ACTenviro Ranks on the Inc. 5000 List for 2020!

We are immensely proud to announce that ACTenviro is once again on the annual Inc. 5000 list, the most prestigious ranking of the nation’s fastest-growing private companies. Making the list represents a unique look at ACTenviro and how we stay successful as an independent-small business. This list has every range of company on it from Fortune 50, to independent small businesses with twenty to twenty-five people. ACTenviro is proud to have made this annual list eleven years in a row!

As we always say, though it never gets old, this award belongs to each and every one of our employees in the ACT family, who have continued to uphold our core values and propel the company forward. This year in our 20th year of incorporation, a year that has had some unprecedented challenges, the passion and dedication of our team shines even brighter.

ACTenviro COVID-19 Facility Decontamination Services – How We Provide Efficient, Safe, and Affordable Coronavirus Decontaminations

Since the outbreak first emerged, surface cleaning and decontamination has been recommended by the CDC and other medical authorities as part of an overall strategy to minimize spread of Covid-19.  In response, in March, ACTenviro announced that we were expanding our services to provide facility decontamination of Covid-19.

As we said then, this isn’t our first rodeo – we have decades of experience with facilities decontamination. Coronavirus is different though, and we needed to make sure our decontamination procedures incorporated the best available information. First and foremost, we needed to uphold our core value of Safety, for our clients, employees, and communities.  Second, we needed to make sure our procedures were effective and would successfully remove surface contaminations.  In response, we created a Covid-19 Safety Committee, whose responsibility was ensuring our procedures incorporated the best guidance, such as the CDC Guidelines for facility cleaning and disinfection, and that we were updating our procedures whenever new information became available.

Facility cleaning and decontamination is recommended as a precautionary measure for all occupied indoor areas, with additional cleaning and decontamination for indoor areas that have been occupied by personnel who have contracted or potentially been exposed to coronavirus.

In general, Covid decontamination requires physical cleaning followed by use of approved disinfecting agents (bleach, ethanol, IPA or other approved disinfectants).  Workers will utilize personal protective equipment (PPE), including glove, respirators and protective clothing, based on the cleaners and disinfectants used as well as the method of application.  Work activities will progress in a systematic manner from the outside of the potentially contaminated, working from higher areas to lower areas.   Surfaces will be physically cleaned by ACT personnel before decontamination soap/water or other cleaners.

Once surfaces are physically clean, the decontaminating agent can be applied by hand wiping, spraying, fogging (with an electrostatic sprayer) or other suitable means. Disinfectant applied by hand wiping will be spread using a clean cloth or wipes so there is a visible amount on surfaces, but not so much so that there are large droplets or pools of liquid. Disinfecting agent will be allowed to air dry on surfaces or, if that is not feasible, will be left on the surface for the manufacturers recommended contact time.

ACT implemented these procedures to ensure surface decontamination is conducted effectively and consistently.  All decontamination projects will be led by a project manager, who will assess the unique needs of each client’s facility. Additionally, our teams have the highest level of training allowing us to provide preventative cleaning, decontamination and emergency response services safely and efficiently. We have the expertise to choose the right level of PPE to protect our workers without adding unnecessary burden or expense. Covid-19 Decontamination Certificates can be provided to clients as requested.

For more information or if you would like a free quote for your facility, please email us at [email protected] or call (866) 333-9222. Whether it’s proACTive or reACTive, our coronavirus response services handle everything from decontamination to disposal.

See our Coronavirus Services Page here.

Coronavirus Cleaning and Disinfection – What to do and how to do it!

Coronavirus is spread from person to person by respiratory droplets caused by coughing, sneezing or talking, and the biggest risk factor for acquiring the illness is spending time near people who have the illness (whether they know they are infected or not).  These droplets may also settle on nearby surfaces.  There is currently some debate on how long these droplets may remain airborne (https://www.latimes.com/world-nation/story/2020-07-04/coronavirus-airborne-spread); however, it is clear that while they do not travel far and they only remain viable for a limited amount of time, it is still possible for workers to be exposed to Coronavirus from contact with contaminated surfaces.  With this in mind, routine or periodic cleaning and disinfection are an important part of an overall workplace Coronavirus safety program, along with hand washing, social distancing and source control measures such as mask use.   Additional cleaning and disinfection can be considered in work areas if one or more workers contract Coronavirus.

