A level detection float gauge fails in a fuel tank, leading to an overfill and a spill into a storm drain and nearby waterway. A forklift mishap accidentally damages a tank of pressurized gas, resulting in an evacuation. An electrical fire in a facility causes an overpressure event and rupture of a chemical storage tank – resulting in contamination of both onsite and offsite soil. In the immediate aftermath of an unexpected incident, resulting in a pollution release or environmental exposure, the facility needs efficient access to the appropriate response equipment, personal protective gear, and possibly a response contractor. Should the local press show up, facility staff must have a clear understanding of how to interact, as inevitably seemingly innocuous statements are taken out of context on the six-o’clock news.

These incidents have one critical component in common: time is critical. Delay means the potential for greater liability and cost. Hazardous materials and substances can travel rapidly and impact air, soil, surface waters and groundwater, as well as endanger human health.

The Environmental Contingency Plan

To prevent, control, and respond to unexpected releases of hazardous materials, chemical and manufacturing facilities will develop Environmental Contingency Plans. These plans are often referred to as the “Red Binder” or “Red Book.” Conceptually, the environmental contingency plan is the facility’s written road map outlining the actions to be implemented in the event of a hazardous material release. Not unlike a playbook for a sports team, it should be part of staff member training and practiced. The plan should also be periodically updated – to reflect changing facility conditions, surrounding communities, and response capabilities.

A well-developed environmental contingency plan is specific to each facility; there is no one-size-fits-all plan. Each industrial operation and facility is different. The types and quantities of chemicals used are unique to each facility and operation. Some facilities are located in metropolitan areas and others in rural locations, with varying distances from residential and commercial neighbors. The infrastructure and natural resources that could be affected will also differ from one facility to another.

What’s Included in the Environmental Contingency Plan?

The following are some basic sections that should be included in the plan. Because of the complexity of the environmental contingency planning process, development of the plan may require a multidisciplinary team with representatives from operations, facilities, safety, security, and environmental departments.

• Hazard identification and risk assessment: Hazards that are not identified cannot be evaluated. This makes an understanding of the hazardous materials on site critical. Once the materials are identified, the plan should address potential release scenarios and environmental pathways.
• Response procedures: Step-by-step actions for spills, leaks, emissions, containment, isolation, cleanup, and escalation. This should include shutdown procedures, if needed. Employee training is vital to the proper implementation of a facility’s contingency plan. The training must involve all levels of employees – from those responsible for reporting the initial incident to senior-level management personnel who make regulatory notifications and authorize the use of environmental consultants and cleanup contractors. ¨
• Roles and communication protocols: Defined responsibilities, notification trees, and internal and external reporting procedures. In the event of a catastrophic release, having a media relations consultant available to assist with statements or manage press releases can help ensure that the public and other stakeholders receive clear and timely information and can reduce the spread of misinformation.
• Equipment: Spill kits, personal protective equipment (PPE), monitoring tools, and containment materials. There should be documented, periodic inspections of response equipment and PPE; and deficiencies should be corrected in a timely manner.
• Coordination with outside agencies: Information for contacting local fire departments, emergency responders, medical support providers, and regulatory agencies. Larger incidents may require the use of multiple third-party vendors. Vetting vendors as part of contingency plan development is a crucial step in the process. Having current agreements in place with environmental response contractors, environmental consultants, and media relations firms will allow for a timelier response. No one wants to negotiate terms and conditions for service while the building is on fire.
• Recovery and documentation: Procedures for waste handling, investigation, corrective action, and post incident review.

Beyond the Written Plan

Developing a plan is only the beginning. A response plan works only if it is effectively implemented and maintained. Operations change over time through the introduction of new materials, revised processes, staffing changes, equipment modifications, and updated regulations. Facilities should review and update the plan regularly, train employees on their responsibilities, inspect emergency equipment, and conduct drills to determine whether the plan works under realistic conditions.

Inviting local responders to participate in drills or conduct a facility tour is an effective way to inform them of site-specific hazards and assist them in providing a timelier and more effective response. Integrating lessons learned from debriefings after drills or actual incidents is critical to keeping the hazardous materials contingency plan reliable.

Hazardous material contingency plans are facility-specific and based on operational hazards, chemical types and uses, and the response actions to be implemented. Developing and maintaining a response plan is an investment in preparedness, resilience, and responsible operations. For chemical manufacturing facilities, it can make the difference between a limited incident and a large-scale hazardous material release.

How HETI Can Help

The same planning elements that make a contingency plan useful during an emergency also make it challenging to develop and maintain. HETI assists clients with the development, review, and implementation of facility-specific hazardous materials and environmental contingency plans. Our environmental health & safety (EHS), industrial hygiene, environmental, and risk management professionals can help identify release scenarios, evaluate response resources, develop notification and communication procedures, coordinate with emergency responders and regulatory agencies, and support employee training, drills, and post-incident reviews.

We also provide environmental emergency response, regulatory support, compliance auditing, risk management, and remediation-related services to help clients prepare for incidents before they occur, respond effectively when they do, and to help reduce risk exposures and costs.

For further information on HETI’s environmental services, please contact us.

Russell Greatorex Senior Environmental Scientist

Legionella is a naturally occurring waterborne bacterium that becomes dangerous when it colonizes and amplifies in human-made water systems. The most common sources are cooling towers, but may also include hot tubs, decorative fountains, hot water tanks, and complex plumbing systems.

People are infected by inhaling contaminated water droplets (mist), not through person-to-person contact. The resulting illness, Legionnaires’ disease, is a severe pneumonia with an average fatality rate of roughly 10% – rising substantially in healthcare and long-term-care settings. Risk factors for contracting illness include age (over 50 years old), smoking, and individuals with a history of lung disorders or compromised immune systems. The onset of symptoms may occur 2-10 days after exposure. Legionella exposure claims frequently implicate property owners, facility management companies, and water-treatment contractors. Increasingly, cases of illness draw plaintiff firms’ marketing directly to potential claimants within days of a public health announcement.

This issue of HETI Horizons reviews the major confirmed U.S. Legionella events during the past 12 months, the causation patterns responsible parties should watch for, and the regulatory landscape shaping liability exposure. Several of these events, particularly the ongoing New York City cluster, were still under active investigation at the time of writing and figures may have changed since.

Major U.S. Outbreaks: July 2025-July 2026

Over the past year, there have been several Legionella events that resulted in illness and death. As of July 2026, in the Upper East Side in Manhattan, NY, CNN reported 74 confirmed cases of Legionnaires’ disease – including 12 people hospitalized and three fatalities with the illness. New York City (NYC) identified this as a likely community cluster with cases limited to three ZIP codes and by mid-July had inspected all 183 cooling towers in the Carnegie Hill/Yorkville investigation zone – finding 76 with preliminary Polymerase Chain Reaction (PCR) positive results. No definitive source building has been confirmed and officials noted that confirmatory culture testing was being conducted. This incident was the first major test of NYC’s tightened cooling tower inspection law, effective May 2026.

In Westchester County, NY, 37 cases of Legionnaires’ disease, including two deaths, occurred in the Summer of 2025. This incident included a five-case Yonkers sub-cluster in which investigators were unable to match patient sample results to any specific cooling tower.

