May 28, 2021
NPGA Opposes New OSHA Label Proposal
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. 
May 31 Deadline: Annual Retail Propane Sales Report
The deadline to complete the Annual Retail Propane Sales Report is fast approaching. All propane retailers were sent an email invitation from Rachel Greenberg, PERC’s Senior Market Research Analyst, with a unique link to complete their company’s report. If you are unsure who at your company received the invitation or if you did not receive it, please contact Rachel Greenberg, at 202-452-8975. All submissions are due by May 31st! 
 
Why is the Annual Retail Propane Sales Report important? 
  • Ensures the Pacific region receives an accurate amount of state rebate funding from PERC. 
  • Funds successful projects in the Pacific region that support your business operations and growth. 
  • Studies market trends in your state, region, and country to support your business. 
Don’t let other states take funding away from the Pacific region! File your report TODAY! 

Learn more at propane.com/salesreport. Please submit your report today! 
PPGA 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.
Participate in the NPGA 2021 Annual Meeting Virtually
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. Click here for the agenda for the Board meeting. 

To register for the meetings, see the preliminary agenda, and find hotel information, please visit the event page.
Resources for National Safety Month in June
June is National Safety Month, which is the perfect time to share safety information with your customers using PERC’s collection of safety social content available in the resource catalog. The collection of social content provides safety-focused assets for you to post directly on your own social media channels. The content includes social-media-ready safety videos  and image posts designed for a variety of markets, including commercial, forklift, autogas, and more. To help you get started, there is also a downloadable guide  that will make posting the assets to your social channels simple. 
 
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. 
Save the date for the PPGA Annual Conference and WPGA Chairwoman’s Board Meeting, October 27-29, 2021. Registration coming soon.

PPGA 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 and we are also accepting donations for the PPGA Dick Start Scholarship Chance Auction taking place at the conference. Learn More and Register Online.

Accommodations are available at Kauai Beach Resort and special discounted rates are available for conference guests. Please be aware these rooms are limited so reserve yours early. More Information
P3 Virtual Safety Summit
Thursday, June 10 | 9:00 p.m. – 2:00 p.m. PT
You're invited to the P3 Virtual Safety Summit! Join us for an afternoon of free webinars that will provide a deep dive into the P3 safety documentation and regulatory compliance system. Created to be a valuable resource for P3 users and non-P3 users, the P3 Safety Summit will cover a range of safety, compliance, and data management topics hosted by industry experts. 
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The information contained herein is provided as a service by the Pacific Propane Gas Association (PPGA) for the purpose of education, communication, and information and PPGA 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. PPGA disclaims any and all liability for injury and/or other damages which result to a user from the material offered or discussed herein.