Home / News / Regulatory Updates / SCAQMD Rule 462: Organic Liquid Loading

SCAQMD Rule 462: Organic Liquid Loading

February 24, 2026

Applicability and Purpose

On August 1, 2025, the SCAQMD adopted amendments to Rule 462, which regulates VOC emissions during the transfer of organic liq-uids with a true vapor pressure of 1.5 pounds per square inch absolute (psia) or greater (e.g., gasoline and ethanol) into tank trucks, trailers, and railcars. The rule also establish-es contingency measures for appli-cable ozone standards for the reduc-tion of VOCs.

Lower VOC Limit for VR Systems

Under Rule 462 Section (d)(1)(D), the allowable VOC emission rate from vapor recovery (VR) and disposal systems at large loading facilities (“Class A” facilities that load more than 20,000 gallons per day) was reduced from 0.08 pound (lb) to 0.04 lb per 1,000 gallons of organic liquid transferred. According to the SCAQMD, the amendment to lower the VOC emission rate formalizes best performance, since the source testing data reviewed by the SCAQMD during rulemaking re-portedly showed that most facilities were already meeting the new limit. Permit modifications incorporating the new limit are due by February 1, 2027 [Rule 462 Section (e)(1)(C)].

New 5-Year Source Testing Requirement

To verify ongoing compliance, each Class A facility must conduct peri-odic source tests every 60 months using United States Environmental Protection Agency (U.S. EPA) or SCAQMD-approved methods [Rule 462 Section (f)(8)]. Facilities that are not already conducting periodic source tests must submit a source test protocol by August 1, 2026, and complete testing by August 1, 2027.

Monthly OGI Inspections

Beginning August 1, 2026, Class A and B facilities (i.e., facilities that load more than 4,000 gallons per day) must perform monthly optical gas imaging (OGI) inspections to detect fugitive VOC emissions [Rule 462 Section (d)(6)]. Each detection of a vapor or liquid leak must be addressed within 3 days, and re-paired or replaced components must be reinspected.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / CARB CTR Phase 3

CARB CTR Phase 3

February 24, 2026

Background

Assembly Bill (AB) 617 created the Criteria and Toxics Reporting (CTR) Regulation, California’s uniform statewide system for annual emissions reporting of criteria pollutants and toxic air contaminants (TACs). CTR became effective January 1, 2020, and has been phasing in by air district group and sector. CTR identifies which facilities must report based on greenhouse gas (GHG) reporting, criteria pollutant emissions, elevated toxics risk, or specific permitted processes. CTR requirements are submitted as part of each air district’s annual emissions reporting program.

New for DY2025

Beginning with data year (DY) 2025, Phase 3 of the California Air Resources Board’s (CARB’s) CTR Regulation applies to Additional Applicability Facilities in District Group A, which includes the South Coast Air Quality Management District (SCAQMD), San Diego County Air Pollution Control District (SDAPCD), San Joaquin Valley Air Pollution Control District (SJVAPCD), Imperial County Air Pollution Control District (ICAPCD), Sacramento Metropolitan Air Quality Management District (SMAQMD), and Bay Area Air District. Facilities with Phase 3 permitted processes that meet the activity thresholds listed in CTR Appendix A, Table A-3 must now report emissions or activity data, even if they have not reported to local air districts before. Examples of Phase 3 permitted processes now subject to reporting for District Group A include:

• Cremation of Humans or Animals;
• Fiberglass Manufacturing;
• Semiconductor Manufacturing;
• Oil and Gas Extraction and Production;
• Metal Melting and Foundries;
• Long-Term Asbestos Removal; and
• Large Natural Gas or Propane Combustion [≥ 75 Million Standard Cubic Feet (MMSCF) or 77,000 Million British Thermal Units (MMBtu) per Year].