A similar outbreak of Legionnaires’ disease occurred in July through August 2025 in central Harlem, NY. In this event there were 118 confirmed cases and seven deaths. Genomic sequencing matched clinical sample results to two cooling towers on the same city block – one of the more definitive source confirmations among last year’s clusters.

From August through September 2025, 74 cases of Legionnaires’ disease, including two deaths, occurred in Marshalltown, Iowa. State epidemiologists attributed the outbreak to a cooling tower. The business responsible was never publicly identified, shielded by Iowa’s communicable-disease privacy statute. Notably, Iowa has no statewide cooling tower registration or testing requirement and any future regulation would have to come from local ordinance.

In Ector County (Odessa), Texas,12 cases of Legionnaires’ disease, including two deaths, were reported from November 2025 through January 2026. Local health officials were unable to identify a single source, stating there was no reason to suspect municipal water and instead pointing to individual risk factors such as unsanitized home respiratory equipment.

Over the past year, there were a number of smaller clusters – including a gym in Orlando, Florida (14 cases, 0 deaths), a nursing facility in Bloomingdale, Illinois (2 cases, 0 deaths), a hospital in Cincinnati, Ohio (2 cases, 0 deaths), and a resort in Avon, Colorado (3 cases, 0 deaths).

Why the Trend Line Keeps Climbing

Centers for Disease Control and Prevention (CDC) surveillance data show reported Legionnaires’ disease cases have been rising since the early 2000s, peaked in 2018, and rebounded after a COVID-era dip. 2024 and 2025 provisional figures continue that upward trend, per CDC. Aging cooling tower and plumbing infrastructure; inconsistent water management program adoption; warmer and more humid summers that extend the seasonal risk window; and an aging, more comorbid population all contribute to sustained frequency. Detection is also improving in well-resourced jurisdictions, which increases reported case counts even where underlying exposure hasn’t changed – an important consideration when comparing loss trends across the United States.

Regulatory and Compliance Landscape

Regulations to control Legionnaires’ disease occurrences vary among the states. New York requires registration, annual certification, monthly inspection, and Legionella testing at least every 90 days for all cooling towers – with the law tightened further in May 2026 after the Harlem outbreak. Other states, including Iowa and Texas noted in the events above, have no comparable statewide mandate, leaving water management program (WMP) adoption largely voluntary and governed by industry guidance, such as ASHRAE 188, rather than statute.

Risk Management Takeaways

Reducing Legionella exposure is best achieved through a rigorous building-specific WMP and active case management. Some of the preventative measures that can be taken include:

• Properties with cooling towers, hot tubs, decorative fountains, or complex plumbing (hotels, hospitals, senior living, large multifamily, gyms, resorts) should have a documented, currently maintained WMP, and treatment, if needed.
• Frequency of testing should be in accordance with applicable state/local requirements. Voluntary compliance with ASHRAE 188 should be a minimum threshold – even where no statute exists.
• Source-attribution failure is a real possibility in claims handling; not every outbreak resolves to a single confirmed premises source, which affects both coverage triggers and subrogation potential.
• Rapid plaintiff’s bar activity should be expected following any public health advisory; claims development can begin before final case counts or environmental testing are complete.

How HETI Can Help

HETI’s team of Certified Industrial Hygienists and EHS professionals work with property owners, facility managers, and insurance carriers to reduce Legionella exposure before it becomes a claim. Our services include on-site water system risk assessments and cooling tower inspections; development and audit of water management programs aligned with ASHRAE 188 and applicable state/local requirements; coordination of Legionella sampling, culture, and both PCR or culture testing with accredited laboratories; post-remediation verification/documentation; and rapid-response consultation when a cluster or positive test result is identified.

By combining technical expertise with regulatory knowledge across jurisdictions, HETI helps clients close the gap between voluntary guidance and enforceable compliance – reducing both the likelihood of an outbreak and the liability exposure that follows one.

To find out more about HETI’s industrial hygiene and EHS services, please contact us.

Michael Henderson, PhD, CIH Director, Industrial Hygiene

The reliability of the U.S. electrical grid is under increasing pressure. Aging transmission and distribution infrastructure, combined with more frequent and more severe weather events, has elevated the risk of extended power outages for commercial and industrial facilities across the country. The North American Electric Reliability Corporation (NERC) has identified elevated risk of energy shortfalls during peak demand periods in multiple regions, and has warned that power generation facilities are being shut down faster than new ones are being built to replace them.1 For many businesses, an extended outage is not just an inconvenience; it translates directly into property damage, production loss, and potential regulatory non-compliance.

These realities have prompted facility owners, operators, and their insurers to take a closer look at backup power preparedness. Advances in distributed generation and battery storage technology are expanding the options available beyond traditional diesel and gas generators; and a growing understanding of global fuel price volatility has added another argument for diversifying energy sources. This edition of HETI Horizons examines the current state of grid reliability, key backup power plans and strategies for reducing exposure to fossil fuel supply disruptions.

Grid Reliability Under Pressure

The February 2021 winter storm in Texas provided a prime example of what large-scale grid failure looks like in practice. More than four million homes and businesses lost power, with outages lasting up to several days and resulting in an estimated $195 billion in economic damage.2 The event exposed vulnerabilities in aging infrastructure, fuel supply chains, and weather forecasting that had been known for years but never fully addressed.

NERC’s 2023 Long-Term Reliability Assessment identified elevated risk of energy shortfalls during both summer and winter peak demand periods across the Midcontinent Independent System Operator and Southwest Power Pool regions, as well as portions of the Western Interconnection. Retiring coal and older natural gas plants have left thinner operating margins than traditional grid planning was built around.

For individual facilities, the practical consequence of these trends is that power interruptions are likely to become more frequent, longer in duration, and harder to anticipate. Facilities that have rarely dealt with serious outages may need to take a harder look at whether their backup power is actually adequate.

Emergency Generator Maintenance and Testing

Diesel and natural gas generators remain the most common backup power solution for commercial and industrial facilities, and they remain highly effective when properly maintained. However, generator failure during actual emergencies is not uncommon; and the root cause is usually maintenance related, not a problem with the equipment itself.

The National Fire Protection Association’s NFPA 110, Standard for Emergency and Standby Power Systems, establishes minimum maintenance and testing requirements for emergency power systems. Level 1 systems (those serving critical life-safety applications such as hospitals and emergency response facilities) require monthly testing under load. Level 2 systems (non-critical business operations) must be tested at least every six months.3

Diesel fuel degrades within six to 12 months, and moisture intrusion and microbial growth in fuel tanks can clog injectors and filters, preventing a clean start. Dead starting batteries are among the most common reasons generators fail when actually needed, yet battery condition is often the last thing to get attention in a maintenance program. Loss prevention guidance for emergency and standby power systems recommends comprehensive maintenance programs that include regular fuel testing, annual load testing, and battery replacement on a two-to-four-year cycle.4

Organizations should maintain detailed maintenance logs consistent with NFPA 110 recordkeeping requirements.3 After an outage, a well-documented maintenance history can be the difference between a covered claim and a denied one.