According to guidelines from the Centers for Disease Control (CDC) at https://www.cdc.gov/coronavirus/2019-ncov/community/reopen-guidance.html, the first step to disinfect a surface is cleaning with soap and water to remove dirt and dust and to reduce the amount of virus on the surface.  This should be followed by application of an approved disinfectant by wiping, spraying or fogging, consistent with manufacturer instructions.  Carpets or fabric that cannot be cleaned with soap and water can be HEPA-vacuumed, laundered or similar. The approach can be tailored to each workplace; however, to be effective, disinfection practices should be consistent with CDC guidelines.  Vendors marketing disinfection without cleaning may not be complying with CDC guidelines

Additionally, ACTenviro is happy to provide professional assistance to any infectious disease questions or concerns. Whether it is proactive or reactive, our team of highly qualified technicians are fully equipped for infectious disease facility decontaminations.

Cleaning should address areas and surfaces that are potentially contaminated.  Droplets typically travel 6 feet or less before settling on nearby surfaces, which limits areas that need to be addressed.

  • Typical surfaces include high-traffic areas such as floors, counters, tables, furniture, doors, items on open desks and walls (up to approximately 6 feet).
  • Other areas to address include high-touch surfaces such light switches, doorknobs or faucets.

Elevated or inaccessible areas are not likely to be contaminated and should not be cleaned.

  • For this reason, gas “bombs”, fumigation and similar approaches are not needed, and may not comply with CDC guidelines which require cleaning prior to application of disinfectant.
  • Similarly, because the particles do not travel far and are only viable for a limited amount of time, cleaning and disinfection of ducts, filters and other HVAC equipment is generally not necessary.

Other areas that may require cleaning but not disinfection include objects that are not frequently touched, outdoor areas, and areas that have not been occupied for seven days or more.

Once clean, an approved disinfectant should be applied to surfaces by wiping, spraying or fogging, consistent with manufacturer instructions.  Workers should use appropriate personal protective equipment (PPE), such as gloves and eye protection, and it is important that cleaners and disinfectants be prepared and used as indicated by manufacturers.  Once disinfectants are applied to a surface, they should be left on the surface for the designated “contact time” or allowed to dry on the surface.

Once complete, the area is cleaned and disinfected and ready to be re-occupied!

Stay tuned for our next post where we will talk about EPA List N, approved disinfectants and how to find out if the product that you are using appropriate for covid-19 decontamination.

We will follow that up with a final post in this 3-part series that looks at validation and how to make sure that your cleaning and decontamination process is effective.

Flexible Online Options for Workplace Safety and Environmental Compliance Training

Now more than ever, we are learning that going to work can look different for everybody. With adjusted in-office employee schedules for the foreseeable future, we understand companies need flexible options for workplace safety and environmental compliance training. At ACTenviro, our training options embrace the idea that training doesn’t always have to take place in the office. Whether it’s in-person, live webinars, web-based training, or a combination of each, we can create the perfect program for your team. Click the here to get started.

Use of “Face Coverings” and Compliance with OSHA Respiratory Protection Standard

As federal, state and local governments advocate (and in some cases require) the use of cloth “face coverings” as a Covid source control measure, many businesses have questions about the regulatory compliance implications and whether use of face coverings is subject to the same requirements as use of respirators at work.

The OSHA respiratory protection standard (29 CFR 1910.134) establishes employer requirements when employees use respirators at work.  Regulatory requirements are identical under the Cal/OSHA respiratory protection standard (8 CCR 5144).  For OSHA, and Cal/OSHA, the term “respirator” refers to personal protective equipment (PPE) intended to protect the worker from inhalation exposures to hazardous materials (gas, vapor or particulate).  In all cases, respirators must be certified for their intended use by the National Institute of Occupational Safety and Health (NIOSH).

