Sophic Pursuits, Inc. - Practical Solutions for Today's Regulatory Environment

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Keeping your LDAR Program Current
It is time to start watching - S697
New Chemicals under Prop 65
Toxicity - Sensationalism versus reality


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2016 is a Chemical Data Reporting Year!  On June 1 - EPA will be presenting a Webinar on the current reporting tool (more information can be found on the EPA website here.)

In addition, it appears that the conference committee has reached an agreement on TSCA Reform.  And, we should see movement soon.  You can find out more by going to the American Chemistry Council page announcing the agreement.

Keeping your LDAR Program Current

The 15th LDAR Symposium Sponsored by the ISA just concluded in New Orleans.  If you were unable to attend that session, here is a webinar that was presented prior to the Symposium "Keeping your LDAR Program Current."

It is time to start watching - S697

After several years of hearing that it is coming, it appears it is finally happening.  There has been a move afoot to "modernize" the Toxic Substance Control Act (TSCA). Over time there has been a bill that has been introduced and then never acted upon.  However, this session of Congress appears to be moving this one along.

It seems that Senate Bill 697 (S697) has become the consensus leader in the pursuit of action. And, so far seems to be moving at a rapid pace.  This Bill - the "Frank R.

New Chemicals under Prop 65

For those of you who have to do Prop 65 labeling - there are 12 new chemicals that have to be included:

Toxicity - Sensationalism versus reality

Toxicity – noun – the quality, relative degree or specific degree of being poisonous.

How many times have you seen in the news – toys contain toxic materials, or your food is loaded with toxic chemicals, or there are toxic materials in your holiday decorations?  The list of headline variations is just as numerous as the number of materials that exist.  And, from a public relations or sensationalism point of view – these headlines are effective.  But, are you aware that water is toxic, and I don’t mean the impurities in the water either.

Year in review - preparation for 2015

2014 is quickly drawing to a close.  Which means that many of the regulatory specialists are in the process of developing a plan of attack for the year end reporting.  January always brings a slew of data gathering, and requests to parse that data for a variety of reports.  So, it is always helpful to look at what changes may have occurred in the past year that you need to be aware of as there may be changes to the lists of materials, slight definition changes that may require a bit of analysis to determine if the data you are collecting is correct, and there may even be a new form or report that you haven't considered.


On November 28, 2014  - the Department of Energy issued a proposed rule that will impact commercial and industrial compressors.  From the summary of the proposed rule:

"The U.S. Department of Energy (DOE) is considering establishing energy conservation standards for commercial and industrial compressors. To date, DOE has considered energy conservation standards only for compressors intended to compress air, rather than natural gas. As a result, DOE's current efforts have focused on air compressors.

Legislation, Regulation and Impacts

For those of you that follow this blog, you have heard me discuss the unintended consequences of regulation before.  But look at the following items:

According toGovTrack

The 113th Congress has passed 186 Laws 
The 112th Congress passed 284 Laws
The 111th Congress passed 385 Laws

According to an article published inMarch 2014- the 17,522 pages of regulations have been added to the Code of Federal Regulations since 2009 - essentially an 11% increase in the regulatory burden. 

Just prior to this holiday weekend - the

The Chemical Safety Board & the Chevron Refinery Incident

The Chemical Safety Board (CSB) had released its final report on the Chevron Refinery Incident that occurred on August 6, 2012.  (The final report can be foundhere.)  Additionally, the CSB has issued some recommendations regarding how refineries should be regulated.  (See the CSBpress release) At issue is the process safety management (PSM) program and how it is managed.  Today the CSB sees PSM as primarily reactive rather than a proactive adapted program. 

PSM and other regulations such as the SARA Community Right to Know have been under a great deal of scrutiny of late due to incidents like this one and the one that occurred in West, TX.

OSHA Announces a New Chemical Exposure Initiative

You might have missed it given all of the various news items about Ebola and what is happening with the Center for Disease Control - but OSHA has announced a new initiative regarding the evaluation of permissible exposure limits (PELs) in the work place.  

According to the OSHA'spress release, over 95% of the current OSHA PEL's have not been updated since the initial acceptance of the PEL in 1971.  Additionally, the current list covers fewer than 500 chemicals. On October 10, a Request for Information was published in the
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