Solar Generation and Battery Storage as Backup Power

Solar photovoltaic systems paired with battery energy storage have emerged as a practical complement to, and in some cases a partial replacement for, conventional backup generators. A solar-plus-storage system consists of solar panels, battery storage, and power electronics that manage energy flow between the panels, the batteries, and the facility’s loads. When the utility grid fails, the system automatically disconnects from the utility and continues to supply power using stored energy and active solar generation.

The economic case for solar-plus-storage has improved substantially over the past decade as equipment costs have declined. Unlike a diesel generator that sits idle between outages and generates no return during normal operations, a battery storage system can reduce peak demand charges, participate in power buyback programs, and serve as a dispatchable resource, providing more value than traditional generators.5

Extended outages – the very scenario that represents the greatest risk – may exceed battery capacity, particularly when solar generation is unavailable due to weather or nighttime conditions. Most commercial installations can sustain critical loads for two to eight hours on stored energy alone. Facilities are therefore pairing a conventional generator for long outages with solar-plus-storage for shorter interruptions. This approach offers additional resilience that neither technology provides on its own.

Fossil Fuel Supply Volatility

The cost of diesel and natural gas is exposed to geopolitical shocks and supply chain disruptions that facility operators cannot see coming. The 2022 Russian invasion of Ukraine and the restriction of Russian natural gas exports, and the ongoing conflict in the Middle East with its disruption of global oil supplies, produced sharp increases in global natural gas prices, with effects that elevated utility costs for everyone. Depending on a single fuel type or supply chain introduces a category of risk that is separate from grid reliability, but just as significant for operating costs.

Solar-plus-storage systems offer a meaningful buffer against these types of uncertainties. Once installed, the operating cost of solar generation is effectively zero and unaffected by commodity markets or international events. Battery storage extends this advantage by capturing excess solar output for use during periods of peak grid pricing or constrained supply. For facilities with substantial generator runtimes, incorporating solar-plus-storage into a hybrid energy strategy can reduce fuel consumption and minimize operating costs associated with price swings.

A facility that draws from multiple energy sources, including renewable generation, grid power, and stored or conventionally fueled backup, is less exposed to any single point of failure – whether that failure originates in grid infrastructure, an extreme weather event, or a policy decision made overseas.

How HETI Can Help

HETI’s staff of engineers, environmental scientists, and technical professionals can assist facility owners and operators in evaluating their backup power preparedness, identifying gaps in maintenance programs, and assessing opportunities to incorporate renewable and distributed energy resources into a comprehensive site energy strategy. Our services in this area include backup power system assessments, emergency response procedure development, maintenance program review, and regulatory compliance support.

References

1 North American Electric Reliability Corporation. (2023). 2023 Long-Term Reliability Assessment.

2 The Perryman Group. (2021). Preliminary Estimates of Economic Costs of the February 2021 Texas Winter Storm.

3 National Fire Protection Association. (2022). NFPA 110: Standard for Emergency and Standby Power Systems.

4 FM Global. (2022). Data Sheet 5-23: Design and Protection for Emergency and Standby Power Systems.

5 Ramasamy, et al. (2021). U.S. Solar Photovoltaic System and Energy Storage Cost Benchmarks: Q1 2021. National Renewable Energy Laboratory. NREL/TP-6A20-81408.

For further information on HETI’s risk management and EHS services, please contact us.

Alexander Ostrobrod,

LSRP Senior Environmental Scientist

Reports of bed bug infestations in the workplace have risen in recent years. Consider this scenario: a facilities manager receives an urgent call. Several employees in an office building have reported itchy welts after returning from business travel. Within days, signs of bed bugs appear in conference room chairs and cubicle partitions. What begins as an isolated complaint quickly escalates into widespread concern, temporary workspace closures, costly remediation, and significant impacts on employee morale and productivity.

Incidents like this are no longer rare. Once considered a problem confined to hotels and residential housing, bed bugs have made a dramatic resurgence across workplaces, healthcare facilities, transportation hubs, and commercial buildings – representing a growing occupational health concern that demands proactive attention.

What Are Bed Bugs?

Bed bugs (Cimex lectularius) are small, flat, oval-shaped insects approximately four-five millimeters long (about the size of an apple seed). They are reddish-brown, wingless, and feed exclusively on human blood, typically at night. During the day, they hide in tiny cracks and crevices – in mattresses, furniture seams, baseboards, electrical outlets, and even behind wall pictures or in luggage.

Unlike many other pests, bed bugs do not breed in filth or require food waste; they thrive wherever people rest or sit for extended periods. They are excellent hitchhikers – spreading easily on clothing, briefcases, furniture, and shared equipment. A single pregnant female can initiate a new infestation that grows rapidly if left unchecked.

Health and Safety Impacts

Bed bugs are not known to transmit diseases to humans. However, their bites can cause significant physical and psychological effects. Common reactions include itchy red welts or raised skin lesions, often appearing in linear clusters. Allergic responses range from mild irritation to severe swelling in sensitive individuals. Secondary skin infections from scratching and elevated indoor histamine levels from shed skins, feces, and saliva may exacerbate respiratory or allergic conditions.

The psychological toll is often more profound. Workers may experience anxiety, insomnia, embarrassment, and social stigma. In severe cases, infestations have been linked to depression, reduced productivity, absenteeism, and even post-traumatic stress like symptoms. For employers, these issues translate into morale problems, workers’ compensation claims, and potential liability under the Occupational Safety & Health Administration (OSHA) General Duty Clause.

Why the Resurgence

Bed bug populations declined sharply after World War II due to widespread pesticide use. Their return since the early 2000s stems from increased international and domestic travel, pesticide resistance in modern strains, reduced public awareness, the popularity of second-hand furniture, and the sharing economy.

Workplaces are particularly vulnerable because employees, vendors, visitors, and contractors unknowingly transport bed bugs from hotels, homes, public transit, or other sites. Sectors at higher risk include hospitality, healthcare, offices with open-plan seating, call centers, and facilities managing shipped goods or furniture.

Detection Challenges and Early Warning Signs

Bed bugs are masters of concealment. Visual inspections often miss early infestations. Key signs include tiny dark fecal spots or blood smears on sheets, mattresses, or walls; cast skins resembling small translucent seeds; a distinctive sweet, musty odor in heavy infestations; and live bugs or eggs in seams and crevices.

Because bites may not appear immediately and can be mistaken for mosquito bites or other dermatological issues, many infestations go undetected until they spread. The “breakfast, lunch and dinner” pattern refers to small clusters of bed bug bites, often in a line or zigzag pattern, caused by sequential feeding on exposed skin and can differentiate from typical mosquito or other bites. Traditional reactive approaches – waiting for complaints – allow populations to explode.

Integrated Pest Management: The Most Effective Strategy

The gold standard for bed bug control is Integrated Pest Management (IPM), which emphasizes prevention, monitoring, and minimal pesticide use. Effective IPM includes routine visual inspections and employee education programs; use of monitoring devices and canine detection teams; non-chemical methods such as heat treatment, steam, vacuuming, and mattress encasements; targeted, low-toxicity pesticide applications only when necessary; and sealing cracks, reducing clutter, and implementing travel protocols.