Permitted facilities are required to submit emissions inventory reports to document criteria air pollutants and TAC emissions to local air districts. For facilities in the SCAQMD, emissions reports are due May 1, 2026, for the previous year’s emis-sions. Due dates for other air districts may vary.

Coming in DY2026

Beginning with DY2026 and subsequent years, District Group A facilities subject to Phases 1, 2, and 3 must report additional TACs listed in CTR Appendix B, Table B-3 . Facilities in Phases 1, 2, and 3 should prepare to quantify criteria pollutants and TACs for DY2026 reporting.

District Group B facilities are subject to Phase 3 beginning with DY2027.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / SCAQMD Rule 1171: Solvent Cleaning Operations 

SCAQMD Rule 1171: Solvent Cleaning Operations

February 24, 2026

Applicability and Purpose

On June 6, 2025, the SCAQMD amended Rule 1171. Rule 1171’s purpose is to reduce volatile organic compounds (VOCs), TACs, and stratospheric ozone-depleting compounds from solvent cleaning operations. Rule 1171 applies to anyone who uses cleaning solvents in the SCAQMD.

Rule 1171 Amendments Overview

Rule 1171’s amendments include the phasing out of para-Chlorobenzotrifluoride (p-CBtF) and tert-butyl acetate (t‑BAc), establishing VOC content limits for energy curable printing of lamps and reflectors, and establishing alternative usage limits for electricity and water utilities and aerosol cleaning.

Rule 1171’s amendments will affect facilities using solvent cleaners containing p-CBtF or t-BAc, suppliers and distributors of cleaning solvents with p‑CBtF or t-BAc, automotive refinishing shops, electric/water utility providers, and energy curable printing
operations.

Table 1 of Rule 1171 sets the VOC content limits, Table 2 sets the alternative usage and product weighted-maximum incremental reactivity (PW-MIR) limits for electrical and water utilities, and Table 3 of the rule sets the usage limits of solvent cleaner usage for solvent cleaning of automobile parts, batteries, and other solvent cleaning activities.

Rule 1171 Deadlines

There are three important dates in Rule 1171 for the p-CBtF and t-BAc phase-out. Solvent cleaning materials manufactured after January 1, 2026, and containing more than 0.01% by weight of p‑CBtF and t-BAc cannot be used for solvent cleaning activities. Solvent cleaning materials manufactured prior to January 1, 2026, containing more than 0.01% of p-CBtF and t‑BAc can be sold or supplied until July 1, 2027, and used until July 1, 2028.

Other Rules Affected

Similar to Rule 1171’s amendments to phase out p-CBtF and t-BAc from solvent cleaning materials subject to Rule 1171, the SCAQMD is in the process of amending other source-specific rules to phase out p-CBtF and t-BAc, including Rule 1107 (Coating of Metal Parts and Products), Rule 1124 (Aerospace Assembly and Component Manufacturing Operations), Rule 1113 (Architectural Coatings), Rule 1122 (Solvent Degreasers), and Rule 1130 (Graphic Arts), among others.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / New EPA Refrigerant Regulations

New EPA Refrigerant Regulations Under 40 CFR Part 84 Subpart C: Implications for the Refrigerant Industry

June 02, 2025

On December 10, 2024, the U.S. Environmental Protection Agency (EPA) implemented updates to its refrigerant management rules under 40 Code of Federal Regulations (CFR) Part 84 Subpart C. These updated regulations impose stricter limits on the use of reclaimed refrigerants and set lower compliance thresholds. The rule becomes fully effective on January 1, 2026, but businesses should begin preparing now to meet these standards.

