Month: February 2020

Chemical Safety Board Issues Final Rule on Release Reporting.  Just two months after issuing a proposed rule, the Chemical Safety and Hazard Investigation Board has published a final rule for reporting of accidental releases of a regulated substance or other extremely hazardous substances into the ambient air from a stationary source. The rule includes releases of petroleum products, including biofuels. Stationary sources would exclude trucks or other motor vehicles. The CSB estimates that 200 releases per year will be subject to its new reporting requirements. The rule creates a new Part 1604 of title 40 CFR.  It requires reporting any accidental release from a…

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A few years ago, my digital marketing agency audited the internet marketing programs of over 175 distributors and manufacturers and found that only 3.4% had a marketing plan. That’s not to say the companies without a plan weren’t spending money on marketing. Rather, they were letting marketing happen instead of creating a list of objectives, dedicating the necessary resources (internal labor, vendor support and advertising dollars) and establishing a system of measurement to allow for an assessment of progress toward specific goals. As you might imagine, that’s not a great situation. For those committed to taking digital marketing seriously, you’ll…

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End User Safety Communications For the first 100 years of the Compressed Gas Association’s history, our members’ products were used almost exclusively in heavy industry – steelmaking, chemical production, food freezing – as well as in medical gas applications. But, in recent years, we have seen a growing number of these products used in applications that are either very close to, or at the consumer level: from retail shops selling liquid nitrogen ice cream, to marijuana processing for CBD oil extraction, to patients’ in-home use of medical oxygen. While we can’t tell individuals how to use our products for specific…

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Congress, the Food and Drug Administration (FDA) and the Federal Motor Carrier Safety Administration (FMCSA) have all been active in considering the regulation of products containing cannabidiol (CBD). Drivers of commercial motor vehicles, and their employers, should not assume that these products are legal, safe or harmless, however. In the 2018 Farm Bill, Congress removed hemp (defined as cannabis with less than 0.3% THC) from the list of Schedule I controlled substances and made it an ordinary agricultural commodity. The recently passed 2020 Agriculture Appropriations Bill gave the FDA $2 million for research, policy evaluation, market surveillance and issuance of…

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One of the largest trends in American consumerism is the rise in direct to doorstep food delivery services. Companies like Blue Apron and Hello Fresh are popular meal kit services and now even Amazon is promising two-hour grocery delivery. As Americans get busier and the “Amazon Effect” continues to take hold, more and more we’ve grown accustomed to being able to get goods brought directly to our home at the click of a button without ever having to leave the couch. According to Statista, the fresh-food meal kit industry was valued at $4.65 billion in 2017. By 2022, it’s projected…

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