Tuesday, November 27, 2012

NIOSHA Recommended Medical Surveillance For Some Healthcare Workers

National Institute for Occupational Safety and Health (NIOSH) is recommending addition protections for healthcare workers who prepare, administer, or transport hazardous drugs or dispose of hazardous drug waste  To minimize or prevent exposure to chemical hazards, NIOSH is recommending that employers establish a medical surveillance program as part of a comprehensive prevention program that utilizes engineering controls, good work practices, personal protective equipment (PPE), and training to protect workers.

Medical surveillance involves collecting and interpreting data to detect changes in the health status of working populations potentially exposed to hazardous substances.The elements of a medical surveillance program are used to establish an initial baseline of workers' health and then monitor future health as it relates to their potential exposure to hazardous agents. This information can be used to identify and correct prevention failures leading to disease. In particular, an effective surveillance program begins with a hazard identification program that is integrated with surveillance for disease or illness.

NIOSH has indicated that for workers exposed to hazardous drugs, the medical surveillance program should include:

  • Reproductive and general health questionnaires completed at the time of hire and periodically thereafter.
  • History of drug handling as an estimate of prior and current exposure, including dates of duty assignment related to hazardous drugs and similar types of information.
  • A plan to provide initial baseline clinical evaluation, including appropriately targeted medical history, physical examination, and laboratory testing for workers identified as being potentially exposed to hazardous drugs that anticipates their potential toxicities.
  • A follow-up plan as needed for workers who have shown health changes suggesting toxicity or who have experienced an acute exposure (substantial skin contact or inhalation exposure, cleaning a large spill [a broken IV bag, leaking IV line], etc.).

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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Thursday, November 15, 2012

Information Request For Hydraulic Fracturing Study

EPA has published a request for information in the Federal Register asking the public to submit data and scientific literature on the potential impacts of hydraulic fracturing on drinking water resources. Congress has requested that EPA to conduct scientific research to examine the relationship between hydraulic fracturing and drinking water resources, in response to public concern.

The Agency is undertaking a study to understand the potential impacts of hydraulic fracturing on drinking water resources, if any, and to identify the factors that may affect the severity and frequency of such impacts. The scope of the study includes the full hydraulic fracturing water lifecycle, from water acquisition, through the mixing of chemicals and injection of fracturing fluids, to the post-fracturing stage (including the management of flowback and produced water), to its ultimate treatment and disposal. The study will include a review of the published literature, analysis of existing data, scenario evaluation and modeling, laboratory studies, and case studies.

Interested persons are requested to submit scientific analyses, studies, and other pertinent scientific information. The agency will accept data literature until April 30, 2013.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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Tuesday, October 9, 2012

Use of e-NEPA System Required After October 1, 2012

U.S. Environmental Protection Agency (EPA) has announced the release of e-NEPA, a new online system that allows federal agencies to submit environmental impact statements (EISs) electronically. Traditionally, EISs have been submitted to EPA in hard copy. e-NEPA eliminates the need to mail or deliver copies of EISs to EPA headquarters, reducing printing, shipping, and delivery costs. EPA also belives it will save time through electronic filing and e-confirmation and improves transparency, allowing EPA to post EIS documents to EPA’s website.

The National Environmental Policy Act (NEPA) requires federal agencies to integrate environmental considerations into their decision-making processes by identifying the environmental impacts and reasonable alternatives to their proposed actions. To meet NEPA requirements federal agencies prepare detailed analyses known as EISs. EPA reviews, provides comments, and maintains a national filing system for EISs.

Beginning on October 1, 2012, all agencies are required to use the e-NEPA filing system.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.
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Monday, October 8, 2012

FTC Issues Revised Green Guides For Environmental Attribute Claims

The Federal Trade Commission (FTC) recently issued revised "Green Guides" that are designed to help marketers ensure that the claims they make about the environmental attributes of their products are truthful and non-deceptive. FTC has modified and clarified sections of the previous Guides and provided new guidance on environmental claims that were not common when the Guides were last reviewed.

Among other modifications, the Guides caution marketers not to make broad, unqualified claims that a product is "environmentally friendly" or "eco-friendly" because the FTC's consumer perception study confirms that such claims are likely to suggest that the product has specific and far-reaching environmental benefits. The revised Guides advise marketers not to make an unqualified degradable claim for a solid waste product unless they can prove that the entire product or package will completely break down and return to nature within one year after customary disposal.

The FTC cautions that items destined for landfills, incinerators, or recycling facilities will not degrade within a year, so marketers should not make unqualified degradable claims for these items; and clarify guidance on compostable, ozone, recyclable, recycled content, and source reduction claims.The Guides also contain new sections on Certifications and seals of approval; carbon offsets; free-of claims; non-toxic claims; made with renewable energy claims; and made with renewable materials claims.

The FTC first issued its Green Guides in 1992 to help marketers avoid making misleading environmental claims. It revised the Guides in 1996 and 1998, and proposed further revisions in October 2010 to take into account recent changes in the marketplace. The guidance they provide includes:
  • General principles that apply to all environmental marketing claims;
  • How consumers are likely to interpret particular claims, and how marketers can substantiate these claims; and
  • How marketers can qualify their claims to avoid deceiving consumers.