Key Updates Under the New EPA Refrigerant Regulations

Effective January 1, 2026, the new regulations under 40 CFR Part 84 Subpart C introduce several key changes. Below are the most significant updates:

1. Lower Refrigerant Thresholds: The new rule sets lower thresholds for refrigerant amounts in stationary refrigeration systems that trigger regulatory requirements. Facilities that contain 15 pounds or more of refrigerants with a Global Warming Potential (GWP) greater than 53 will now be subject to the updated regulations. This makes the EPA’s regulations stricter than California’s current threshold, which remains at 50 pounds.
   • Many commonly used hydrofluorocarbons (HFC) refrigerants – such as R-134a (GWP 1430), R-404A (GWP 3922), and R-410A (GWP 2088) – fall into the category of refrigerants with a GWP higher than 53. With the new thresholds, businesses using these refrigerants may now find themselves subject to the federal rules, even if they previously did not meet the threshold.
2. Starting in 2025, restrictions will be placed on the use of HFCs with higher global warming potentials (GWPs) in new aerosols, foams, and refrigeration, air conditioning, and heat pump equipment.
3. Beginning in 2026, there will be new requirements for fire suppression systems, including required training, recycling, and reporting requirements.
4. Updated Leak Detection Requirements: As of January 2026, the EPA will require automatic leak detection systems in facility refrigeration systems with 1,500 pounds or more of refrigerant with a GWP greater than 53. This is a lower threshold compared to the 2,000 pounds or more refrigeration system limit set by the California Air Resources Board (CARB) for systems using refrigerants with a GWP greater than 150. The new leak detection requirements mean that more facilities will need to install and maintain automatic leak detection systems, adding a layer of compliance responsibility for a larger number of refrigerant-containing facilities.
5. Updated Leak Rate Determination and Repair Requirements: As of January 2026, any time refrigerant is added to an appliance – except in cases of retrofits, new appliance installations, or seasonal variances – the equipment is required to undergo a leak rate check. The leak rate can be calculated by an annualized or rolling average method. If the leak rate is over 20% for commercial refrigeration appliances, 30% for industrial process refrigeration requirements, or 10% for comfort cooling, transport, or other types of appliances not covered by the other two types, then:
   • The facility must identify and repair the leak within 30 or 120 days of detection;
   • The equipment must undergo a verification test within 30 or 120 days to indicate the repairs were successful;
   • The facility must conduct a follow-up verification test within 10 days of the initial test; and
   • Follow-up leak inspections must be conducted as follows:
     • Every 3 months for units containing more than 500 pounds of refrigerant; or
     • Annually for units with 15 to 500 pounds of refrigerant; and
     • Inspections will continue until the leak rate no longer exceeds the threshold.

Alternative options, such as retrofitting or replacing leaking equipment, are also available. Equipment with leak rates over 125% of capacity are still required to report to the EPA by March 1^st of each year.

Additionally, refrigeration appliances are required to maintain records, including equipment information, date of installation, full charge, service, and repair records and other information, until 3 years after the appliance is retired. Furthermore, reporting is required for extensions to complete repairs, retire equipment, and when excluding purged refrigerants from annual leak rate calculations.

1. Reclamation Standard: Effective January 1, 2026, no refrigerant can be sold, identified, or reported as reclaimed if it contains more than 15% virgin-regulated substance by weight. Virgin-regulated substance refers to any refrigerant that has never been used in equipment (i.e., new, unused refrigerant). This threshold significantly reduces the amount of virgin refrigerant that can be included in reclaimed products, encouraging the use of recycled materials.

What These Changes Mean for CARB-Registered Refrigerants

The updated EPA regulations set stricter thresholds than CARB for refrigerant quantities and ALD systems. It also incorporates comfort cooling/heating, ventilation, and air conditioning (HVAC) systems. Units with over 15 pounds of refrigerants or with a high GWP will require tracking and reporting.

Reclaimed refrigerants must meet the new standard for virgin refrigerant content, which could affect how refrigerants are processed and resold.

For CARB-registered refrigerants, the new EPA rule creates a situation where the federal standard is stricter in terms of refrigerant quantities and leak detection thresholds. Companies will be expected to comply with both State and federal requirements, particularly in systems with small-to-medium refrigerant amounts. A leak detection system will be required for applicable refrigeration units. For units installed in 2026, the system must be operational upon installation; for existing units, the requirement takes effect by January 1, 2027, in accordance with 40 CFR 84.108(b). This introduces a new compliance benchmark that companies will need to plan for in advance.

