Date: Fri, 24 Apr 1998 12:03:40 -0500
The US EPA Common Sense Initiative (CSI) Electronics Subcommittee, to which several
IPC members belong, is exploring ideas regarding integrating safety and health
improvements with pollution prevention and other environmental performance goals.
Toward that end, the Subcommittee would like to pose several general questions to the
industry:
1--What problems and issues exist with the present EPA and OSHA environmental, health
and safety framework, and what impediments exist to hinder improved performance in
either or both areas? For example, are there actions you might undertake to improve
worker safety, but environmental regulations prevent you from doing so (or vice
versa)?
FYI, this is the precautionary principle: "When as activity raises threats of harm
to human health of the environment, precautionary measures should be taken even if
some cause and effect relationships are not fully established scientifically. In
this context, the proponent of an activity, rather than the public, should bear the
burden of proof."
Also FYI, the CSI is EPA's "cleaner, cheaper, smarter" project in regulatory reform.
Any comments, thoughts, examples or inquiries are quite welcome.
Thank you.
Christopher Rhodes
Date: Mon., 27 Apr 1998 11:45:57 -0400
Labeling is an area that could use some uniformity among the agencies;
specifically related to flammable/combustible materials. EPA, OSHA, NFPA
and DOT all have different definitions for what is flammable(<100 or <141),
ignitable(<140) or combustible (100-200 or 142-200). This topic always
presents a training nightmare since depending on the context the definition
changes.
Another area I see a conflict in health/safety vs. environment, is
ventilation requirements. There needs to be consensus on how much you need
to protect the workers and how will the increased ventilation contribute to
air pollution.
Just some quick comments.
Rose Perkins
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Subject: Environmental (EPA) and safety (OSHA) integration
2--If a forum of health experts were convened (with NIOSH and OSHA), what specific
topics might be included on the agenda that could allow for constructive engagement
of all stakeholders?
3--How can a rapidly changing industry most effectively be in conformance with the
precautionary principle?
Director of Public Policy
IPC
2215 Sanders Road
Northbrook IL 60062
847/509-9700 x306
fax 509-9798
rhodch@ipc.org
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