Since face coverings are not respirators, use of face coverings at work is not subject to the requirements of the OSHA respirator standard, even if use of face coverings is required by the employer.

It is possible for workers to use disposable N-95 “filtering facepiece” respirators (or other “real” respirators) as a “face covering”.  In this case, the N-95 (or other respirator) is still being worn for source control purposes, not personal protection.

  • This assumes the wearer is allowed by their employer to wear other face coverings and is choosing to wear the N-95 (or other respirator).
  • If this use of a respirator is permitted (but not required) by an employer, then the employer would be subject to the OSHA requirements for “voluntary use” of respirators.
  • Voluntary use of filtering facepiece respirators (like N-95s) does not require a written respirator program, training, medical surveillance or fit testing, but employers do need to provide respirator wearers with the information in Appendix D of the respirator standard (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134AppD)
  • In addition to the appendix D information, if employers allow voluntary use of tight-fitting respirators (such as ½-face or full-face air purifying respirators), they must also provide medical evaluation to the wearer (but no written program or fit testing), so many employers choose not to allow voluntary use of tight-fitting respirators.

Where N-95s (or other respirators) are used on a voluntary basis as a source control measure, and the respirators do not need to maintain any certification or qualifications, the respirators can be cleaned and/or re-used as appropriate, based on hygiene, physical condition and similar considerations.

If employers require employees to use N-95 respirators (or any other respirator) for covid-control (or for any other purpose), then the voluntary use provisions no longer apply and the employer is subject to the applicable requirements of the respiratory protection standard, including written program, training, medical surveillance, fit testing, etc.

  • One covid-related example would be work activities in medical facilities, where workers are in close proximity to Covid patients and where workers are using respirators for their own health protection.

Do you have any questions about respiratory protection and Covid?  Or about respirator use in general?  Or any other workplace safety or environmental compliance issues?

Contact [email protected]

James Kapin, MPH, CIH, CSP
Director of EM Services,
ACTenviro

California Environmental Compliance Deadlines under Covid-19 Lockdown

Like all businesses, hazardous waste and universal waste generators and handlers in California are impacted by the current coronavirus crisis and many are struggling to comply with the various hazardous waste and environmental compliance deadlines as they also manage the challenges associated with stay-at-home orders, working from home and social distancing.  Conducting weekly waste area inspections can seem like a low priority when we are trying to keep our business functioning while keeping our workers safe.

Unfortunately, the various public health orders and recommended practices that have been established to “flatten the curve” have not changed the underlying EPA and DTSC regulatory requirements.  All California hazardous waste generators are still expected to comply with applicable satellite accumulation area (SAA) and central accumulation area (CAA) requirements as well as requirements to update their hazardous materials business plan (HMBP) in the California Environmental Reporting System (CERS), to ensure workers stay current on hazardous waste training, to comply with applicable tiered permitting requirements and to satisfy other environmental responsibilities.

Most CUPAs and PAs take a practical, pragmatic approach and it is likely that they will show flexibility and understanding during future inspections, however the expectation from DTSC, Cal/EPA and EPA is that all parties will comply with applicable requirements.  For example the DTSC (https://dtsc.ca.gov/wp-content/uploads/sites/31/2020/04/DTSC-EERD-COVID-19-Guidance_4-06-20_a.pdf)  recognizes the hardships created by coronavirus control measures but states that:

“Hazardous waste generators, transporters, electronic waste handlers, and tiered permit facilities must comply with all statutory and regulatory requirements”

If compliance is not possible, the DTSC guidance document says that waste generators and others should document the specific requirement, why the delay occurred and what is being done to return to compliance.  There is also a procedure to request an extension to hazardous waste accumulation time periods for up to 30 days from the EPA (for RCRA wastes) of from the local CUPA (for non-RCRA wastes).

