🇺🇸 US Requirements — EHS · Energy · CSR

• Employers must furnish a workplace free from recognized hazards likely to cause death or serious physical harm — even where no specific standard exists.
• Used by OSHA to cite hazards such as heat stress, workplace violence and ergonomics.
• Defense relies on showing you identified hazards and applied feasible controls — i.e. a documented risk-assessment process.
• State Plans may have explicit rules where federal OSHA relies on 5(a)(1) (e.g. Cal/OSHA heat illness prevention).

Tools that help: Risk Assessment (document hazards & controls) · Inspections · Ergonomics Assessment.

• Record work-related injuries and illnesses meeting recording criteria on the OSHA 300 Log, with a detailed Form 301 incident report for each case (within 7 calendar days).
• Post the annual summary Form 300A at each establishment from February 1 to April 30, certified by a company executive.
• Electronically submit data via OSHA's Injury Tracking Application by March 2 each year (300A for covered establishments; larger establishments in designated high-hazard industries also submit 300/301 data).
• Report a fatality within 8 hours; any in-patient hospitalization, amputation or loss of an eye within 24 hours.
• Your log feeds TRIR (recordables × 200,000 / hours worked) and DART — the metrics every US client will ask for.

Tools that help: Incident Management (301-style investigations) · EHS KPI Dashboard (TRIR / DART calculation & trending) · Retention Calculator (5-year record retention).

• Maintain a written HazCom program and a complete chemical inventory of hazardous chemicals on site.
• Ensure containers carry GHS-compliant labels (pictograms, signal word, hazard statements); workplace labeling system for secondary containers.
• Keep Safety Data Sheets (16-section GHS format) readily accessible to employees for every hazardous chemical.
• Train employees on hazards, labels and SDS before initial assignment and whenever a new hazard is introduced.
• Note the standard has been updated to align with more recent GHS revisions — check label and SDS compliance dates with suppliers.

Tools that help: Chemical Risk Manager (inventory, GHS data, SDS register) · Training Matrix (HazCom training records).

• Establish an energy control program with documented, machine-specific written procedures for servicing and maintenance.
• Provide standardized locks and tags; only the authorized employee who applied a lock may remove it.
• Train authorized, affected and other employees to their respective levels.
• Conduct and certify a periodic (at least annual) inspection of each energy control procedure.
• Cover group lockout, shift changes and contractor coordination in the procedures.

Tools that help: Safety Instructions (LOTO procedures & placards) · Training Matrix (authorized-employee training) · Internal Audit (annual procedure inspections).

• Identify and evaluate all confined spaces; classify permit-required spaces and post danger signs.
• Implement a written permit space program: entry permits, atmospheric testing (oxygen, flammables, toxics — in that order), isolation and ventilation.
• Assign and train entrants, attendants and entry supervisors; the attendant remains outside at all times.
• Arrange rescue and emergency services evaluated for capability — not just "call 911".
• Cancel and retain permits (1 year) and review the program annually.

Tools that help: Permit to Work (confined space entry permits) · Risk Assessment (space classification) · Training Matrix.

• Written respiratory protection program administered by a designated program administrator.
• Medical evaluation of each user before fit testing or first use (OSHA medical questionnaire or exam).
• Fit testing (qualitative or quantitative) before first use, whenever a different facepiece is used, and at least annually.
• Respirator selection based on exposure assessment; procedures for cleaning, storage, inspection and cartridge change-out.
• Training annually; Appendix D information even for voluntary use of filtering facepieces.

Tools that help: JHA & PPE Selector (selection logic) · Medical Surveillance (evaluations & clearances) · Training Matrix (annual fit-test & training tracking).

• PEL of 90 dBA as an 8-hour TWA; feasible engineering/administrative controls required above it.
• Action level 85 dBA (8-h TWA): enroll exposed employees in a hearing conservation program.
• Program elements: noise monitoring, baseline and annual audiograms, standard threshold shift (STS) follow-up, hearing protector provision with adequate attenuation, training and recordkeeping.
• Work-related STS cases resulting in a recordable shift go on the OSHA 300 log (hearing loss column).

Tools that help: Hearing Conservation (exposure, audiometry & STS tracking) · Medical Surveillance · EHS KPI Dashboard.

• Perform a workplace hazard assessment to determine required PPE — and certify it in writing (workplace, assessor, date).
• Employer pays for most required PPE (with limited exceptions such as everyday safety-toe footwear).
• Select PPE meeting consensus standards (ANSI/ISEA); train employees on when, what, how — and require demonstration of understanding.
• Specific subparts cover eye/face (1910.133), head, foot, hand and electrical protective equipment.

Tools that help: JHA & PPE Selector (generates the certified hazard assessment) · Risk Assessment · Training Matrix.

• Fall protection required at 6 feet (1.8 m) in construction — guardrails, safety nets or personal fall arrest systems (general industry: 4 ft under 1910.28).
• Specific rules for leading edges, holes, roofing work, excavations and wall openings.
• Training by a competent person on fall hazards and equipment use, with written certification; retrain when deficiencies appear.
• Inspect fall arrest equipment before each use; plan rescue of suspended workers.
• Fall protection is consistently OSHA's #1 most-cited standard — expect inspection focus.

