IHMM Government Affairs2023-06-06T20:19:41+00:00

 IHMM Government Affairs

Advocacy seeks to ensure that all people in society are able to have their voices heard on issues that are important to them.
Our advocacy seeks to protect and promote our rights as citizens. Advocacy ensures that we have our views
and wishes genuinely considered when decisions are being made about our lives.

OSHA Seeks Feedback on Effectiveness of Leading Indicators to Improve, Develop Resource Tool

The U.S. Department of Labor’s Occupational Safety and Health Administration is asking for stakeholder input on their current use of leading indicators and their impact on managing their safety and health management systems. Leading indicators are proactive and preventive measures that can provide insight on the effectiveness of safety and health activities and reveal potential problems. They are vital in reducing worker fatalities, injuries, illnesses, and financial impacts.

As OSHA considers developing a Leading Indicators Resource, the agency welcomes stakeholders to share their experience and expertise and provide detailed feedback on how/where they are used at their workplace. OSHA is interested in various perspectives on stakeholders’ answers to questions, such as the following:

  • What leading indicators do you use?
  • What lagging indicators do you use (OSHA incident rates, for example)?
  • What leading indicators are, or could be, commonly used in your industry?
  • What metrics do you share with top management?
  • How do you determine the effectiveness of your leading indicators?
  • Do you link your leading indicators to outcome data, such as OSHA incident rates to evaluate results?
  • How could employers be encouraged to use leading indicators in addition to lagging indicators to improve safety management systems?
  • What barriers and challenges, if any, have you encountered to using leading indicators?

Individuals may submit comments at regulations.gov by July 17, 2023, which is the Federal eRulemaking Portal, identified by docket number OSHA-2023-0006. For more information, see the OSHA Trade Release.

Ohio EPA – Hazardous Waste Program Proposed Rules

May 3, 2023  – 10.30 am – 11.00 am

Organic Air Emissions and Definition of Solid Waste Rules: On March 27, 2023, the director of Ohio Environmental Protection Agency, under the authority of Section 119.03 of the Ohio Revised Code and in accordance with Chapter 119, proposed to original file 173 rules as a part of the Organic Air Emissions and Definition of Solid Waste (OrgAirDSW) rules package. A public hearing on this proposed rulemaking will be held in-person on Wednesday, May 3, 2023, at 50 W. Town Street, Suite 700, Conference Room A (Autumn), at 10:30am.

The hearing will also be held virtually at the same date and time. Advance registration for this hearing may be completed here:
https://attendee.gotowebinar.com/register/5706686780059016797

Any persons intending to give public testimony at said hearing should notify the Ohio EPA Public Interest Center [P.O. Box 1049, Columbus, Ohio 43216-1049, (614) 644-2160]. Written testimony may be either be submitted ahead of the hearing to the below address, electronically to Kit Arthur or Madison Graham, or to the Hearing Officer at the public hearing.

Read more >>  https://epa.ohio.gov/about/media-center/events/public-hearing-HazWasteRules

IHMM thanks our friends at Central Ohio CHMM (COCHMM) for sending this to us.

PHMSA Requests Feedback on Recycled Plastics Policy

On April 14, 2023, the Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published a request for feedback on its recycled plastics policy. 88 Fed. Reg. 23140. PHMSA states that it published the notice to solicit information pertaining to how the potential use of recycled plastic resins in the manufacturing of specification packagings may affect hazardous materials transportation safety; ensure transparency of its current policy pertaining to the use of recycled plastics in the manufacturing of specification packagings; seek input on this policy to inform better potential regulatory changes; and gather information for the evaluation of future approval requests and to inform better decisions pertaining to potential regulatory revisions and other related work. Comments are due July 13, 2023. PHMSA notes that in conjunction with the notice, it is considering conducting a webinar to inform the public of its recycled plastics policy if there is sufficient feedback. PHMSA will post information regarding any future webinars on its website. For more information, please read the full memorandum.

