On February 27, 2017, the Ministry of Agriculture, Forestry, Environment and Water Management for Austria opened a consultation period for a draft regulation amending four implementation ordinances implementing the Fluorinated Greenhouse Gas Act 2009. The Government has published supporting documents on its website for contributors to consider before submitting their recommendations. Interested individuals had to submit comments via e-mail by April 10, 2017.
 
Comments may discuss (1) the draft Ordinance on Qualification and Certification Measures in Connection with Localized Refrigeration and Air-Conditioning Systems and Heat Pumps; (2) the draft Ordinance on Qualification and Certification Measures in Connection with Fixed Fire Protection Systems and Fire Extinguishers; (3) the draft Ordinance on Qualification and Certification Measures Relating to High-voltage Switchgear; and (4) the draft Amendment on Qualification Measures Relating to Vehicle Air-conditioning Systems.

The Russian Government has amended the Federal Law “On Industrial Safety of Hazardous Production Facilities.” The State Duma adopted the amendment on February 8, 2017, and the Federation Council approved the law on February 15, 2017. The amendment augments sub-paragraph 1 of paragraph 5 of Annex 2 of the original law. Specifically, it adds an exception for filling stations equipment intended for refueling vehicles with natural gas. The Federal Law entered into force thirty days following the date of its official publication.

​On February 21, 2017, the Cabinet of Japan approved the Cabinet Order for the Partial Revision of the Order for Enforcement of the Act on the Rational Use of Energy. The Order of Enforcement stipulates the addition of showcases to list applicable top-runner equipment that is “particularly necessary to improve the rational use of energy” under Article 78 of the Act on the Rational Use of Energy. The Order also requires manufacturers and other entities of covered top-runner products to manufacture or import 100 or more showcase units in order to qualify. The top-runner program defines target criteria for energy-efficient performance of such equipment. The Energy Efficiency Division, Energy Conservation and Renewable Energy Department, and Agency for Natural Resources and Energy are in charge of the Order. Enforcement began on March 1, 2017.

The Ministry of the Presidency and for the Territorial Administrations for Spain has issued Royal Decree 115/2017, Regulating the Marketing and Handling of Fluorinated Gases and Equipment Based on Them, as well as the Certification of the Professionals Who Use Them and Laying Down the Technical Requirements for Installations that Develop Activities that Emit Fluorinated Gases. This Decree entered into force on February 19, 2017.  
 
The Decree lists specific requirements for what types of substances are covered, how to apply and obtain certification for competence of handling fluorinated gases and their corresponding safety equipment, and guidelines for preventing and dealing with accidents, among many other things. The purpose of regulating fluorinated gases is to control the contribution of their emissions to climate change, given their global warming potential. 

The Ministry of Environment of Ecuador (MAE), with support from the Global Environment Facility (GEF), through the United Nations Development Program (UNDP), has launched the National Program for the Proper Management of Chemicals During the Life Cycle. Members of the public and private sectors joined the Ministry to consider the key phases of implementing the program. The National Program will manage hazardous chemicals, including persistent organic pollutants and mercury, through concrete public policy and implementation projects.
 
Implementation of the National Program is anticipated to strengthen national institutional capacity and the regulatory framework for the sound management of chemicals using the life-cycle approach. The implementation program will train 706 people, eliminate 30 tons of obsolete pesticides containing persistent organic pollutants, and reduce the use of new POPs, among many other things. The National Program and its implementation signal Ecuador’s continued commitment to international agreements to protect human health and the environment.

Isosceles is proud to announce the availability of another new product line: Workplace Bullying Assessments and Checklists.

Workplace Bullying Assessments and Checklists provide general information on the current state of workplace bullying as a global health and safety risk, as well as regional and country specific legislation, trends, government and corporate practices and resources. An audit checklist of applicable legislation is provided at the end for self-assessment.

Learn more about our workplace bullying expert, Ellen Pinkos Cobb, here.

A free copy of our first assessment, for Serbia, is available below. If you would like a workplace bullying assessment and checklist for a particular country, please contact Brittany Palmer for a quote at [email protected].

Isosceles is proud to announce the availability of a new product line: Workplace Wellness Assessments.