Tools that help: Permit to Work (work-at-height permits) · Checklists (equipment pre-use inspections) · Training Matrix.

• Applies to processes with highly hazardous chemicals above threshold quantities (Appendix A) or large flammable inventories.
• 14 interlocking elements: process safety information, process hazard analysis (revalidated every 5 years), operating procedures, training, mechanical integrity, management of change, pre-startup safety review, incident investigation, emergency planning, contractors, hot work, employee participation, trade secrets, compliance audits.
• Compliance audits every 3 years with certified findings and tracked corrective actions.
• EPA's Risk Management Program (RMP) under the Clean Air Act mirrors PSM for offsite consequences — many sites need both.

Tools that help: Risk Assessment (PHA support) · Internal Audit (triennial compliance audits) · Incident Management · Document Control (process safety information & MOC).

• Written EAP required when another standard mandates one (kept at the workplace; oral plan allowed only with 10 or fewer employees).
• Minimum content: reporting procedures, evacuation routes and procedures, accounting for all employees, critical plant shutdown duties, rescue/medical duties, contact names.
• Alarm system distinguishable for each purpose; designated and trained evacuation wardens are good practice.
• Review the plan with each employee at assignment, when duties change, and when the plan changes. Pair with a Fire Prevention Plan (1910.39) where required.

Tools that help: Safety Instructions (emergency procedures & postings) · Toolbox Talk Pack (drill briefings) · Checklists (drill & equipment checks).

• Your monthly generation rate sets your category: VSQG (≤100 kg/month), SQG (100–1,000 kg), LQG (>1,000 kg, or >1 kg acute hazardous waste) — with escalating obligations.
• Obtain an EPA ID number (SQG/LQG); ship waste with a hazardous waste manifest (e-Manifest) to permitted facilities only.
• Respect accumulation time limits (90 days LQG, 180 days SQG) and container rules: closed, labeled "Hazardous Waste" with accumulation start date.
• Perform weekly inspections of accumulation areas; maintain contingency plan and personnel training (formal annual training for LQG).
• LQGs file a Biennial Report (March 1 of even-numbered years); SQGs re-notify every 4 years. Many states add stricter rules.

Tools that help: Waste Register (streams, quantities, manifests, generator status) · Inspections (weekly area checks) · Retention Calculator (3-year manifest retention).

• Tier II: annual inventory of hazardous chemicals stored above thresholds (generally 10,000 lb; 500 lb / TPQ for extremely hazardous substances) — due March 1 to the state agency, LEPC and fire department.
• TRI (Form R): facilities in covered sectors with 10+ employees report releases and waste management of listed toxic chemicals above activity thresholds — due July 1.
• Immediate release reporting (EPCRA §304 / CERCLA §103) for releases of listed substances above reportable quantities.
• Keep SDSs and storage data aligned with what you declare — agencies cross-check.

Tools that help: Chemical Risk Manager (inventory with quantities & locations for Tier II) · Environmental Manager (releases & aspects) · Legal Register (deadline tracking).

• No intentional venting of ozone-depleting or substitute refrigerants (HFCs); recovery with certified equipment during service and disposal.
• Technicians servicing equipment must hold EPA Section 608 certification.
• Leak rate tracking and repair obligations for comfort-cooling, commercial and industrial refrigeration appliances above the regulated charge threshold (50 lb full charge); records of service and refrigerant additions.
• The AIM Act HFC phasedown is progressively restricting high-GWP refrigerants — plan retrofits and purchases accordingly.

Tools that help: Environmental Manager (equipment registers & leak logs) · GHG Calculator (fugitive refrigerant emissions, Scope 1).

• Required when aggregate aboveground oil storage exceeds 1,320 gallons (counting containers ≥55 gal) — or 42,000 gal underground — with a reasonable expectation of discharge to navigable waters.
• Prepare and implement a written SPCC Plan: secondary containment, inspections, security, transfer procedures, training.
• Plan certified by a Professional Engineer (self-certification possible for qualified facilities ≤10,000 gal with no significant spill history).
• Review every 5 years and amend on facility changes; document monthly/periodic tank inspections.

Tools that help: Environmental Manager (tank inventory & containment) · Inspections (tank inspection rounds) · Checklists.

• Industrial facilities in regulated sectors with exposed activities need NPDES stormwater permit coverage (federal MSGP or the state equivalent) — or certify No Exposure.
• Develop and keep current a Stormwater Pollution Prevention Plan (SWPPP): pollutant sources, best management practices, spill response.
• Conduct routine facility inspections and quarterly visual assessments of discharges; benchmark/analytical monitoring per sector.
• Construction projects disturbing ≥1 acre need separate construction stormwater permit coverage.

Tools that help: Environmental Manager (aspects, BMPs, monitoring) · Inspections (quarterly visual assessments) · Waste Register (good housekeeping of waste areas).