___________________________

Yorke Engineering specializes in refrigerant management reporting and regulatory analysis, helping businesses navigate these evolving requirements. Whether it’s assistance with compliance strategies, regulatory analysis, or detailed reporting for EPA and CARB standards, our team is here to provide expert guidance and ensure businesses meet regulatory obligations efficiently.

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / New Federal PFAS TRI Reporting Requirements

California Facilities Face New Federal PFAS TRI Reporting Requirements 

March 28, 2025

Quick Facts:

• A facility is required to report under the Toxic Release Inventory (TRI) Program if it meets chemical activity thresholds and is either a covered industry sector (based on NAICS code) and exceeds the employee threshold, or specifically required to report based on a determination by the Administrator under the Emergency Planning and Community Right-to-Know Act (EPCRA) 313(b)(2).
• The United States Environmental Protection Agency (U.S. EPA) designated per- and polyfluoroalkyl substances (PFAS) “chemicals of special concern,” effective for Reporting Year (RY) 2024, which has a report due date of July 1, 2025.
• Effective for RY2024, de minimis exemption is no longer available for PFAS—even trace amounts of PFAS must now be assessed and reported by July 1, 2025.
• The addition of nine new PFAS chemicals for RY2025 is postponed until March 21, 2025, or later, but TRI PFAS reporting requirements for previously listed PFAS remain unchanged.
• California industries most impacted include industrial processing, manufacturing, mining, electric utilities, hazardous waste treatment, and petroleum terminals.

TRI Reporting Requirements

• Belonging to a covered industry sector, and then exceeding the employee threshold; or
• Specifically required to report, based on a determination by the Administrator under EPCRA 313(b)(2).

To determine whether a facility is covered under the TRI Program, the facility needs to verify whether its primary NAICS code is included under the list of 400 TRI-Covered NAICS Codes. Once verified, the facility determines whether it has at least ten full-time employees or equivalent. If the facility meets both the covered industry sector and the employee threshold, an assessment of chemical activity for TRI-listed chemicals is needed to determine whether TRI reporting is required.

1. Manufacturing;
2. Processing; and
3. Otherwise use.

Each category is assigned a different limit for each TRI-Listed Chemicals.

In general, the TRI reporting thresholds are 25,000 pounds (lbs) each for manufacturing and processing and 10,000 lbs for otherwise use. However, some of the TRI-Listed Chemicals are designated as “chemicals of special concern.” This includes Persistent Bioaccumulative Toxics (PBT) chemicals, which are assigned a much lower reporting threshold.

PFAS TRI Background

Beginning with RY2024, PFAS are designated as “chemicals of special concern.” Given the designation, many facilities that were not previously subject to TRI reporting yet meet both (a) the covered industry sector and (b) the employee threshold, will now be required to submit a TRI reporting of their PFAS releases. This change follows the elimination of the de minimis exemption, which had previously allowed facilities to omit reporting PFAS if they were found to be in small concentration, below the de minimis exemption. As a result, businesses must now track, assess, and report even a small concentration of PFAS, significantly expanding compliance requirements.  

Understanding these PFAS TRI updates, and the new impacts they impose on covered industry sectors, will be crucial for ensuring your facility is compliant.​ Facilities are advised to begin tracking PFAS usage and manufacturing activities starting January 1, 2024, to ensure readiness for the first reporting deadline, which is set for July 1, 2025. ​ In California, industries such as manufacturing, mining, utilities, and petroleum are among those most impacted. 

For RY2025, nine new PFAS chemicals will be added to the EPA TRI list, bringing the total to 205 PFAS chemicals. However, the EPA has delayed the effective date for the addition of these nine new chemicals until later in the year. While this postponement does not eliminate the reporting requirement for these new chemicals, it does provide facilities additional time to prepare.  