This approach is consistent with guidance from Cal/EPA (parent organization of the DTSC) at https://calepa.ca.gov/2020/04/15/calepa-statement-on-compliance-with-regulatory-requirements-during-the-covid-19-emergency/ which confirms the importance of environmental protection (through regulatory compliance).  Cal/EPA recognizes covid-related hardships but avoids blanket exemptions and instead states:

“Specific time-delimited remedies, such as the extension of deadlines, may be warranted under clearly articulated circumstances…”

So the bottom line from California environmental regulators is that generators can apply for exemptions or extensions under limited circumstances but that they need to do everything they can to dispose of their waste in a timely manner and comply with other applicable requirements, even under these challenging circumstances.

At ACTenviro, we will do whatever we can to support you through these tough times.  Please let us know how we can help – reach out any time at [email protected]

James Kapin, MPH, CIH, CSP
Director of EM Services

New OSHA (and Cal/OSHA) Guidance on use (and re-use) of N-95 “Filtering Facepiece Respirators”

N-95 dust masks are considered “filtering facepiece respirators” (FFRs) by OSHA and use of FFRs at work (as well other types of respirators) is regulated by the OSHA respiratory protection standard (29 CFR 1910.134).  This standard, along with associated enforcement guidance and interpretations, limits the service life and re-use of FFRs and requires that all FFRs used for worker protection have current NIOSH certification.  Recent guidance from OSHA (https://www.osha.gov/memos/2020-04-03/enforcement-guidance-respiratory-protection-and-n95-shortage-due-coronavirus) temporarily relaxes some of those requirements as healthcare providers and others struggle with limited supplies.  This is in addition to emergency actions from the FDA to increase access to respirators (https://www.fda.gov/media/136403/download), including allowing use of some respirators certified outside the U.S. and authorizing use certain industrial respirators to be used in healthcare settings.

Remember – members of the general public are encouraged (and in some cases required) to wear face coverings when in public.  These face coverings are intended to prevent the wearer from inadvertently spreading contamination, they are not intended as personal protective equipment.  In order to preserve as many respirators as possible for healthcare providers and others who need them, FFRs should not be used as face coverings.  If respiratory protection needed for worker protection (not social distancing) outside of healthcare, employers should use non-disposable respirators wherever possible, consistent with applicable OSHA standards.

Fed OSHA Guidance on Extended Use and Re-Use

The recent OSHA guidance suggests that employers maximize use of engineering and administrative controls as well as re-usable types of respirators.  If these are not sufficient, OSHA will allow extended use and/or re-use of an FFR by the same worker if the respirator is physically intact, structurally sound and not excessively soiled or contaminated.

  • Employers should develop procedures for storage and for donning/doffing potentially contaminated FFRs if they are being re-used
  • Workers should be instructed that if seal checks cannot be performed successfully, the respirator should no longer be used
  • Employers who need to extend use or re-use should update their written respiratory protection plan (RPP) as needed to address these issues and to describe circumstances under which a disposable respirator will be considered contaminated and not available for extended use or reuse

If other options are not available, the OSHA guidance also allows use of certain respirators that have passed the manufacturer shelf life, as long as they pass a visual inspection and as long as they are not used for certain high-risk surgical procedures (see list of respirators at https://www.cdc.gov/coronavirus/2019-ncov/hcp/release-stockpiled-N95.html).

Cal/OSHA Guidance on Extended Use and Re-Use

The situation is similar in California.  The Cal/OSHA respiratory protection standard (8 CCR 5144) is similar to the fed OSHA standard (including restrictions on extended use and re-use of disposable respirators), however healthcare facilities in California also have to comply with the provisions of the aerosol transmissible disease (ATD) standard (8 CCR 5199).  Recent Cal/OSHA guidance (https://www.dir.ca.gov/dosh/coronavirus/Cal-OSHA-Guidance-for-respirator-shortages.pdf) allows similar flexibility for extended use or re-use of FFRs in order to conserve respirator supplies, as long as the details are captured in an updated RPP.  In addition, for healthcare facilities regulated under the ATD standard, Cal/OSHA allows surgical masks to be used instead of respirators under limited circumstances and for lower hazard medical tasks if FFRs or other types of respiratory protection are not available.

