STP COMPLIANCE EHS REGALERT ROUND-UP
JANUARY 31ST 2025
CLP Regulation Updates – New Hazard Classes (e.g., Endocrine Disrupting Substances)

S. Korea’s OSHA Revised to Address Working in Extreme Temperatures
Ontario and Alberta Revise Workplace Harassment and Violence Provisions
Recent changes in Ontario (ON) and Alberta (AB) highlight a growing focus on workplace violence and harassment in Canada. The amendments require employers to review and potentially update their workplace harassment and violence policies and programs to ensure compliance. On October 28, 2024, ON Bill 190, Working for Workers Five Act, 2024, amending the Occupational Health & Safety Act (OHSA), received Royal Assent and brought into force two revised definitions, “workplace harassment” and “workplace sexual harassment,” effectively expanding the scope of existing protections for both types of harassment to cover such behavior occurring “virtually through the use of information and communications technology.” Under the OSHA, ON employers must prepare a policy concerning workplace harassment and review the policy as often as necessary (at least annually). A written program to implement the policy is also required; therefore, employers with policies
and programs that have not been recently updated and/or reviewed should review these documents as soon as possible to ensure compliance.
More recent amendments to Part 27 of Alberta’s Occupational Health and Safety (OHS) Code on Violence and Harassment, issued under AB Regulation 202/2024, became effective on December 4, 2024. Key amendments repealed and replaced the separate violence prevention plan and harassment prevention plan requirements, consolidating these requirements into one consolidated and prescribed violence and harassment prevention plan. These new integrated plans continue to have a 3-year minimum review schedule. Still, they must also be reviewed when an incident of violence or harassment indicates a review is required (not necessarily after every incident as previously required), when a change may affect the potential for such an incident, and upon the Joint H&S Committee or representative’s request. Other related amendments on preventative training and the investigation and reporting of incidents are largely unchanged but provide clarifications.

The Changing State of Reclaimed Water
On October 1, 2024, California became the second state with a Direct Potable Reuse Program. Direct potable reuse (DPR) introduces reclaimed water, without environmental buffers and treated using advanced methods, directly into a potable water distribution system. Namibia has operated the only full-scale DPR facility since 2002, despite many attempts from jurisdictions around the world to get approval for more. It appears that is about to change. The nation’s first DPR program, in Colorado, became effective just two years ago. Arizona and Florida have published proposed rules, and twelve states have DPR guidelines.
Agencies cite increasing water demand and diminishing supply as primary drivers for these programs; more affordable and proven methods make them practicable. Recycled water has many secondary benefits for business, including better development planning assurance due to stable water supplies and answering ESG considerations since recycled or reclaimed water is considered a form of water reduction. The effects of DPR extend beyond the cities they serve too. It has the smallest carbon footprint of any community water source because it is produced close to where it is used and provides relief for sensitive aquatic ecosystems from reduced withdrawal pressure and contaminated effluent. However, the
progress of DPR as a regulatory movement belies the stalled status of bringing advanced water treatment facilities into production. Public concerns have stymied permitting efforts despite demonstrating safe test methods from pilot facilities.
Florida may help break the logjam. It has been recognized as the national leader in water recycling for a generation. Highly treated reclaimed water augments surface water through its indirect potable reuse (IPR) program and helps Florida recycle nearly half of its wastewater. IPR differs from DPR in that it retains an environmental buffer, but with wastewater involved, IPR also faces strong public resistance. Utilities and agencies in Florida have a track record of IPR implementation they could emulate in promoting the safety and benefits of DPR to end users already acclimatized to water reuse. Florida’s water conservation success makes its recent rulemaking, Advanced Potable Water Reuse System, January 7, 2025, worth watching. It proposes a comprehensive DPR framework, establishing procedures to obtain a permit, construct, modify, operate, and maintain an advanced water purification facility. It includes the requirements for monitoring and reporting once a permit is issued and requirements for the proper operation of advanced potable water reuse systems. In concert with the DPR proposed rule, the agency has also proposed expanding its IPR program to allow groundwater replenishment.