CTI EHS Blog

New NFPA 652: Standard on Combustible Dust

2014-01-06T20:27:52Z

NFPA 652, Standard on Fundamentals of Combustible Dust is a new combustible dust standard that is currently under development by the National Fire Protection Association’s Fundamentals of Combustible Dusts Committee. The committee will be holding its second Draft Meeting in St. Petersburg, FL, which Brian Edwards, PE will be attending to learn more about the direction of the standard.

In its current form, NFPA 652 is designed to be the single standard that will be used in addressing general combustible dust compliance at facilities. It will be the standard that all of the industry specific standards cite in regards to providing the specific properties and tests for determining whether a dust is combustible, as well as requirements for collection of the samples.

Additionally, NFPA 652 consolidates the performance-based design option and process hazard analysis methods from the combustible dust standards. These other standards will likely begin referring to NFPA 652 in regards to these topics, and for topics on hazard management, mitigation and prevention, and for management systems. The hazard management chapter provides the design and programmatic requirements for a variety of facility equipment and processes in order to manage a combustible dust hazard. This chapter includes things like separation and segregation, and velocity design requirements for dust collectors and dust collection lines. Finally, the management systems chapter includes all of the management specific topics seen in the other standards, such as maintenance and training requirements.

By pulling all of the general combustible dust standards like housekeeping, hazard analyses, and PPE from the industry specific standards, NFPA is providing more correlation between the standards. It is also allowing for the other dust standards to be more streamlined and focused on the industries that they cover.

Conversion Technology engineers to wear FRC when conducting Combustible Dust Hazard Analysis

2013-11-02T16:00:34Z

Flame resistant clothing (FRC) has been used for years in a number of industries to protect workers from flash fires, arc flash, embers, molten metal, and other potential sources of ignition to clothing. The reason FRC is so important is that many fatalities have occurred because a worker's clothing has caught on fire, exposing him/her to burning heat for a much longer time than would have occurred during the initial event (e.g. arc flash, vapor flash fire).

When looking at burn victims, there is a "magic" number - well, more accurately, a statistically relevant number - that predicts if the victim has a better chance of surviving ... or dying. This number is 50%. Meaning, when the percent of a person's body with 2nd or 3rd degree burns exceeds 50%, it is more likely that he will not survive. FRC is extremely valuable in minimizing the percentage of 2nd/3rd degree burns for a person exposed to a flash fire or other short duration thermal exposure (less than 3-4 seconds). It does this not by providing insulation, rather, FRC resists catching on fire and becoming a source of burns itself.

As I mentioned earlier, a number of industries have adopted FRC as standard issue clothing - think petroleum refining and steel mills. One area where the need for FRC has become more apparent is for workers potentially exposed to combustible dust flash fires. When combustible dust is suspended in air in sufficient concentrations, and there is a source of ignition, a flash fire very similar to that of a vapor fire can occur. Workers in the vicinity can be exposed to both the initial event, but they also stand the risk of having their clothing ignite. Because of this, NFPA 654 - Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids - now details the need for considering FRC as part of the hazard analysis conducted for an industrial plant where combustible dust is present.

At Conversion Technology, Inc. (CTI), our safety and environmental engineers have long wore FRC when it was required by our client's facility. However, we have noticed that a large percentage of industrial facilities with potential combustible dust hazards have not considered FRC in their Personal Protective Equipment (PPE) hazard assessment. Therefore, we have decided that regardless of the Client's requirements, we will require all engineers conducting combustible dust hazard assessments to wear FRC while on site.

Not all facilities who process and handle combustible dust will need to require FRC. Part of CTI's scope of work while conducting a combustible dust hazard assessment is to determine whether or not FRC is needed. However, until we have made that determination, our engineers will not know if they will be walking into an area where they are potential exposed to a dust fire hazard. This unknown is why we have made this decision.

We hope that all facilities that handle and process combustible dust will make the effort to determine if workers are potential exposed to combustible dust fire and explosion hazards. Conversion Technology is available to help those that need assistance in making this determination.

Are your employees at risk of isocyanate exposure?

2013-10-21T22:00:26Z

OSHA has implemented a National Emphasis Program (NEP) to raise awareness of the dangers associated with isocyanate exposure.

Isocyanates are hazardous chemicals that are often found in activities using paints, foam insulation, polyurethane, surface coatings, rubber, and adhesives.

They are powerful irritants to the mucous membranes of the eyes, nose, and throat. Hazardous health effects associated with occupational exposure to isocyanates include irritation of the skin and mucous membranes, hypersensitivity pneumotitis (inflammation in the lungs), and chest tightness. A more serious hazardous health effect resulting from exposure to isocyanates is occupational asthma. Occupational asthma is an illness that can make it difficult to breath and causes chest tightness, wheezing, coughing, and shortness of breath. It is frequently serious and can be fatal. Isocyanates also include compounds that are classified as potential human carcinogens and have been known to cause cancer in animals.

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Because of isocyanate’s toxic characteristics, it is very important that employee exposure to isocyanates is minimized. Facilities should conduct an inspection determining where isocyanates accumulate and how they are spread throughout the facility. An inspection should consist of two primary aspects: Air sampling and wipe sampling. Along with these quantitative inspections, facility activities should also be monitored to determine how isocyanates are spread throughout the facility.

If isocyanates are present at the facility, employees should be notified of the results and the facility should work to implement controls to prevent exposure, such as installing ventilation to remove isocyanates or requiring employees to wear suitable PPE to prevent isocyanate exposure. The facility can also incorporate surface and/or skin safe decontamination solutions into their routine janitorial regimens. These solutions are developed to completely eliminate isocyanates from surfaces or the skin. High traffic areas where isocyanates may be easily spread such as door handles or water fountains may be cleaned using the surface decontamination solution on a regular basis. Additionally, employees can wash their hands using the skin-safe decontamination solution to eliminate isocyanates that may be on their skin after working with hazardous materials.

