2026 September - EHS Regulatory Update

>> Click Here to View 2026 September Regulatory Updates <<

This month's update reinforces an important EHS leadership principle: regulatory requirements may evolve, but our responsibility to recognize serious risk, maintain effective safeguards, and verify that those safeguards are working remains constant. 

A few items worth your attention:

• The latest CSB findings provide an important process safety reminder. Following a fatal explosion at a Pennsylvania coke facility, the CSB emphasized the importance of facility siting and ensuring that occupied buildings provide adequate protection from fires, explosions, and toxic releases. For those operating process facilities, this is a worthwhile reminder to periodically challenge whether our occupied spaces remain appropriately located and protected as operations change over time.
• OSHA continues its emphasis on proactive enforcement. The agency has extended its Warehousing and Distribution Center Operations National Emphasis Program through 2031, following extensions of other emphasis programs addressing hazardous machinery and heat illness. This reinforces the importance of maintaining inspection readiness even in facilities with strong safety performance and no recent triggering event.
• Workplace violence prevention continues to receive increased attention. The September 15 webinar included in this month's update provides an opportunity to better understand emerging requirements and prevention strategies. Although much of the discussion will focus on California, the broader lessons and best practices may be useful for organizations evaluating their own programs.

 On the environmental and transportation fronts, EPA's upcoming RCRA activity deserves attention, particularly potential changes involving PFAS, electronic manifests, lithium batteries, and solar panels. The transportation resources also provide useful reminders regarding hazmat shipping documentation and the potentially severe consequences of lithium battery incidents.

 Leadership takeaway:
Strong EHS leadership requires us to look beyond whether a requirement is technically being met and ask a more important question: Are the people exposed to our highest-consequence hazards actually protected if something goes wrong? Regulations establish a baseline; effective risk management requires us to continually test whether our safeguards remain adequate in the real operating environment.

 Question for consideration:
Where in your operation could you be fully compliant on paper, yet still have an exposure that could produce serious consequences if one critical safeguard failed?

As always, I welcome your questions, observations, and suggestions for future EHS Committee discussions.

With appreciation,
David
 
David J Neely, MS, CSP (Emeritus)
PCA EHS Committee Technical Support
Cell: 740.258.4605

Stay visible. Stay curious. Stay engaged.