IPM not only controls infestations more effectively than chemical treatments alone but also reduces risks from pesticide exposure – an important consideration under OSHA and Environmental Protection Agency (EPA) guidelines.

Regulatory and Compliance Considerations

The EPA regulates pesticides used against bed bugs; but specific reporting and management regulations are administered at the state level. While OSHA does not have a specific standard for bed bugs, the General Duty Clause applies, so employers must address recognized hazards that can cause death or serious physical harm. Failure to respond appropriately can lead to citations.

Many states and local health departments also have guidance or requirements for commercial facilities. Bed bug laws and obligations vary by state; but generally, landlords are responsible for addressing infestations, while tenants must report issues promptly. Approximately 23 states have enacted bed bug-specific legislation or regulations; but often the focus is on responsibilities for landlords and property managers. Proactive environmental health & safety (EHS) programs that incorporate bed bug policies, training, and rapid response plans demonstrate due diligence and help mitigate liability.

How HETI Can Help

HETI’s team of certified industrial hygienists and EHS professionals works with organizations to integrate bed bug prevention and response into comprehensive workplace health and safety programs. Our services include on-site risk assessments and facility inspections; development of customized bed bug prevention policies, employee training materials, and response protocols; coordination with licensed pest management professionals to ensure treatments align with IPM principles and minimize chemical exposure; and post remediation verification.

By combining technical expertise, regulatory knowledge, and practical field experience, HETI helps clients reduce the likelihood and impact of bed bug incidents while protecting worker health and organizational reputation.

To find out more about this and other HETI industrial hygiene and EHS services, please contact us.

Stephen Bell, CIH Senior Industrial Hygienist

A laboratory technician opens a long-forgotten cabinet and finds a sealed bottle of diethyl ether with crystalline material forming around the cap. Unknown to the current staff, the solvent has sat undisturbed for years – slowly forming explosive peroxides. What began as routine housekeeping now presents an immediate detonation hazard.

Incidents like this are not rare. Incompatible chemical storage, degraded materials, and abandoned containers continue to drive fires, exposures, and costly emergency responses across industries. In many cases, the root cause is not the chemical itself; it is the absence of an accurate, actively managed inventory.

For organizations managing chemical risk, the question is not simply “What do we have?” but “Do we actually know what we have – and is it being managed appropriately today?”

When Inventory Fails: Preventable Incidents

Chemical incidents tied to poor inventory management tend to follow familiar patterns. Peroxide-forming chemicals, such as ethers and certain olefins, can become increasingly unstable over time. Without tracking receipt dates, opening dates, and storage conditions, these materials may remain on shelves well beyond their safe lifespan – transforming into shock-sensitive hazards.

In other cases, incompatible chemicals are stored in close proximity due to space constraints or poor labeling practices. Oxidizers stored alongside organic materials, or acids stored near cyanides, can create conditions where a simple container breach escalates into a fire, toxic release, or both.

A third common issue is the accumulation of “legacy chemicals” – containers left behind by prior staff, contractors, or tenants. These materials are often unlabeled, degraded, or unknown – complicating emergency response and disposal. For insurers and property stakeholders, such unknowns represent unquantified liability.

Each of these scenarios shares a common thread: the organization lacked a current, verified understanding of what was present on-site.

The Regulatory Backbone: More Than a Paper Exercise

Regulatory frameworks reinforce the importance of maintaining an accurate chemical inventory; but compliance alone does not guarantee safety.

Under the Occupational Safety & Health Administration’s (OSHA’s) Hazard Communi cation Standard (29 CFR 1910.1200), employers are required to maintain a list of hazardous chemicals and ensure that Safety Data Sheets (SDS) are readily accessible. This inventory forms the foundation for employee training, labeling, and hazard communication.

However, the regulatory landscape is evolving. The Environmental Protection Agency’s implementation of the Toxic Substances Control Act (TSCA) increasingly emphasizes “conditions of use,” requiring organizations to understand not just what chemicals are present, but how they are handled in specific operational contexts. This shift places greater importance on accurate, site-specific data.

An incomplete or outdated inventory can lead to cascading compliance failures: incorrect hazard classifications, improper personal protective equipment (PPE) selection, and training programs that do not reflect actual workplace risks. From a regulatory standpoint, if an organization cannot demonstrate control over its chemical inventory, it is unlikely to be viewed as compliant.

Chemical Inventory and Hygiene Audits: A Proactive Approach

A growing best practice is the implementation of what can be termed a “Chemical Inventory and Hygiene Audit.” This process moves beyond simple recordkeeping to provide a structured evaluation of chemical risk at the facility level.

A comprehensive audit typically includes:

• Verification of inventory accuracy through physical inspection
• Assessment of storage compatibility and segregation practices
• Review of labeling and alignment with current SDS information
• Identification of time-sensitive or unstable materials (e.g., peroxide formers)
• Flagging of chemicals subject to specific regulatory requirements
• Evaluation of opportunities for elimination or substitution

Importantly, these audits also provide a mechanism to apply the Hierarchy of Controls in a meaningful way. By identifying unused, redundant, or high-hazard chemicals, organizations can eliminate risks entirely or substitute less hazardous alternatives – often achieving greater risk reduction than PPE or administrative controls alone.

Rather than reacting to incidents or regulatory findings, organizations that conduct periodic audits can identify and address risks before they escalate.

The Hidden Risk: Inventory Drift

One of the most persistent challenges in chemical management is “inventory drift”: the gradual divergence between documented inventory and actual conditions on-site. Over time, chemicals are consumed, relocated, repackaged, or abandoned without corresponding updates to inventory records. New materials are introduced without full integration into the Hazard Communication program. The result is a growing gap between what is believed to be present and what actually exists.

This gap creates both regulatory and financial risk. Inaccurate inventories undermine training programs and PPE selection – increasing the likelihood of worker exposure. An unmanaged inventory represents an unknown risk profile – one that may only become visible after a loss event. In practical terms, an unmanaged chemical inventory is not just a safety issue; it is an unquantified liability.

How HETI Helps

HETI works with organizations across industries to transform chemical inventories from static lists into active risk management tools.

Through on-site chemical inventory audits, HETI’s Certified Industrial Hygienists verify the presence, condition, and storage of chemicals while identifying gaps in compliance and risk controls. This process goes beyond counting containers; it involves interpreting regulatory requirements, evaluating storage practices, and identifying chemicals that present elevated risk.

HETI also supports the development and implementation of Hazard Communication programs that are aligned with actual site conditions. This includes updating written programs, ensuring SDS accuracy, and delivering targeted training that reflects the specific hazards present in the workplace.

For clients in insurance, real estate, and industrial operations, these services provide critical clarity. Accurate inventories support due diligence, improve risk assessment, and reduce the likelihood of unexpected liabilities tied to chemical hazards.

In an environment where regulatory expectations and chemical risks continue to evolve, proactive inventory management is no longer optional. It is a foundational element of operational resilience.

To find out more about this and other HETI industrial hygiene services, please contact us.