FTC says the revised Guides issued take into account nearly 340 unique comments and more than 5,000 total comments received since the FTC released the proposed revised Guides in the fall of 2010. They also include information gathered from three public workshops and a study of how consumers perceive and understand environmental claims.

The Green Guides are not agency rules or regulations, but describe the types of environmental claims the FTC may or may not find deceptive under Section 5 of the FTC Act. Under Section 5, the agency can take enforcement action against deceptive claims, which ultimately can lead to Commission orders prohibiting deceptive advertising and marketing and fines if those orders are later violated.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.

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Wednesday, September 12, 2012

Minnesota Based Grocery Chain Awarded For Improved Refrigerant Handling

Minnesota-based Supervalu, which operates Albertsons and Lucky stores, earned this year’s Distinguished Partner Award. The Distinguished Partner Award is given to the supermarket partner company that goes above and beyond to advance the mission of the GreenChill Partnership. Albertsons Carpinteria, Calif., store was recognized with GreenChill’s prestigious Best of the Best Award, given to the best new GreenChill-certified store each year. The Carpenteria store recently achieved Platinum-Level store certification, the highest certification level that can be obtained for advanced refrigeration technology that prevents harmful refrigerant emissions. It is the first store in the nation to use a new generation of low global warming refrigerants.

GreenChill is an EPA partnership with supermarkets to transition to low-impact refrigerants; reduce the amount of refrigerant used, and eliminate refrigerant leaks. GreenChill has 54 partners with almost 8,000 stores, representing over 20% of the supermarket industry.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.
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Monday, August 6, 2012

Microbial Risk Assessment (MRA) Guideline

The Environmental Protection Agency (EPA) and the USDA’s Food Safety and Inspection Service (FSIS) has announced the release of the Microbial Risk Assessment (MRA) Guideline. This new MRA Guideline lays out an approach to conducting assessments of the risks posed by pathogens in food and water. Pathogens ingested in food and water can result in acute gastrointestinal-related illnesses; some gastrointestinal-related illnesses can result in long-term and permanent health effects as well as premature death. This new guideline will improve the quality of the data collected by public health scientists charged with protecting Americans from pathogen-related risks in food and water.

Formal risk assessments for food, water, and environmentally-relevant chemicals have been undertaken for decades. However, an overarching microbial risk assessment guideline has not been available until now. The guideline announced today meets this need by providing comprehensive, yet specific and descriptive information for developing assessments of microbial risk in food and water.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment.
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Flame Retardant Alternatives Report

US Environmental Protection Agency (EPA) has released a draft report on alternatives to the toxic flame retardant chemical known as decabromodiphenyl ether (decaBDE). Developed with public participation under the Agency's Design for the Environment (DfE) program, the comprehensive assessment profiles the environmental and human health hazards of 30 alternatives to decaBDE. DecaBDE is a common flame retardant used in electronics, vehicles, and building materials. Because it can cause adverse developmental effects, persist in the environment, and bioaccumulate in people and animals, it will be phased out of production by December 2013.

EPA's new report was intended to help manufacturers identify alternatives to decaBDE. EPA will work directly with manufacturers to investigate chemical and non-chemical alternatives to flame retardants. EPA said the draft report is the latest in a series of actions it is taking to address flame retardants made with bromine. Other actions include:
  • June 1, 2012: EPA released a TSCA work plan of 18 chemicals which the agency intends to review and use to develop risk assessments in 2013 and 2014, including three flame retardant chemicals. EPA is currently developing a strategy, scheduled for completion by the end of this year that will address these three and a broader set of flame retardant chemicals. This effort will aid the agency in focusing risk assessments on those flame retardant chemicals that pose the greatest potential concerns. EPA anticipates initiating the risk assessments on this category of chemicals in 2013.
  • April 2, 2012: EPA proposed actions under TSCA that will require manufacturers, importers, and processors of polybrominated diphenyl ether (PBDE) flame retardants to submit information to the agency for review before initiating any new uses of PBDEs after Dec 31, 2013. Those who continue to manufacture, import, or process after December 31, 2013, would be subject to a testing requirement under TSCA.
  • 2009: EPA developed action plans on PBDEs (including pentaBDE, octaBDE, and decaBDE) and hexabromocyclododecane (HBCD) that summarized available hazard, exposure, and use information; outlined potential risks; and identified the specific steps the agency is pursuing under the TSCA. The alternatives analysis for decaBDE was included in the action plan.

According to EPA, alternatives to decaBDE characterized in the report are already on the market and will be used increasingly as decaBDE is phased out, but they also have differing hazard characteristics and are associated with trade-offs. For example, some alternatives that appear to have a relatively positive human health profile may be more persistent in the environment. Some alternatives appear to be less toxic than decaBDE. Preliminary data suggests that these flame retardants may have a lower potential for bioaccumulation in people and the environment. However, the Agency points out that these health and environmental profiles are largely based on computer-model generated estimates, and that the models are limited in their ability to predict concern. Laboratory testing and ongoing environmental monitoring is necessary to fully understand the potential for concern associated with these chemicals.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Environmental Review and Environmental Impact Assessment. Caltha Environmental Review Website