Workplace Wellness Assessments provide an overview of workplace wellness and workplace wellness programs in the context of the global and regional environment, current trends, and the role of government. The focus then shifts to details on the current state of employees and workplace wellness in a particular country. This includes applicable legislation, government guidance, whitepapers, strategies, and plans, followed by corporate programs within the country, and wellness service providers. 

A free copy of our first assessment, for Malaysia, is available below. If you would like a workplace wellness assessment for a particular country, please contact Brittany Palmer for a quote at [email protected].

On February 2, 2017, the Ministry of Foreign Affairs and Cooperation of Spain issued amendments to Annexes A and C of the Stockholm Convention on Persistent Organic Pollutants, adopted in Geneva on May 15, 2015. The amendments include new hazardous substances that were recommended by the Persistent Organic Pollutants Review Committee. The additions include hexaclorobutadiene, pentachlorophenol and its salts and esters, and polychlorated naftalans. The amendments were published in the Official Gazette on February 10, 2017. 

By: Richard DiNitto

Many a common misunderstanding and misconceptions abound when addressing what OSHA requires or has not explicitly ruled on.  First aid requirements are ones that can often be misunderstood.  First aid is addressed in OSHA’s Standard 29 CFR 1910.151 on Medical Services and First Aid.  There are four basic requirements in this Standard and while seemingly limited in number, they are expansive in potential scope and apply to any employer:
 

1. Ensure readily available medical personnel for advice and consultation on matters of plant health;
2. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid;
3. Adequate first aid supplies shall be readily available; and
4. If any person’s eyes or body may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

 
While seemingly explicit, there is a lot of room for ambiguity and interpretation of these.  In this article, we will address requirement number one (1) on “readily available personnel”.
 
The exact wording of the OSHA requirement [1910.151(a)] is:
 
“The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.”
 
What OSHA has interpreted this to mean is that an employer must ensure prompt treatment for any injured employee at its facility.  This is commonly addressed in one of two ways (or both if desired): by (a) having personnel onsite that are trained to render first aid to the injured person or, (b) by ensuring that emergency treatment services are within reasonable proximity of the worksite.
 
OSHA has stated in opinion letters that an employer must ensure that “… adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee.” [1]
 
The “reasonable proximity” component of what OSHA expects is also not explicitly defined by OSHA, but OSHA has provided some clarification in subsequent interpretations, namely that “… OSHA has long interpreted the term 'near proximity' to mean that emergency care must be available within no more than 3-4 minutes from the workplace.” [2]
 
OSHA further states in the same interpretation that “… in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid.” [3]
 
OSHA has noted that in workplaces, such as offices, where the possibility of such serious work-related injuries is less likely, a longer response time of up to 15 minutes may be reasonable.
 
It should be noted that this Standard applies to all businesses, but more strict requirements do exist for unique special work conditions (logging, electrical power industry, etc.), where employee first aid training is mandatory, and a complete reliance on outside emergency responders is not allowed.
 
There are no exemptions for small employee or worker population sizes for compliance with this Standard.
 
As a major action step, employers should evaluate their operations and activities on a routine basis for the potential of serious injuries to occur and the availability of medical personnel within either the 3-4 minute window or the 15-minute window as identified in OSHA’s clarifications.  This is particularly important if no onsite first aid responder is available. These time windows apply whether the employer has an ambulance or medical professionals come to its facility or plans to transport the injured person to a medical facility itself.
 
We will discuss first aid training in our next article on OSHA’s First Aid Requirements.


Mr. DiNitto is a co-founder and Managing Partner of The Isosceles Group with over 30 years of
years of environmental and safety consulting and business operations experience, with emphasis on the design and implementation of ESH management systems for business operations, and the analysis and reporting of international regulations for environmental and occupational health and safety that affect industry and commercial enterprises. He can be reached at [email protected].


[1] https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25627

[2] https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25627

[3] https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25627

​The Tianjin government recently issued Notice on the Implementation Plan for Comprehensive Management of Hazardous Chemicals in order to ramp up efforts on risk evaluations on the city’s hazardous chemicals industry. The plan includes the digital mapping of hazardous chemicals entities and their production, storage, transportation, and operations evaluations. Additionally, the government will obtain the full number of companies within the municipality and establish a list for closures, conversions, and relocations according to safety evaluations. The government will also offer incentives and assistance for entities that relocate from highly populated areas to industrial parks