Do you have any questions about respiratory protection and Covid?  Or about respirator use in general?  Or any other workplace safety or environmental compliance issues?

Contact [email protected]

James Kapin, MPH, CIH, CSP
Director of EM Services,
ACTenviro

As an Essential Service Provider, ACTenviro Remains Open for Business

ACTenviro is here for you during this unprecedented and uncertain time. Our top priority is to continue to provide environmental services and emergency response needs to support your business and team’s safety. As an essential service provider during a pandemic response, ACTenviro is here to provide you with the following additional services:

  • Preventative Decontamination Services
  • COVID-19 Decontamination Services
  • Providing field oversight of a contractor’s decontamination/sanitization activities
  • 24/7 Emergency Response Services
  • Environmental, Health, and Safety Consulting Services
    • Back-Up HazMat Technician
    • Back-Up EH&S Roles
  • Web-Based Training
    • RCRA Hazardous Waste Awareness (basic)
    • CA Hazardous Waste Awareness (basic)
    • CA Hazardous Waste Management (advanced)
    • DOT for Signing a Manifest
    • Medical Waste Management
    • Other environmental compliance and OSHA workplace safety classes
  • Continued Onsite Services with open communication
    • Federal Regulations l Regulatory Compliance

Please email [email protected] or call (866) 333-9222 for more information. Or request a free quote here.

New Hazardous Materials Release Reporting Rules from the Chemical Safety Board

The US Chemical Safety and Hazard Investigation Board (CSB) adopted new regulations (40 CFR part 1604) for reporting releases of hazardous materials, effective March 23, 2020. Under the new regulation, businesses must report any spills or releases that result in a death, serious injury, or substantial property damage to CSB within 8 hours. For those who have been following this issue, this is a change from the proposed regulation, which required reporting within 4 hours. Where applicable, multiple owners or operators may provide a consolidated report to CSB, as long as all reporting requirements are met. This initial report can be revised as needed for a 30 day period following the release. See https://www.federalregister.gov/documents/2020/02/21/2020-02418/accidental-release-reporting for more information.

What needs to be reported
The report should contain the following:

  1. The name of, and contact information for, the owner/operator;
  2. The name of, and contact information for, the person making the report;
  3. The location information and facility identifier;
  4. The approximate time of the accidental release;
  5. A brief description of the accidental release;
  6. An indication whether one or more of the following has occurred:
    1. fire;
    2. explosion;
    3. death;
    4. (serious injury; or
    5. property damage.
  7. The name of the material(s) involved in the accidental release, the Chemical Abstract Service (CAS) number(s), or other appropriate identifiers;
  8. If known, the amount of the release;
  9. If known, the number of fatalities;
  10. If known, the number of serious injuries;
  11. Estimated property damage at or outside the stationary source;
  12. Whether the accidental release has resulted in an evacuation order impacting members of the general public and others, and, if known:
    1. (1) the number of persons evacuated;
    2. (2) approximate radius of the evacuation zone;
    3. (3) the type of person subject to the evacuation order (i.e., employees, members of the general public, or both).

If a report has already been made to the National Response Center (NRC) due to 40 CFR 302.6 reporting requirements and additional report does not need to be made to the CSB. Instead the CSB reporting requirement may be satisfied by submitting the NRC identification number to the CSB within 30 minutes of submitting a report to the NRC.

Why are these requirements needed
The CSB was required to create accidental release reporting requirements as part of Clean Air Act A(CAA) amendments in 1990. Initial rulemaking was started, but never completed and instead, CSB has relied on existing EPA release reporting requirements for notification. The current rulemaking originates from a recent lawsuit from environmental groups that led to a court order for the CSB to create a new release reporting regulation by 2020.

Note that the CSB reporting requirements apply to spills or releases that result in a death, serious injury, or substantial property damage and state or local regulators may have lower thresholds for release reporting or require notification for spills that do not need to be reported to the CSB or NRC.

If you have any questions about this, or any other environmental or workplace safety requirements, please contact us at [email protected].

– James Kapin, MPH, CIH, CSP
Director of EM Services