How To Keep Up With Chemical Regs

Both the pace of chemical regulatory change and the pervasiveness of chemical regulation itself have increased dramatically over the past few years. At the same time, keeping track of changing regulatory requirements has become a much more difficult task. This is especially true for small to medium-sized firms, which often face severe budgetary and staff restraints when it comes to regulatory compliance matters. On the other hand, with such sweeping new requirements as the 1986 Superfund Amendments and Reauthorization Act (SARA), these companies have little choice but to do the best they can to keep up. A review of the information resources available may prove helpful in keeping up with chemical regulatory change. I would like to present these resources in three rather loosely defined, and somewhat overlapping categories: human re-sources, print information resources, and automated information resources. Although the specific examples within each category are fairly representative, there are usually numerous comparable resources. Human Resources Human resources are one of the least expensive and often most productive sources of information. One good starting point is to keep in close contact with your suppliers. They should not only be able to provide you with material safety data sheets and updates, but also more specifically regulatory information about the substances they manufacture or distribute. Understanding the supplier's regulatory responsibilities vis-a-vis the chemicals of interest to you can be extremely helpful in alerting you to some of your own responsibilities. Another resource is sharing information with companies with similar concerns. One way to do this is through participation in trade and professional associations at the national and especially at the state and local levels. The standard source for finding these groups is Gale Research Co's annual Encyclopedia of Associations. Govemment officials can also provide a wealth of information including the latest regulatory developments. And, at least at the federal level, they are much more accessible than one might suppose. There are several useful directories available to help you identify specific individuals at various levels of government. For some federal agencies, you can, for a few dollars each, order individual agency telephone directories (such as the Environmental Protection Agency's telephone directory) from the Superintendent of Documents in Washington, D.C. However, most companies will want to consult one of the commercial directories since they are more comprehensive and up-to-date, and are better organized. These include the Federal Yellow Book from Monitor PubIishing Co.; the quarterly federal, federal regional, state, county and municipal executive directories from Carroll Publications; and Congressional Quarterly's Washington Information Directory. There are also government hot line numbers you may call for assistance, but these are of limited value for current awareness. While keeping in touch with suppliers, colleagues and government officials is extremely valuable, these information sources neither are individually comprehensive, nor do they necessarily address the specifics of your company's situation. For this reason, it is worth considering the services of a consultant to address your regulatory compliance situation and to review with you periodically the implications of recent regulatory developments. Although this is frequently perceived to be an expensive option, it should be carefully evaluated for several reasons. The consultant addresses your specific situation and deals with it comprehensively, from a knowledge and experience base unlikely to be available in house. Furthermore, use of a consultant can minimize the diversion of staff time and resources away from the company's primary mission. Given these factors, there are many cases where a consultant could prove the single most cost-effective resource for regulatory compliance information tailored to your company's needs. In addition to word of mouth, there are several readily available sources for identifying consultants. Every January, the American Industrial Hygiene Association's monthly Journal publishes a list of industrial hygiene consultants. More comprehensive consultant coverage is provided in two annual directories: Gale Research Co.'s Consultants and Consulting Organizations Directory and Dun's Consultants Directory. Each covers 10,000 or more consultants and consulting firms. Most of these directories are standard references likely to be available at larger public libraries as well as at university and government libraries. Useful as personal contacts are, all except the consultant option require continuing initiative and discipline; that is, you have to aggressively seek out the information you need, and you have to do it regularly. Fortunately, there are a number of organizations (including federal and state governments) which, to one degree or another, will do this for you—for a price. Print Information Resources At their best, some trade magazines and journals can provide roughly the same current aware-ness coverage as some broad-based newsletters, usually at less cost, and occasionally at no cost. Penton Publishing's Occupational Hazards magazine is a case in point. It is a controlled circulation publication; that is, if you fit a certain occupational or professional profile, you can receive the publication free of charge. Each month, Occupational Hazards, among other features, reviews OSHA actions and proposals, notices new books and training materials, provides studies of actual OSHA cases, and reports on relevant court cases. Many similar publications exist, both paid subscription and controlled circulation, far too many to even begin to enumerate here. There are literally dozens of commercially published newsletters in the chemical and environmental fields. (This figure moves into the hundreds if one includes the numerous newsletters generated by trade associations and by governmental, environmental, and related groups.) Newsletters are generally published once or twice each month, and subscription prices typically fall into the $200-$300 per year category. To identify newsletters of possible interest, there are two guides available: The annual Newsletter Yearbook Directory and the biennial Oxbridge Directory of Newsletters. Newsletters vary consider ably in quality and focus, and it is helpful to review actual copies of the publications of interest to you. Fortunately, most newsletter publishers make it possible for you to obtain sample issues so you can make an informed decision. Business and Legal Reports offers two newsletters directly focusing on chemical regulatory compliance issues at both the federal and state levels. Published twice each month, The Environmental Manager's Compliance Advisor contains a mixture of general news items as well as several special features, including a separate section on state news and a digest of Federal Register actions. Each issue also contains a section treating one or more topics in some detail. A recent issue, for example, devoted four pages to developments related to the SARA Section 313 Toxic Chemical Release Inventory Form requirements. The same company also publishes a similar, but some-what more narrowly focused monthly newsletter called the Right-to-Know Compliance Advisor that covers both federal and state level developments. Thompson Publishing Group also offers two regulatory newsletters of interest. The first, Right-to Know News, is a semimonthly covering primarily the federal- and state-level Hazard Communication Standard and other right-to-know developments. The second, Community Right-to-Know News, provides twice-monthly reporting on chemical notice and disclosure requirements, emergency response programs, and industry liability at the federal, state and local levels. Coverage includes, but is not limited to, the implementation of the 1986 SARA legislation. Other publishers have developed whole families of at least loosely related newsletters. Business Publishers Inc. (BPI), for example, offers publications in the environmental field. Of particular interest are the weekly Toxic Materials News, which covers developments in toxic substances legislation, regulation, and litigation at federal, state and local levels; and the bi-weekly State Regulation Report, which covers state-level legislative and regulatory developments of significance to chemical manufacturers and users. BPI's more focused newsletters, such as Hazardous Waste News and the Clean Water Report, also provide regulatory coverage. A somewhat different newsletter approach is taken by Van Nostrand Reinhold Information Services in its biweekly Hazchem Alert. This newsletter is global, tends to be chemical-specific in focus, and includes in the 100-plus sources it follows many respected scientific journals. As a result, in Hazchem Alert, one is as likely to find a newsbrief on the results of a toxicology study as a news item on Superfund legislation. From the user's standpoint, the problem with newsletters is—given the inevitable overlap among reIated newsletters—"Which one best meets my needs?" And, Do I have to subscribe to more than one newsletter to cover all bases?" Unfortunately, because of the nature of newsletters, no one is likely to "cover it all." But, fortunately (at least from the user's point of view) a proliferation of newsletter subscriptions is unnecessary, since this medium is only one ingredient in a successful current awareness program. Clansky is president of Roytech Publications, Inc., publisher of the Suspect Chemicals Sourcebook and the Chemical Guide to the OSHA Hazard Communication Standard. His address is l499 Old Bayshore Highway, Suite243, Burlingame, CA 94010. Adapted from a talk at the l987American Chemical Society meeting in Denver.

How To Keep Up With Chemical Regs

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