Three Actions Facility Operators Should Take Now

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / Bay Area Air District Requires Tier 4-Level Engines as BACT 

Bay Area Air District Requires Tier 4-Level Engines as BACT for Small- to Medium-Sized (<1000 hp) Emergency Engines

February 28, 2025

As of December 2, 2024, any permit application for a diesel emergency standby engine rated 50 brake horse-power (BHP) or greater now triggers Best Available Control Technology (BACT) requirements to meet Tier 4 emissions levels for combustion con-taminant emissions of nitrogen oxides (NOx), carbon monoxide (CO), precur-sor organic compounds (POCs) (non-methane hydrocarbons, or NMHCs), and particulate matter, as set by the U.S. EPA. The BACT and BACT for Toxics (TBACT) requirement is now Tier 4 and is consistent for all standby diesel generators 50 BHP and greater. BACT is required when a source of emissions has the potential to emit 10 or more pounds per day of a pollutant. TBACT is required for sources with an associated cancer risk greater than 1.0 in one million and/or a chronic hazard index greater than 0.20.

There are three ways that an engine may meet Tier 4 standards:

1. Be certified by the U.S. EPA to meet Tier 4 standards;
2. Be packaged by the equipment manufacturer with abatement equipment that brings the emis-sions levels to Tier 4 standards; or
3. Be a lower-tier engine with after-market abatement equipment from a third-party vendor.

All three methods are acceptable; how-ever, additional requirements, such as source testing, may apply if the engine is not certified to Tier 4 standards. Source testing may be required annu-ally, which is an additional cost that would be incurred by the operator. A retrofitted engine might also require usage restrictions on the hours of oper-ation for maintenance.

This change in BACT/TBACT levels applies to emergency engines, such as those that power backup generators or fire pumps. In cases where the equip-ment would need to meet National Fire Prevention Act (NFPA) Section 110, Level 1 (direct risk to human life) re-quirements, such as an engine driving a fire pump or used for backup gener-ation of medical life-sustaining sys-tems, an auxiliary emissions control device (AECD) may be installed on the Tier 4 engine to allow for the tempo-rary disabling of any emissions con-trols during a qualified emergency sit-uation. This is permitted per Code of Federal Regulations (CFR) Title 40, Chapter I, covering U.S. EPA and air pollution controls.

When choosing an engine for a project, these new limits should be taken into consideration. Limitations on the avail-ability of smaller (under 75 horse-power) Tier 4 engines for emergency use may require upsizing the engine to meet BACT requirements.

The Bay Area Air District has also pro-vided guidance on how to shorten the permitting time for these types of en-gines. Based on the engine’s proximity to a nearby receptor, location in an Overburdened Community, size, and hours of use, a health risk assessment (HRA) analysis may be avoided or “streamlined.” A streamlined HRA would still require public notice if the engine will be located in an Overbur-dened Community; however, it will shorten the overall permitting time from the typical full HRA.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / California Vehicle Electrification

California Vehicle Electrification

February 28, 2025

Updated Notice: On February 18th, the Office of Administrative Law (OAL) disapproved the amendments to the California Air Resources Board (CARB) Low Carbon Fuel Standard (LCFS) Regulation. On February 26th, CARB provided guidance that they will address the issues raised by OAL and resubmit the amended regulation within 120 days. The summary of the revisions below will likely remain in the amended regulation but will not go into effect until approved by OAL.

