Updates
UTAH
Workers' Compensation (Effective date: Currently) - The state seal was removed, a reference to the Workers' Compensation law was added and a new web site link for information was added. These changes would normally be considered non-substantive, however the agency informed us that employers "should" have the most current version posted though they could not confirm whether or not a penalty would be levied for not doing so. Based on this, we are recommending that our clients update their posters to stay on the safe side. Projected availability: The week of August 1st. Click here to order.
VIRGINIA
Safety and Health (Effective date July 1, 2016) - The new notice, based on recently enacted legislation, notes the requirement to report all "injuries or illnesses that result in an in-patient hospitalization, amputation or loss of an eye" within 24 hours. Previously, these were listed as requiring reporting within 8 hours, whereas now only fatalities must be reported within 8 hours. Projected availability: The week of August 1st. This is a substantive change and an updated Virginia poster is required. Click here to order.
GEORGIA
Workers' Compensation Bill of Rights (Effective date July 1, 2016) - Previously, weekly benefits were capped at $550 and at $367 if the case leaves you capable of performing work with restrictions. Now the caps are $575 and $383 respectively. The maximum benefits for a widowed spouse with no children is increased to $230,000 from $220,000. Additionally, the new notice stipulates that all injuries occurring prior to June 30, 2013 are entitled to lifetime benefits, while those occurring after that date are capped at 400 weeks with the possibility of some catastrophic injuries still being entitled to lifetime benefits. Projected availability: Currently. This is a substantive change and an updated Georgia poster is required. Click here to order.
2016 Asmark Institute, Inc. This information is believed to be reliable by the Asmark Institute, however, because of constantly changing government regulations, interpretations and applicability or the possibility of human, mechanical or computer error, the Asmark Institute does not guarantee the information as suitable for any particular purpose.