2026 November - EHS Regulatory Update

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Important compliance deadlines, regulatory developments, and a critical lesson about acting on known hazards. 

Colleagues,

Attached is the November 2026 EHS Regulatory Update, highlighting several important regulatory developments, upcoming compliance deadlines, and lessons learned that deserve our attention.

A few items worth noting:

• OSHA Hazard Communication: The November 20, 2026, employer compliance deadline for substances is approaching. Facilities should verify that applicable workplace labeling, written programs, and employee training requirements have been addressed.
• Transportation: The lithium battery marking transition concludes December 31, 2026, with revised marking requirements taking effect January 1, 2027.
• Process Safety: The CSB's investigation into the fatal Nippon Dynawave storage tank failure raises a particularly important question: When inspections identify equipment operating below minimum safe conditions, what ensures corrective action is taken before a failure occurs?

The update also covers OSHA enforcement priorities, EPA regulatory developments, and additional CSB findings relevant to chemical manufacturing operations. 

I encourage you to take a few minutes to review the attached update and consider which developments may warrant attention at your facilities. 

As always, your comments, questions, and suggestions for future updates are welcome. 

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

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