Read more >> https://www.lawbc.com/regulatory-developments/entry/phmsa-requests-feedback-on-recycled-plastics-policy

More Federal Recognition for the CSHM, CSMP, CHMM, and CHMP – IHMM Drafts Comments to OSHA Voluntary Protection Program [VPP]

OSHA’s Voluntary Protection Programs (VPP) was initiated in 1982 to recognize workplaces with exceptional safety and health management. VPP was groundbreaking, being among the first programs to employ a management system structure emphasizing management leadership, worker participation, robust hazard identification and control, and training. In the intervening 40+ years, the program has grown to include a wide variety of organizations in many industries. Much has been learned about safety and health management since the VPP requirements were last updated in 1989. OSHA published its Recommended Practices for Safety and Health Programs in 2016 and consensus standards have been published at both the national (ANSI Z10-2019) and international level (ISO 45001-2018).

OSHA is seeking public input as it considers updating its Voluntary Protection Program (VPP); to expand participation and increase Safety and Health Management System (SHMS) adoption.

IHMM has drafted comments for the OSHA VPP proceeding, focused on the CSHM, CSMP, CHMM, and CHMP, which we intend on submitting by the end of May. If you have any comments on the IHMM submission please send them to Gene Guilford at [email protected]

Professional Certification Coalition

IHMM is a member of the PCC. The PCC monitors state and federal legislative and regulatory activity affecting professional certification on an ongoing basis. The PCC has compiled several “Watchlists” identifying and analyzing provisions in pending legislation at both the state and federal level that, under applicable rules, may still be enacted in the current legislative session.  Depending on the carry-over rules in the relevant legislature, the charts listing current legislation may include bills introduced in a prior year.  In addition, the PCC compiles each year a chart of enacted legislation that affects certification. The charts include hyperlinks to every bill or executive order. Note that the Watchlist and the Enacted Legislation document do not include profession-specific legislation and do not include regulatory initiatives. The charts will be updated as needed based on new developments.

IHMM Credential Recognition

The highest priority of IHMM’s Government Affairs Committee is the recognition of IHMM’s credentials by government. We have made substantial progress in the two years we have undertaken this endeavor, as outlined in detail here > https://ihmm.org/credential-recognition/

In this project we have 45-in-5, increasing the number of states that recognize IHMM credentials.

  • We have already succeeded in 13 states – New York, Connecticut, Pennsylvania, Indiana, California, Colorado, Nebraska, Minnesota, Arkansas, Oklahoma. Ohio, North Dakota, and Georgia. [Red states in the map above]. These are states where IHMM credentials are cited or 40 CFR 312.10 is cited by reference.
  • We have partially succeeded in another 16 states – Alaska, Hawaii, Idaho, Montana, Arizona, Kansas, Iowa, Missouri, Illinois, Kentucky, Florida, Delaware, Rhode Island, Massachusetts, Vermont, and Maine. [Orange/Black Stripe states in the map above] These are states where the requirements of an “environmental professional” or QEP are cited that coincide with an IHMM credential so that relatively little work would need to be done to clarify the desired outcome.
  • We have 21 states where no reference to an IHMM credential is made in either statute or regulation, nor is there anything defined in the area of an environmental professional. These states will require legislation or regulatory work. [Yellow states in the map above].

in January 2022 Gene Guilford released the 40 CFR § 312.10 EPA regulation that states a private certification that meets or exceeds the requirements of the regulation is an Environmental Professional under the regulation. Here is the crosswalk between the 40 CFR § 312.10 EPA regulation and the Certified Hazardous Materials Manager [CHMM] blueprint. The CHMM meets or exceeds the requirements of an Environmental Professional. 

Here’s what we ask each volunteer to do:

  • Watch legislative and regulatory developments in your state that provide an opportunity for us to create amendments or other interventions
  • Be willing to speak with regulators and legislators in your area about the recognition efforts we craft together

Other State and Federal Activities

In this section we will highlight other state and federal government affairs activities undertaken by the committee.

Current Priorities April-June 2023

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