Kevin Murphy, CIH, CSP Senior Industrial Hygienist

Jim Durant, MSPH, CIH Senior Industrial Hygienist

Over the past few years, there has been increasing concern about microplastic contamination. Annual global plastic production is currently estimated at 460 million tons and is expected to reach 736 million tons by 2040.

What are Microplastics and Nanoplastics?

According to the U.S. Food and Drug Administration (FDA), microplastics are very small pieces of plastic that are typically considered less than five millimeters in size in at least one dimension. Microplastics can be either primary (manufactured to be that size, such as resin pellets used for plastic production) or secondary (degraded to that size from larger plastics discarded into the environment). Nanoplastics are even smaller – typically considered to be less than one micron, in size. For reference, the diameter of a human hair is about 70 microns. Together, micro- and nanoplastics are often referred to as MNPs. They are comprised of many different chemical compositions and/or stages of degradation and can contain chemical additives such as antioxidants, UV stabilizers, fillers, colorants, lubricants, and antistatic agents.

Where are Microplastics and Nanoplastics Found?

MNPs are ubiquitous. They have been found in samples from the highest mountains to the deepest undersea trenches on earth. They have been detected in multiple components of the human food chain – including fish, shellfish, drinking water, fruits and vegetables, salt, sugar, tea bags, and baby bottles. Ingestion is considered the primary route of exposure. The inhalation of house dust containing polybrominated diphenyl ethers, which were used as fire retardants in older plastics and synthetic fabrics, also presents an exposure concern. The chemicals used in the manufacture of plastics, such as phthalates and bisphenols, have been found in biomonitoring samples, including samples from newborns and pregnant women (Zarus, et al, 2021, https://doi.org/10.1016/j.scitotenv.2020.144010). Other plastic-associated chemicals, including PFAS and various additives, have also been detected in human populations. Many of the plastic chemicals in use today have not been evaluated for toxicity in human health studies.

Why the Concern?

Apprehension about plastics, in general, is not new from an environmental perspective. With current production exceeding 400 million tons annually – less than 10% of which comes from recycled plastic waste, with the remainder derived from fossil fuels – the potential for pollution is substantial. Plastics enter the environment at all stages of their life cycle, including manufacture, fabrication, use, and waste management. Because plastics are highly durable, they degrade very slowly and consequently accumulate in oceans and landfills. As plastics degrade, they fragment into MNPs, which tend to be more environmentally mobile and may have greater potential for biological uptake.

The extent to which MNPs cause human harm remains uncertain, and research is constrained by analytical challenges. MNPs have been detected in human tissues – including placenta, blood, lung, arterial plaque, and brain – indicating exposure and systemic distribution. However, the health significance of these findings is not yet clear. Experimental studies suggest MNPs may activate biological pathways such as inflammation, oxidative stress, and endocrine disruption, but causal links to human disease have not been established. Limited human studies report associations with outcomes such as cardiovascular events and reproductive effects, while evidence for neurological and gastrointestinal conditions remains sparse and indirect.

At present, there is significant interest within the scientific community in investigating the synergistic toxicity relationship between MNPs and PFAS in both environmental systems and human cell lines. Some recent studies have linked MNPs with:

• Stroke
• Myocardial infarction
• Endocrine disruption
• Irritable Bowel Syndrome (IBS)
• Intrauterine growth restriction
• Dementia
• Alzheimer’s disease

Industries Contributing to MNPs in the Environment

A wide range of industrial sectors contribute to the release of micro- and nanoplastics into the environment through production processes, product use, and material degradation. Key contributors include:

• Plastic Manufacturing and Pellet Production– Loss of resin pellets and fragments during production, transport, and handling.
• Textile and Fashion Industries– Synthetic fabrics shed microfibers during laundering and routine wear.
• Automotive Sector– Tire abrasion during normal vehicle operation generates significant quantities of microplastic particles.
• Single-Use Plastic Packaging– Fragmentation and improper disposal of packaging materials introduce persistent plastic particles into ecosystems.
• Cosmetics and Personal Care Products– Some formulations, such as certain toothpastes and exfoliating products, contain microbeads that enter wastewater streams.
• Marine and Fishing Industries– Wear and degradation of nets, ropes, and other gear release plastic fibers and fragments into aquatic environments.
• Agriculture and Food Production – Application of sewage sludge, use of plastic mulch films, and irrigation practices can introduce microplastics into soils and waterways.
• Construction and Coatings – Paints, sealants, and other building materials release microplastics through weathering and surface erosion.

Recent Regulatory/Legal Developments

Some recent regulatory and legal events have the potential to impact insurance claims related to MNPs:

The U.S. Environmental Protection Agency (EPA) is currently developing the Sixth Unregulated Contaminant Monitoring Rule (UCMR 6). Scheduled for 2027-2031, the proposal includes monitoring for microplastics in public water systems.

As of January 2026, California’s SB 1053 bans all plastic checkout bags, providing a clearer legal floor for enforcement.

Improved source attribution science “chemical fingerprinting” and oceanographic drift modeling are allowing plaintiffs to link specific plastic waste back to individual producers. This is bridging the “accountability gap” that previously protected companies from liability in diffuse-source pollution cases.

Extended Producer Responsibility laws are scheduled to take effect in early 2026 requiring companies to fund and take responsibility for the entire lifecycle of their products.

As scientific research continues to evaluate potential associations of MNPs and the chemicals involved in their production with a range of disease outcomes, organizations face a heightened risk of environmental, property damage, and product liability claims.

HETI Technical Services

HETI has experienced professionals, assisting clients with environmental health & safety (EHS) support to help reduce risk exposures and costs. Our scientists, engineers, and other technical staff, with expertise in many different market sectors – including chemical, construction, manufacturing, mining, agriculture, retail, real estate, waste management, oil and gas, and transportation – are available for technical reviews, site assessments, and other EHS services.

HETI is also available to assist with loss control program review, engineering guideline development, market sector risk assessment, and other loss control services to help our clients reduce the possibility and severity of losses before they occur.

To learn more about HETI’s EHS And loss control services, please contact us.

Michael McClure, MS, CIH Senior Scientist

Artificial intelligence (AI) is rapidly being adopted across environmental health and safety (EHS) programs. In this context, AI refers to systems that perform one or more cognitive functions: perceiving conditions (such as computer vision and sensor systems), recognizing patterns, predicting outcomes, generating language, or recommending actions. From camera systems that flag unsafe behaviors to algorithms that forecast injury rates and generative tools that summarize regulations, AI is often marketed as a neutral, tireless safety professional that never looks away.

In practice, however, AI systems inherit the assumptions, blind spots, and data limitations of the humans who design and deploy them. When these systems fail, the consequences are not abstract. They are physical injuries, missed hazards, flawed compliance decisions, and false assurances of safety.

A widely reported example occurred in November 2023 at an agricultural distribution center in South Korea, where a worker inspecting a sensor on a robotic lifting system was fatally crushed when the machine’s vision software failed to distinguish him from the boxes it was programmed to handle. This was not a simple mechanical malfunction. The sensors worked and the code executed, but the system lacked the contextual understanding to differentiate between “product” and “person.” 1

This incident highlights a critical vulnerability in modern automation: algorithms do not see the world; they classify patterns based on prior training. When classification fails, the outcome can be catastrophic.