In 2006, the California Legislature passed the California Global Warming Solutions Act, Assembly Bill (AB) 32, creating a multi-year roadmap to greenhouse gas (GHG) emissions reduction in California. The first regulation passed under AB 32 to address transportation fuel emissions was the LCFS Program. The LCFS Program is designed to decrease the carbon intensity (CI) of transportation fuel in California. Annual CI benchmarks are lowered each year to encourage providers of transportation fuels to supply a lower-carbon mix. Use of lower CI fuels generates credits that can be sold on the open market. The LCFS Regulation was amended in November 2024 with the following changes:

• Increased the 2030 CI targets from 20% to 30%, with an immediate 5% cut in 2025;
• Extended the program to achieve 90% reduction target by 2045;
• Phased in some limits to bio-methane crediting;
• Reduced credits from electric forklifts;
• Required direct metering for electric forklift credits;
• Required third-party verification to electricity, hydrogen, and other fuels; and
• Expanded zero-emission vehicle (ZEV) infrastructure crediting opportunities.

The full proposed LCFS Regulation language is available at: https://ww2.arb.ca.gov/our-work/pro-grams/low-carbon-fuel-standard/lcfs-regulation

Several additional CARB rules have been enacted to reduce fossil fuel use, including the following:

• Advanced Clean Trucks (ACT): This rule is in effect and places ZEV sales requirements on manufacturers of heavy-duty trucks.
• Advanced Clean Cars II (ACC II): This legislation is in effect and requires all new passenger cars, pickup trucks, and sport utility vehicles (SUVs) sold in California to be ZEVs by 2035.
• Zero-Emission Forklift Regulation: Forklifts using large spark-ignition (LSI) engines are subject to phaseout for zero-emission versions (battery-electric and fuel-cell) starting in 2026.
• Advanced Clean Fleets (ACF): CARB withdrew their request for a U.S. Environmental Protection Agency (U.S. EPA) waiver for ACF for High-Priority or Drayage fleets. So, CARB is not enforcing the High-Priority and Drayage ACF rules. The ACF State and Local Government Agency (SLGA) rule is in effect and requires medium- and heavy-duty vehicles to start transitioning to zero-emission or near zero-emission technologies.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / GIR for Hazardous Waste Facilities in California

Generator Improvements Rule: New Compliance Requirements for Hazardous Waste Facilities in California

November 25, 2024

• Waste Names: Clear descriptions in layman’s terms.
• Hazards: Waste codes and hazard identification.
• Locations: Accumulation areas within the facility.
• Facility Map: Visual layout marking hazardous waste storage.
• Street Map: Facility’s location relative to surrounding areas.
• Response Notes: Details on emergency procedures.
• Special Instructions: Guidance for hospitals and treatment providers.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / Cal/OSHA’s Indoor Heat Illness Prevention Standard

Cal/OSHA’s Indoor Heat Illness Prevention Standard

October 18, 2024

The California Division of Occupational Safety and Health (Cal/OSHA) Heat Illness Prevention in Indoor Places of Employment standard, effective July 23, 2024, protects employees working in indoor environments where temperatures reach or exceed 82°F. It mandates the implementation of a comprehensive Indoor Heat Illness Prevention Plan. Elements of the plan include providing access to potable water, maintaining cool-down areas that are below 82°F, and implementing specific heat illness prevention procedures.

This new standard targets indoor workplaces where temperatures may lead to heat stress and other heat-related health risks. Environments such as manufacturing plants, warehouses, commercial kitchens, and foundries are just a few examples of the facilities potentially impacted, but any facility where temperatures reach or exceed 82°F when employees are present must comply.

Key Elements of the Indoor Heat Illness Prevention Plan

Under this new standard, employers are expected to develop an Indoor Heat Illness Prevention Plan that includes the following key elements:

1. Provision of Clean Drinking Water

Ensuring access to potable water is fundamental for preventing heat illness. Cal/OSHA specifies that employers must make water available that is “fresh, pure, suitably cool, and free of charge.” Workers should be encouraged to drink water frequently, ideally about “four cups (one quart) per hour” during their shift to stay adequately hydrated, especially in hotter conditions.

