Author: Richard DiNitto
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Onsite oil, diesel, and related liquids may require that you implement a government-mandated spill management plan in the United States when certain conditions are met.
 
Many people are not aware that if you have 1,320 gallons or more of oil and related liquids “combined” in above-ground storage containers (or greater than 42,000 gallons “combined” in underground storage tanks), you may have to develop and put into place a Spill Prevention & Countermeasures Control (SPCC) Plan under the Oil Pollution Prevention Regulations (40 CFR 112).
 
The second criteria for establishing an SPCC Plan is that a release from the above storage could impact “navigable waters” and “adjoining shorelines”.  This is a more difficult one to address and requires greater knowledge of your facility’s location in relation to surrounding surface water bodies and channels.  Even onsite drainage ditches that channel runoff to nearby streams, etc., could place your operation within this requirement.
 
While many facilities may not routinely store any oils or related liquids, such as diesel, onsite for general use, they often forget to take into account emergency back-up generators. Just two of these generators can have a combined storage capacity of greater than 1,320 gallons.
 
It is important to note that it is the “combined quantity” of all storage onsite that counts, and not the size of just the largest tank. Two tanks of 750 gallons will exceed the threshold for application of this regulation.
 
If you meet the applicability requirements of these regulations, then a SPCC Plan must be prepared and certified by a professional engineer unless:

• You have < 10,000 gallons total in above-ground storage tanks or containers with no single tank > 5000 gallons; and
• There have been no discharges > 1000 gallons in the past 3 years or > 42 gallons in any 12-month period.

 
The contents of the SPCC Plan are detailed within the regulations, but broadly must contain the topics in the table below. The SPCC Plan must be maintained at the facility if manned 4 hours/per day or more, or at the nearest field office if manned less than 4 hours/per day. It is also required to be reviewed and updated every 5 years, or within 6 months of any material changes.

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The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities. 
 
If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at rdinitto@theisogroup.com or (617) 330-2800.

Taiwan published 420 frequently asked questions of its New and Existing Chemical Registration Regulation. The publication addressed questions on regulatory mechanism, registration operation, registration number, joint registration, standard registration, annual reporting and other areas. 
 
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​Additional Information:
https://chemlinked.com/sites/default/files/cdn/img/deng_lu_ban_fa_shuo_ming_hui_ti_wen_ji_shuo_ming_yi_lan_biao_.pdf. 

If you are interested in EHS regulatory products for Taiwan, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

Malaysia issued a notification of approval of industry code of practice known as the Industry Code of Practice for Management of Occupational Noise Exposure and Hearing Conservation. The Minister approved the Code on June 26, 2019 in exercise of the powers conferred by the Occupational Safety and Health Act 1994.
 
Additional Information:
http://www.federalgazette.agc.gov.my/outputp/pub_20190805_PUB%20377.pdf. 

​If you are interested in EHS regulatory products for Malaysia, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

Saudi Arabia issued an amendment to its Work System Law in late July of 2019. Changes include the following:

• Redefining the definition of “agent”;
• Amending article 3 to state that citizens are entitled to work without discrimination on the basis of sex, disability, and age, among others; and
• Prohibiting the dismissal of pregnant employees and those on maternity leave.

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Additional Information:
https://sd.mlsd.gov.sa/ar/policies/%D9%86%D8%B8%D8%A7%D9%85-%D8%A7%D9%84%D8%B9%D9%85%D9%84-0. 

If you are interested in EHS regulatory products for Saudi Arabia, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

​Russia issued Order No. 512H on Approval of the List of Productions, Works and Positions with Harmful and (or) Dangerous Working Conditions, on which the Use of Labor of Women is Limited. The Order determined in which industry jobs and positions with harmful and dangerous working conditions the use of women’s labor is limited. They include certain types of chemical production, underground and mining, metalworking, drilling, oil and gas production, ferrous and non-ferrous metallurgy, and shipbuilding. The order takes effect on January 1, 2021.
 
Additional Information: http://www.garant.ru/hotlaw/federal/1288007/. 

If you are interested in EHS regulatory products for Russia, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

France issued the Order of 17 July 2019 amending the Decree of 29 February 2016 on certain refrigerants and fluorinated greenhouse gases.

The July amendments specify procedures for the implementation of the permanent leak detection system in certain thermodynamic equipment. The order went into effect the day after its publication in the Official Journal.
 
Additional Information:
https://www.legifrance.gouv.fr/affichTexte.do;jsessionid=00C2224B8E6BCEF9F03256646180B862.tplgfr24s_2?cidTexte=JORFTEXT000038969068&dateTexte=&oldAction=rechJO&categorieLien=id&idJO=JORFCONT000038969020. 

​If you are interested in EHS regulatory products for France, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

The United Kingdom issued the Persistent Organic Pollutants (Amendment) (EU Exit) Regulations 2019, amending legislation in relation to persistent organic pollutants.

​Part 2 makes amendments to regulations on EU legislation. Part 3 revokes Part 4 of the Persistent Organic Pollutants (Amendment) (EU Exit) Regulations 2018 (S.I. 2018/1405) and the Environmental and Wildlife (Legislative Functions) (EU Exit) Regulations 2019 (S.I. 2019/473). Amendments are also made to the Chemicals (Health and Safety) and Genetically Modified Organisms (Contained Use) (Amendment etc.) (EU) Exit) Regulations 2019. Amendments take effect on exit day. 
 
Additional Information:
http://www.legislation.gov.uk/uksi/2019/1340/contents/made.

If you are interested in EHS regulatory products for the UK, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

Colombia issued Resolution Number 2404 of 2019 in July 2019, which adopts Instruments for the Evaluation of Psychosocial Risk Factors, the General Technical Guide for the Promotion, Prevention, and Intervention of Psychosocial Factors and their Effects on the Working Population. This resolution determines the periodicity of the evaluation of psychosocial risk factors, according to the level of risk of the workplace. It also details the instruments that are used to determine the presence or absence of labor-related psychosocial risk factors. 
 
Additional information:
https://diario-oficial.vlex.com.co/vid/resolucion-numero-2404-2019-800450345.

​If you have questions regarding the Resolution or have questions about any of our other global services and products, including workplace wellness and bullying, please contact Brittany Palmer at bpalmer@theisogroup.com. 

Slovakia published Decree No. 227/2019 Coll. in June 2019, thereby amending Decree No. 99/2016 Coll. on details of health protection against heat and cold stress at work. This Decree, which includes provisions for optimal and permissible values ​​of heat-moisture factors of the indoor working environment, protective and preventive measures in case of heat and cold stress at work, health risk assessments, and operating rules, entered into force on August 1, 2019. 
 
Additional information: https://www.slov-lex.sk/pravne-predpisy/SK/ZZ/2019/227/.

If you are interested in EHS regulatory products for Slovakia, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.

The Netherlands is preparing a Regulation on extended producer responsibility (UVP) to ensure that producers become aware of and bear responsibility for the waste phase of products. The Regulation will ensure sustainable, reusable and recyclable products. The purpose of the Decree is to set general requirements for existing and future UVPs, including on tasks and responsibilities, costs and information. The consultation period closes on September 15, 2019. 
 
Additional Information:
https://www.internetconsultatie.nl/besluit_regeling_uitgebreide_producentenverantwoordelijkheid.

If you are interested in EHS regulatory products for the Netherlands, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or bpalmer@theisogroup.com for a customized quote.