The Illusion of Objectivity in AI Safety Systems

One of the most persistent myths surrounding AI in safety is that it is objective. Algorithms do not evaluate hazards the way an experienced industrial hygienist or safety professional does. They identify statistical patterns in historical data. If that data is incomplete, biased, or unrepresentative of real-world conditions, the system will confidently produce incorrect conclusions.

AI-based camera systems designed to detect missing personal protective equipment (PPE) or unsafe proximity to equipment may perform well in controlled environments. However, glare, dust, shadows, unconventional PPE, or atypical body positioning can cause both missed detections and false alarms. When alerts are frequently incorrect, workers develop automation-driven alert fatigue – a new risk pathway created not by human complacency, but by technological overconfidence.

AI does not understand context. A worker entering a restricted area during routine operations may represent unsafe behavior. The same action during an emergency repair may be necessary and lifesaving. Algorithms enforce rules based on pattern recognition, not situational judgment.

Predictive Analytics and Reporting Bias

Predictive safety platforms claim to forecast injuries by analyzing incident reports, near misses, and behavioral observations. In theory, this allows earlier intervention. In practice, these systems often amplify existing reporting biases.

If near misses are underreported or minor incidents are discouraged from documentation, the model interprets the absence of data as the absence of risk. High-risk tasks may appear statistically “safe” simply because events were normalized and never recorded. Conversely, more visible or recently scrutinized work groups may appear disproportionately risky.

Early adopters of predictive tools have discovered that models frequently prioritize frequency over severity. Numerous minor ergonomic complaints may outweigh a single low-frequency but catastrophic process safety hazard. Human safety professionals recognize that low-probability, high-consequence risks demand disproportionate attention. Many algorithms do not.

Generative AI in Safety Practice: A New Risk Frontier

For many safety professionals, exposure to AI now occurs primarily through generative large language models (LLMs). These tools are increasingly used to summarize standards, draft safety procedures, generate training materials, and interpret regulatory requirements.

While efficient, generative AI introduces distinct failure modes, LLMs may produce confident but incorrect regulatory interpretations, fabricate citations, oversimplify complex compliance obligations, or omit critical exceptions. Because their language is fluent and authoritative in tone, errors may go undetected unless carefully reviewed by a qualified professional.

In safety and compliance contexts, an inaccurate summary of an Occupational Safety & Health Administration (OSHA) requirement or a misinterpreted exposure limit is not a minor inconvenience; it may influence policy decisions, documentation, or enforcement posture. Generative AI can assist with drafting an information synthesis, but it cannot replace regulatory expertise, professional judgment, or legal accountability.

Automation Does Not Eliminate Risk – It Redistributes It

Automation in robotics, material handling, and industrial systems has improved efficiency and reduced certain physical exposures. In narrow, repetitive, well-controlled tasks, AI systems may outperform humans in speed and consistency.

However, automation does not remove risk; it redistributes it. Mechanical risks may decrease while systemic, classification, oversight, and governance risks increase. When organizations treat AI as a replacement for hazard analysis rather than as an input to it, failures become inevitable.

AI is trained on historical data. Safety, by definition, is concerned with preventing novel and future harm. Algorithms codify past patterns; they do not anticipate unprecedented failure modes.

A Realistic Role for AI in Health and Safety

AI can be valuable when treated as an assistant rather than an authority. It can surface weak signals, identify trends across large datasets, reduce administrative burden, and support documentation efficiency.

The most effective safety programs treat AI outputs as prompts for professional evaluation, not final determinations. When an algorithm flags risk, a competent safety professional investigates. When it reports no risk, that absence is questioned rather than accepted blindly. AI should augment the foundational principles of anticipation, recognition, evaluation, and control – not override them.

Technology Does Not Eliminate Responsibility

Health and safety failures involving AI are rarely failures of technology alone. They are failures of governance, expectation management, and professional oversight. No algorithm can be held accountable during an OSHA inspection, deposition, or incident investigation. Responsibility remains with employers and safety professionals.

As AI becomes more embedded in EHS systems, the need for human expertise becomes more critical – not less. The central question is not whether AI can improve safety. It is whether organizations understand its limits before those limits result in harm.

ETI: Professional Judgment in an AI-Driven Safety Landscape

HETI’s team of certified industrial hygienists and experienced environmental health & safety professionals helps organizations critically evaluate and responsibly integrate AI-based tools into comprehensive EHS programs. Our services include assessing automated system limitations, validating AI-generated safety data through field verification, identifying gaps in hazard recognition, and ensuring that professional oversight remains central to risk management decisions.

By combining technical expertise, regulatory knowledge, and real-world observation, HETI helps clients use artificial intelligence to enhance safety performance without compromising worker protection.

Reference-

1 The Guardian. “Industrial robot crushes man to death in South Korean distribution center,” citing Yonhap News Agency, November 8, 2023. Retrieved January 20, 2026. https://www.theguardian.com/technology/2023/nov/08/south-korean-man-killed-by-industrial-robot-in-distribution-centre

To find out more about HETI’s industrial hygiene and safety services, please contact us.

Daniel Farcas, PhD, CIH, CSP, CHMM Senior Industrial Hygienist

Occupational noise exposure remains one of the most prevalent workplace health hazards in the United States. Widely cited national data indicate that approximately 25% of all U.S. workers have been exposed to hazardous noise during their working lives. Beyond its prevalence, social impacts, and clinical implications, the economic burden is significant. National surveillance data estimate that occupational hearing loss accounts for approximately $242 million each year in workers’ compensation costs related to hearing loss disability. This figure reflects only direct claim costs and does not capture broader impacts such as lost productivity, retraining, medical management, or reduced quality of life.

What makes occupational noise exposure particularly impactful is that it can result in permanent damage, even though its progression is often gradual and painless. By the time hearing loss is identified, the underlying damage has already occurred and cannot be reversed. At the same time, noise-induced hearing loss is one of the most preventable occupational illnesses when exposure is identified and addressed proactively.

Widespread Exposure, Often Unrecognized

Hazardous noise is frequently associated with obvious industrial environments, such as manufacturing floors or construction sites. In practice, excessive noise exposure occurs across a wide range of operations – such as facilities management, utilities, warehousing, laboratory support areas, mechanical rooms, and intermittent maintenance activities.

A significant challenge in managing occupational noise lies in human perception. Through sensory adaptation, constant input becomes less noticeable over time – much like how a smell fades shortly after entering a room or how conversation can be followed in a crowded space despite background noise. This adaptive response reflects how human perception developed to prioritize meaningful cues. In modern workplaces, the same sensory adaptation can cause sustained hazardous noise levels to feel routine, even as physiological damage continues to accumulate.

Human behavioral factors also contribute to the challenges associated with occupational risk management, including noise hazards. Workers may naturally discount risks that are diminished by sensory adaptation, do not produce immediate symptoms, feel temporary, or are perceived as interfering with task completion. This dynamic is common with noise exposure, where short-duration tasks are often assumed to pose minimal risk despite cumulative or high-level exposure potential. A familiar example occurs outside the workplace: the inconvenience of grabbing hearing protection for a brief activity, such as operating a weed trimmer, can outweigh concern for potential hearing loss.