2. Establishment of Cooldown Areas and Rest Periods

Cooldown areas are mandatory under the new standard, which states the following: “For indoor workplaces, employers must provide access to at least one cooldown area which must be kept at a temperature below 82°F. Shade and cooldown areas must be blocked from direct sunlight, large enough to accommodate the number of workers on rest breaks so they can sit comfortably without touching each other, and as close as possible to the work areas.” Additionally, employees must be allowed to take cooldown rest periods upon request without fear of retribution or disciplinary action. This measure helps prevent the progression of heat stress into more severe heat-related illnesses like heat exhaustion or heat stroke.

3. Temperature and Heat Index Monitoring

Employers are now obligated to monitor their work environments. Cal/OSHA says to “measure the temperature and heat index and record whichever is greater whenever the temperature or heat index reaches 87°F (or temperature reaches 82°F for workers working in clothing that restricts heat removal or high-radiant-heat areas).”. This real-time monitoring helps businesses ensure they are always aware of heat levels and can adjust workplace practices accordingly to protect employees.

4. Emergency Response and Medical Aid

Cal/OSHA’s new standard includes detailed provisions for emergency response procedures. Employers are expected to “provide first aid or emergency response to any workers showing heat illness signs or symptoms, including contacting emergency medical services.”  This requirement highlights the importance of having a well-coordinated emergency plan with clearly defined responsibilities and response times.

5. Acclimatization Procedures

The standard requires employers to implement a defined acclimatization process for employees working in hot indoor environments. The new standard states the following: “Closely observe new workers and newly assigned workers working in hot areas during a 14-day acclimatization period, as well as all workers working during a heat wave.”  Additionally, during extreme heat events or heat waves, all employees are expected to be monitored more stringently to avoid the rapid onset of heat illness.

6. Training and Education

“Employers must provide training to both workers and supervisors,” according to the new standard. Employers are required to educate employees on the employer’s procedures to control and respond to heat illness, warning signs of heat illness, the importance of hydration, and the proper use of cooldown areas. Supervisors, in turn, are expected to be trained to identify symptoms of heat illness, respond appropriately to emergencies, and manage workloads during periods of extreme heat.

Stay Compliant with Cal/OSHA’s New Standard

Complying with Cal/OSHA’s new heat illness prevention standard is critical for any employer operating in high-temperature indoor environments. With penalties for non-compliance ranging from fines to potential lawsuits, ensuring that your workplace adheres to the standard and implements preventative elements should be a top priority.

Addressing heat illness proactively enhances employee well-being, productivity, and retention. Heat-related illnesses can lead to significant operational disruptions, increased absenteeism, and reduced morale. In the most severe cases, they can result in permanent injuries or fatalities. Employers who invest in a robust Indoor Heat Illness Prevention Plan are not only safeguarding their workforce, but also minimizing risk.

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...

Home / News / Regulatory Updates / Hazardous Substance Facility Response Plans

Hazardous Substance Facility Response Plans – EPA-Issued Final Rulemaking

September 13, 2024

How to Comply

Facilities affected by the rule will need to:

1. Assess whether they meet the applicability criteria;
2. Develop and submit an FRP to the U.S. EPA that includes a hazard evaluation and outlines response and recovery actions to worst-case discharge scenarios;
3. Implement the plan to mitigate potential environmental harm; and
4. Review and recertify the FRP every 5 years, plus whenever the U.S. EPA updates the list of CWA hazardous substances or adjusts the RQs.

Figure 1: Final Applicability Criteria for CWA Hazardous Substance FRP-Subject Facilities

The final compliance deadline is June 1, 2027, giving facilities a 36-month period from the rule’s effective date on May 28, 2024 to prepare an FRP if they meet the applicability criteria.

See the above figure to understand how this rule applies to you.

[1] For a list of CWA hazardous substances RQs, visit: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-117/subpart-A/section-117.3

________________________________

Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

If you would like a proposal, click the button below.

View our informative archived Newsletters ...