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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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.

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

Has the Clean Air Act Worked?

When working in a regulated industry, the focus is usually on how can I comply with the regulation, or questioning why the regulation has been drafted that way.  The ultimate purpose of the regulation has a tendency to get lost in the day-to-day management of how the regulation is worded, how it is inspected, and what types of violations have been recently highlighted.  Such is the case of the Clean Air Act. 

If you look at the history of the Clean Air Act in the United States, there was a need to do something.

TSCA and Chemical Securities Act

FYI - There is a website out there titled "Reform TSCA" that has information about the "bipartisan" Chemical Securities ACT.  For more information go to this link.

Keep up to date on the happenings with these potential changes.  Even without action in Congress - we are already seeing changes at EPA regarding chemical information and TSCA requirements.

Chemical Risk Assessment

Check out this article

News from the American Chemistry Council - Risk Analysis Meeting

What you may have missed from the Society for Risk Analysis Meeting - News from the ACC.
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