Permanent Outcomes Extend Beyond Hearing Loss

Noise-induced hearing loss is characterized by typically permanent anatomical damage. However, the consequences extend beyond hearing loss documented on an audiogram.

From a safety perspective, reduced auditory acuity can impair verbal communication, diminish the ability to recognize alarms, warning signals, or approaching equipment, and reduce awareness of hazardous noise conditions themselves. In environments where situational awareness is critical, these limitations can increase the likelihood of secondary incidents and delay corrective actions when noise exposures exceed safe levels.

There are also important mental health and psychosocial considerations. Chronic noise exposure and hearing loss have been associated with increased fatigue, cognitive strain, difficulty concentrating, and social withdrawal. Multiple studies indicate that adults with moderate or more advanced hearing loss are more likely to experience mental health challenges than those without hearing impairment.

Regulatory Framework and Measurable Thresholds

Occupational noise is one of the most measurable workplace exposures, with clearly defined regulatory criteria. Under the Occupational Safety & Health Administration’s (OSHA’s) Occupational Noise Exposure Standard (29 CFR 1910.95), a hearing conservation program is required when employee noise exposures reach the action level of 85 A-weighted decibels (dBA) as an eight-hour time-weighted average (TWA). The permissible exposure limit (PEL) is 90 dBA as an eight-hour TWA.

Despite the clarity of these thresholds, many programs remain reactive – initiated only after audiometric shifts or compliance concerns are identified rather than through proactive exposure evaluation and risk control.

Prevention is More Efficient than Program Repair

Early evaluation of noise exposure often identifies straightforward opportunities for risk reduction – including targeted engineering controls, equipment modifications, or administrative adjustments. Addressing noise hazards during facility design, process changes, and routine risk assessments allows organizations to manage exposure before permanent health effects occur.

By contrast, correcting deficiencies after hearing loss has been documented typically requires expanded monitoring, program restructuring, and long-term medical surveillance – increasing both cost and administrative burden. Preventing exposure supports effective risk management while demonstrating a commitment to protecting workers from permanent, avoidable health impacts.

Elements of an Effective Noise Control Strategy

Effective noise management follows risk assessment techniques and the well-established hierarchy of controls. Risk assessment often begins with data gathering through measurement – whether dosimetry for personal exposure evaluation or noise level monitoring of areas or equipment. Engineering controls – such as source modification, equipment enclosures, vibration isolation, or selection of lower-noise alternatives – provide the most reliable exposure reduction. Administrative controls, including task rotation and exposure-time management, may further reduce risk when engineering solutions are limited.

Hearing protection devices remain an important component but should be considered the last line of defense, not the primary control. While critical as an interim protective measure when noise hazards are identified, hearing protection is too often implemented in place of more effective engineering or administrative controls. Personal Protective Equipment (PPE) can become the preferred solution because it feels immediate and convenient, rather than because it provides the most effective risk reduction. When not supported by exposure data, appropriate selection, and training, reliance on hearing protection can limit communication and recognition of auditory hazard cues such as alarms or approaching equipment.

Implementing these measures effectively often requires objective data, technical expertise, and a clear understanding of regulatory expectations.

HETI’s Role in Proactive Noise Management

Given the widespread nature of occupational noise exposure and the permanence of its effects, early, data-driven evaluation is essential. HETI supports clients across regulated industries through noise exposure assessments, personal dosimetry, hazard control design, and hearing conservation program evaluations aligned with regulatory requirements and best practice standards.

HETI’s noise control evaluations are led by experienced Certified Industrial Hygienists (CIHs) with expertise in noise exposure assessment, regulatory compliance, and practical risk control.

HETI’s approach emphasizes practical, defensible recommendations that support compliance while prioritizing prevention. In many cases, early assessments identify manageable exposure pathways before they result in irreversible health outcomes, regulatory scrutiny, or costly remediation. Occupational hearing loss should never be the indicator that action was needed. Noise hazards will always be widespread and capable of causing permanent harm, but with proactive evaluation and effective control design, the outcomes become manageable – and workers remain safe, healthy, and protected.

To find out more about this and other HETI industrial hygiene services, please contact us.

Ben MacDonald, CIH, CSP Senior Industrial Hygienist

Insurance loss control, risk engineering, or risk consulting are all synonymous with risk management techniques that aim to reduce the possibility and severity of losses before they occur. Loss control is an important tool to assist insurance underwriters in understanding the risks associated with the operations, programs, policies, procedures, and culture of the policyholder. The process ideally should take place prior to binding coverage; however it can be conducted at any point during the policy period and/or during the renewal.

Loss Control Coverage Lines

Loss control can be conducted on any insurance product line – most commonly including:

Property – Evaluation of physical assets insured by a policy – including valuation of assets; identification of operational and maintenance procedures, fire suppression systems and other life safety programs; evaluation of potential claims scenarios, including natural disasters; and likely replacement costs.

General Liability (GL)– Evaluation of safety and security/access procedures with the goal of understanding risks to third-party exposures at the insured location and/or off-site operations (excluding pollution liability). Third parties could include: temporary workers, site visitors (vendors, subcontractors, clients, inspectors, delivery drivers), company employees working remotely at a customer location, and adjacent property/ business owners. GL coverage would include claims for property damage or bodily injury to any of the parties.

Environmental – Evaluation of environmental/pollution risks associated with the insured’s operations. This could include hazardous chemicals and waste on site and storage/controls in place for those materials; environmental permits in place and compliance with those permits; proximity to environmentally-sensitive receptors (i.e., surface waters, natural areas, residential dwellings, schools, hospitals, etc.); historic usage of the site and the potential for related legacy environmental issues; and a review of the insured’s environmental programs and stewardship.

Fleet/Auto– Evaluation of commercial fleet and auto operations by the insured, including driver hiring and training practices; fleet maintenance practices; fleet monitoring and safety programs; review of claims and Department of Transportation records and use of fleet vehicles (work only vs. personal usage).

Products Liability – Product risks can be divided into two categories: Product Liability and Product Pollution risks. For product liability risks, a loss control assessment will focus on the products themselves, their usage in the marketplace, potential for misuse, customer base, the raw materials and manufacturing processes involved, and the overall quality controls in place to ensure the products do not pose a risk to customers or the general public. A product pollution risk assessment will center on the raw materials, intermediate products, and the finished goods to evaluate the potential of the products to contaminate a customer’s product or cause a pollution condition for end users.

Workers’ Compensation – Assessment of worker training programs, personal protective equipment that is required, accident/incident investigation procedures, worker health and safety programs, back-to work programs, occupational disease, and claims evaluation for frequent and repetitive incidents.

Generally, loss control can be divided into subcategories that involve:

• Risk Identification– assessment of current risks for the insured and their potential impact for the insurer.
• Risk Mitigation– identification of practices to reduce risk for both the insurer and the insured.
• Implementation – use of plans, practices, training, and other tools, identified in the Risk Mitigation phase, to reduce the overall risk for both the insured and insurer.
• Follow Up – assessment of the Implementation phase, revision to plans and programs, revision to any formal recommendations, and compliance/reevaluation of overall risks – addressed in the initial review.

