Mold Program Update
On January 1, 2016 New York State Article 32 of Labor Law went into effect. Before Article 32, there were no controls on contractors performing mold-related services. Some contractors were therefore able to take advantage of their customers by driving up prices. This provision set specific standards for mold projects and subsequently required those involved in mold assessment, remediation, and abatement to attain and carry a specific license.
The three licensing categories are: Mold Assessor, Mold Remediation Contractor, and Mold Abatement Worker. The usual sequence of events is that a customer would hire a NYSDOL Mold Assessor (such as Walden Environmental Engineering), who inspects the property and develops a Remediation Plan. From there the Mold Remediation Contractor and Mold Abatement worker can be hired by the customer to perform the physical work. Following the completion of the work, the Mold Assessor will determine if the remediation activities were sufficient. For more information, please read Walden’s blog NYS Department of Labor Mold Program Update.
Ventilation Requirements for Nail Salons
New Ventilation Standards for all nail salons in New York State went into effect during October 2016. The requirements included provisions for ventilation and exhaust systems to ensure the following:
- There is enough fresh outdoor air supplied to remove air contaminants to the required levels by exhausting them outdoors in a safe manner.
- Exhaust systems shall be designed to prevent exhaust air from being recirculated back into the building.
Nail salons and any other business that provides nail services which are licensed after October 3, 2016 will immediately be required to comply with these standards. Those that were in service before October 3, 2016 have been granted an additional 5 years to comply with these regulations.
Carbon Monoxide Detector Regulations
The New York State Uniform Fire Prevention and Building Code has been amended (19 NYCRR Part 1228 Section 1228.4) to require carbon monoxide detectors in commercial buildings that contain a potential carbon monoxide source. These include, but are not limited to: furnaces, boilers, gas or liquid fueled ovens, dryers, and any motor-vehicle related operations.
In order to determine the minimum number of carbon monoxide alarms required, a calculation must be done to determine the size of the “detection zone”. A detection zone is typically just a single story of a building, with an exception that each and every classroom is its own detection zone, and will require a carbon monoxide detector regardless of size. A detection zone of less than 10,000 square feet requires one monitor, while over 10,000 square feet requires two, one being at any location 100 feet away from the central location.
Fines for non-compliance are up to $1,000 per day and/or imprisonment. For more information, please read Walden’s Blog NYS Carbon Monoxide Detectors.
New Accident / Injury Reporting Rule
A new rule established by OSHA, effective on January 1, 2017, will require certain employers to submit injury and illness data electronically. High-risk industrial establishments (see https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf) with 20 to 249 employees will be required to submit Form 300A from 2016 by July 1, 2017. Similarly, the 2017 data must be submitted on July 1, 2018. Beginning in 2019, the previous year’s data must be submitted by March 2nd.
For establishments with 250+ employees, the July 1, 2017 submission is exactly the same as above. However, 250+ employee-establishments must submit Forms 300A, 300, and 301 beginning with 2018, and from that point on. Similar to above, starting in 2019 the deadline for submission shall be March 2nd.
Employers of companies that are not on the exempt list for low-risk industries (https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html) and have more than 10 employees must keep their records in-house, but are not required to submit electronically.
Amendment to 6 NYCRR 482-2 (Title V)
Effective June 22, 2016, an amendment was added to 6 NYCRR 482-2, commonly known as “The Operating Permit Program”. The effect of this amendment is all facilities falling under Title V of the Federal Clean Air Act are required to pay an updated annual fee based on emissions, which are based on the facility emissions of the previous year.
The key takeaway is that all facility managers must complete their previous year’s emissions statements, otherwise the emissions amount will be based on total potential emissions. To Learn more, please read Walden’s blog, The Number One Mistake Facilities Can Make with the Title V NYS Air Permit Changes.
For additional information or to learn more about how these regulatory changes may affect your facility, please contact Walden Environmental Engineering at 516-624-7200.