NPGA Opposes New OSHA Label Proposal |
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NPGA advocated for improvements to a proposal by the Occupational Safety & Health Administration (OSHA) that would modify the Hazard Communication Standard (HCS) to align with the international Globally Harmonized System (GHS). Among the modifications, OSHA proposed to codify a Memorandum of Understanding between the agency and the U.S. Department of Transportation (DOT) regarding HCS labels on bulk containers, like cargo tanks. OSHA also proposed to revise HCS labels to feature a “Released for Shipment” date as well as modify the wording for flammable gases in the Prevention and Response categories relative to possible ignition sources. NPGA urged the agency to eliminate or adjust language in the proposed regulatory text to avoid confusion and unnecessary burden on downstream propane companies.
NPGA shared significant concerns regarding the proposed addition of a shipment date component for HCS labels. OSHA intends for a shipment date to assist in circumstances where chemicals are held for long periods of time before shipment and chemical manufacturers identify new hazards for the chemical. NPGA argued, however, that the supply chain for products like propane experience significant turnover such that the chemicals do not sit for extended periods time. In fact, there is considerable product turnover in the propane industry with millions of cylinders and larger containers serving residential, agricultural, construction, motor fuel, and kitchen purposes. If finalized as proposed, propane businesses may be required to relabel containers with a new Released for Shipment date at each filling despite the lack of any new information on the hazards associated with propane. In addition to opposing the new component, NPGA proposed alternative regulatory text to narrow when a shipment date would be necessary. NPGA communicated with other gas industries in developing a response to the agency.
NPGA also led a coalition of hazardous materials industries to clarify the roles and requirements of OSHA’s HCS labels and the labeling, marking, and placarding requirements of DOT. During OSHA’s last revision to HCS in 2012, NPGA joined other hazardous materials to delineate the jurisdiction and requirements between OSHA and DOT. NPGA identified possible points of confusion in the regulatory text recently proposed by OSHA that intended to codify the Memorandum of Understanding between the agencies. Further, NPGA urged OSHA to incorporate DOT’s definition of “bulk packaging” rather than the proposed definition of “bulk shipment.” We recommended utilizing DOT’s definition for clarity across the agencies and regulations.
Please address questions or comments to Sarah Reboli, NPGA Senior Director, Regulatory & Industry Affairs.
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Join us June 23-25 as we return to the beautiful and historic French Lick Resort. The IPGA Convention will fast become a can’t-miss tradition offering valuable and timely propane-focused education as well as opportunities to network with industry colleagues and friends.
IPGA is asking for your help to make this special event a success. We are offering a variety of sponsorship opportunities for you to showcase your company. Click here to learn more. Sponsorship registration deadline is June 2, 2021.
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By Meteorologist John Bagioni, Fax-Alert Weather Service, LLC
As we close out May and head into the first full month of summer, the large- scale pattern continues to suggest warmer than normal departures will win-out overall, but some cool shots will come into play from time to time.
Nothing I have seen to date, be it in modeling trends or in the actual pattern alignment, leads me to believe an overly hot summer season will occur this year.
Yes, there will be some hot periods, and maybe even a noteworthy one prior to the end of June. But I continue to believe we are looking at a modestly warmer than normal summer season with a bit of a back-and-forth tenor to the pattern. Cooling will occasionally come along to break the back of any hot stretches. Click here for the full report.
Meteorologist John Bagioni | FAX-ALERT WEATHER SERVICE, LLC
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Participate in the NPGA 2021 Annual Meeting Virtually |
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The materials for the NPGA 2021 Annual Meeting and Summer Board of Directors meeting on Tuesday, June 8th are ready for your review in advance of the meetings and can be found by clicking here. To register for the meetings, see the preliminary agenda, and find hotel information, please click here.
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Resources for National Safety Month in June |
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In addition to the social media content to share with your customers, it’s also a great time to make sure your employees are taking advantage of all the safety training courses conveniently located online in the Learning Center. Let’s make safety priority #1 in June.
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The Indiana Propane Gas Association is pleased to announce the 2021 Employee Training schedule. IPGA offers certified and non-certified employee training for those employed in the propane industry or looking to obtain propane training certification. To make training more accessible to everyone, classes are held in multiple locations. Classes are open to members and non-members and pre-registration is necessary. Consider sending your employees to this valuable training. Click here to learn more.
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Join P3 for the Safety Summit |
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Virtual Safety, Compliance, and Data Management Event
Mark your calendar for the virtual P3 Safety Summit on June 10, 2021. The P3 Safety Summit will provide an opportunity to take a deep dive into P3’s safety documentation and regulatory compliance system. The P3 Safety Summit will include webinars held from 12:00 p.m. to 5:00 p.m. covering a range of safety, compliance, and data management topics and is open for current P3 users and non-P3 users to attend for free.
Click here to sign up to attend the P3 Safety Summit.
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Complete the Annual Retail Propane Sales Report by Monday |
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PERC is partnering with Frost & Sullivan to conduct its annual retail propane sales report. All propane retailers were sent an email invitation from 2020salesreport@frost.com and/or salesreport@propane.com with a unique link to complete their company’s report.
If you are unsure who at your company received this invitation or if you did not receive it, please contact Rachel Greenberg, PERC’s Senior Market Research Analyst, at rachel.greenberg@propane.com or 202-452-8975.
Why is this important?
- Ensure our state receives an accurate amount of state rebate funding from PERC. These funds support great projects in our state that directly benefit your business operations and growth.
- This is the only report that studies market trends in our state and region and can be used to help your business explore new opportunities.
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President's Council Members |
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The information contained herein is provided as a service by the Indiana Propane Gas Association (IPGA) for the purpose of education, communication, and information and IPGA accepts no liability relative to the contents, accuracy or use of these services. Nothing in this publication is intended to be construed as legal advice. The user is strictly cautioned to seek legal assistance when attempting to determine any legal rights, responsibilities and procedures with respect to business affairs, coding, or other legal aspects of operating a propane company. IPGA disclaims any and all liability for injury and/or other damages which result to a user from the material offered or discussed herein. |
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