Methods of Conducting Loss Control

Loss control can be conducted in a variety of ways. The insurance carrier may establish key risk factors – important to their policy – to be addressed under each coverage line, sometimes involving particular focus on one or more risks. Once those risk factors are identified, the loss control data collection can be conducted by one of the following methods:

Desktop Review– A review of available information (i.e., internet, publicly available sources, and submission documents). A desktop review can be performed for any of the above-referenced lines of coverage with the understanding that limited information on the insured’s actual operations may not be available.

Telephone Survey– Involves providing a general list of topics prior to the call and engaging in a conversation with the insured to ask direct questions about the operations for all the coverages being offered. Phone surveys may involve multiple representatives from the insured to address specific areas of risks and coverage. Further, documents related to the questions can be reviewed (prior to or after the survey) to provide additional detail of the overall risk mitigation programs.

Site Visits– Site visits can include a desktop review and provide similar detail as the phone survey, however it provides a higher degree of risk assessment. While a formal site inspection can be more time-consuming, it allows the insurance carrier or their representative to see firsthand the insured operations, review the plans and procedures in place, and physically identify potential risks to the policies that might not otherwise be apparent from a desktop review or phone survey.

An effective and comprehensive loss control report, regardless of the survey method, assists underwriters and managers in understanding the risks posed by the insured’s operations and rating the account. It can also identify potential areas for exclusions of coverages, and/or deductibles/self-insurance to minimize the potential claims that might arise from unknown or perceived risks, associated with the insured.

HETI Loss Control Services

HETI has experienced professionals, across multiple lines of insurance, to assist insureds and insurers alike with their loss control requirements and help reduce costs – in many different market sectors including chemical, construction, manufacturing, mining, agriculture, retail, real estate, waste management, oil and gas, and transportation.

HETI is also available to assist with loss control program review, engineering guideline development, market sector risk assessment, and other loss control services to help our clients reduce the possibility and severity of losses before they occur.

In the future, HETI Horizons will feature loss control topics specific to a particular insurance coverage or industry sector.

For further information on HETI’s loss control and risk consulting services, please contact us.

John Howard, RG, CPG Theresa Butziger, LPG Anthony Vinci

The U.S. Energy Information Administration, Office of Energy Consumption and Efficiency Statistics, estimates there are more than 120 million residential units in the United States using heating oil as their primary heat source. The U.S. Environmental Protection Agency (USEPA) does not regulate heating oil tanks at single-family residences, as home heating oil tank regulation is primarily handled at the state and local levels. State and local governments often require permits for installation or replacement of heating oil tanks and have established regulations for the cleanup of any spills or leaks. Replacing or installing heating oil tanks should always be done by licensed contractors following standard practices for reliable tank service.

While most leaks from heating oil tanks are typically small and can be remediated with a straightforward removal action, when unnoticed or left unattended, large volumes of oil can be released over time. Larger spills can also occur as a result of misdeliveries or overfills during the fuel delivery process, and older tanks occasionally suffer dramatic failure when over-pressurized during fuel delivery. The extent of impacts to soil and groundwater can also be complicated by the age of the home, foundation construction, and the site setting.

Types of Tanks and Their Regulation

Home heating oil tanks are typically 275-gallon capacity but can range in size from 250 up to 1,000 gallons; and they can be either aboveground storage tanks (ASTs) or underground storage tanks (USTs). Contemporary tanks are typically constructed of coated steel, although fiberglass and steel-fiberglass tanks are available as well. Older tanks are almost always found constructed of bare steel. Tank service life ranges from 20 to 25 years; however, many older residences may have tanks twice this age or more.

Although many homeowners have ASTs located at the rear of the residence, they are normally found in a heated or partially heated part of the home since fuel oil tends to “gel”’ at about 20° Fahrenheit. The most common location is in the basement. Although an AST is easily inspected and small leaks can be detected early, leaking oil inside a basement can cause indoor air quality issues and can seep into the ground along foundation lines. Alternatively, USTs are most often situated outside the building footprint, several feet from the foundation wall, and deep enough to be below the frost line. However, USTs are much more difficult to routinely inspect and to detect leakage.

Leaks from heating oil tanks are predominantly caused by corrosion of the tank, transfer lines, or fill line. Partially full tanks contain air at some level of humidity (tanks are vented so the contents are exposed to the local atmosphere). As temperature changes occur, water may condense out of the surrounding air and collect in small volumes in tanks. Since oil is less dense than water, the water ends up residing at the tank bottom and can lead to corrosion along the bottom centerline of the tank. Occasionally, human error can be the cause of oil releases due to improper installation, loose connections of tank penetration lines, or delivery errors (overfills, delivering fuel oil to fill connections no longer in use, etc.). Routine annual or biennial inspection by a certified tank installer of the tank, fill lines, and transfer lines can catch deficiencies early.

Although USEPA does not regulate home heating oil tanks, all states prohibit releasing substances like fuel oil into the soil, surface waters, and groundwater. Many states have detailed regulatory programs for home heating tanks and/or either guidance or reporting requirements. Some offer incentive funding for homeowners to either upgrade their aging heating oil tank or convert to another heating method (like natural gas or electricity).

Managing Home Heating Oil Releases

The majority of home heating oil releases are relatively minor and can be easily addressed during tank removal or replacement by excavating the impacted soil surrounding the old tank. However, depending on the site setting and the duration of the leak, some heating oil impacts may require a complicated and extensive cleanup effort. For example, highly permeable soils like sand can allow the leaking oil to spread over wider areas and to greater depths. Even lower permeable soil, combined with a long ongoing leak, can lead to a wide area of impact that can be more difficult to remediate. The cleanup of some spill sites can be highly complex due to oil leaking under the home’s foundation or into fractured bedrock. Impacts to both surface water and groundwater can add another layer of complexity.

Remediation costs can vary widely depending on the complexity of the cleanup and can range from $25,000 to more than one million dollars. Depending on the homeowner’s financial position, these costs can be devastating and can sometimes match the value of the home itself. Many state programs provide incentives/funding grants to replace aging tanks; or to provide grants or loans for remediation of soil and groundwater impacted by leaking fuel oil. Some states have mandated that homeowners’ insurance policies include some form of coverage for remediation or that insurance companies actively offer riders as available add-ons to homeowners’ policies.

HETI…Here to Help

Replacing aged tanks and sticking to a regular inspection/maintenance program for the heating oil system can minimize leaks or at least catch leaks early before remediation costs spiral. The current regulatory trend is to offer incentives for good tank practices; to offer grants/loans for remediation; and to require that insurance policies cover leaking tanks.

HETI offers a technical staff with extensive experience in home heating oil releases, insurance and regulation. So whether a client is looking for emergency response service, remedial solutions, or regulatory support, our licensed professionals are available to provide expert and efficient service.

To find out more about HETI’s environmental services, please contact us.

Ron Adams, PE, LSP, LSRP Senior Engineer