Contact CTI for more information on how to address your employees' isocyanate exposure. Call 770-263-6330 or email cti@conversiontechnology.com.

OSHA GHS Deadline Approaching Fast…Are You Ready?

2013-07-17T14:28:22Z

The new Globally Harmonized System (GHS) is upon us. OSHA, with help from the U.N. and global community, has updated the HazCom Standard in an effort to standardize and simplify the communication of chemical hazards. Before this new system, a worker handling drums of flammable material from different manufacturers could notice an array of different warning labels. One manufacturer could have labeled the material as “Flammable”, while another could have labeled it as “Extremely Flammable” or even “Caution Flammable Vapors”. The material is all the same, but now there is confusion as to the level of the hazard present. It is for this reason why the GHS is here.

]]> The GHS provides a common and coherent standard for the identification and classification of chemical hazards, along with specific criteria for material labels, which will make information easier to understand and apply. After the GHS is fully implemented, it would make it easier and less expensive for employers to get into compliance. It would also eliminate much of the conflicting standards and practices of different governing agencies (i.e. OSHA, DOT, EPA, etc.)

The GHS is an update to the current OSHA HazCom standard 29 CFR 1910.1200. This update includes specific criteria for presenting chemical information on all labels, including updated pictograms, signal words, precautionary statements, etc. Also, included in this update is a set format for all Safety Data Sheet (SDS’s), formerly known as Material Safety Data Sheets (MSDS’s). The format for SDS’s comprises 16 sections. Some of the sections incorporated are Hazard Identification, accidental Release Measures, Exposure Control, etc. The new format is very similar to the old format, for those of you who are used to reading the old MSDS style.

While the GHS seems as though it is going to cost employers too much time and money to get into compliance, especially when thinking of the time needed to re-train all employees on the HazCom standard, it will pay off in the long run. The new standard will allow more employees to understand the necessity and comprehension of potential chemical hazards that they may come into contact with. This standard will also give employees the knowledge of how to identify the proper exposure prevention, clean up, and emergency procedures involved in chemical handling. In the end, with workers able to understand better the risks and procedures for chemical handling accidents and injuries, and consequently worker compensation costs, will decrease.

The GHS outlines several dates during the transition period that employers need to meet. These dates include:

Regulatory Update for Major and Area Source Boilers (MACT/GACT)

2013-02-08T15:41:51Z

On January 31, 2013 the U.S. Environmental Protection Agency (EPA) published in the Federal Register the final rule 40 CFR Part 63: National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.

]]> BOILER MACT: In general, this final rule requires facilities classified as major sources of HAP with affected boilers or process heaters to reduce emissions of harmful toxic air emissions from these combustion sources. This will improve air quality and protect public health in communities where these facilities are located.

The compliance dates for the rule are January 31, 2016, for existing sources and, January 31, 2013, or upon startup, whichever is later, for new sources. New sources are defined as sources that began operation on or after June 4, 2010.

Existing boilers have until April 31, 2013, to submit their Initial Notification. New sources must comply by January 31, 2013, or upon startup, whichever is later. New sources are defined as sources which commenced construction or reconstruction on or after June 4, 2010.

Existing boilers will have to complete the following no later than January 31, 2016:

Meet the requirements during periods of startup and shutdown.
Conduct performance tests to demonstrate compliance with all applicable emission limits.
Boiler tune-up
Energy Assessment

BOILER GACT: In general, the final rule requires facilities classified as area sources of HAP with affected boilers to reduce emissions of harmful toxic air emissions from these combustion sources, improving air quality, and protecting public health in communities where these facilities are located.

The compliance date for existing sources is March 21, 2014. The compliance date for new sources that began operations on or before May 20, 2011 is May 20, 2011. For new sources that start up after May 20, 2011, the compliance date is the date of startup. New sources are defined as sources that began operation after June 4, 2010.

Existing boilers have until January 20, 2014, to submit their Initial Notification.

Existing boilers will have to complete the following no later than March 21, 2014:

Boiler tune-up
Energy assessment

For more information visit our website: www.boilermactcompliance.com

EPA Boiler MACT Regulatory Update

2012-12-22T00:21:59Z

On December 20, 2012, the US EPA issued final changes to Clean Air Act standards for major and area source boilers and commerical/industrial solid waste incinerators. For Area Source Facilities (Boiler GACT): The final adjustments do not change the intended coverage of the air toxics standards for industrial, commercial, and institutional boilers and will not affect the estimated emission reductions, control costs or the benefits of the standards in substance. The adjustments do not impose any additional regulatory requirements beyond those imposed by the previously promulgated boiler area source standards and, in fact, will afford relief to some boilers.

EPA is issuing adjustments to the March 2011 standards based on evaluation of additional information provided to the agency since that time, including the following key changes:

Extending by two years the initial compliance date for existing area source boilers subject to the tune-up requirement.
Revising the deadline for initial notification for existing area source boilers to no later than January 20, 2014.
Revising provisions for existing dual-fuel fired units that fuel switch from gas to coal, biomass or oil such that they would still be considered existing sources.
Providing subcategories for seasonally-operated boilers and limited-use boilers.
Requiring tune-ups every five years, instead of every two, for certain area source boilers: seasonally-operated units, limited-use units, small oil-fired units and units with oxygen trim systems.
Clarifying that temporary boilers and residential boilers are not part of the source categories being regulated.
Revising particulate matter (PM) emission limit requirements such that combustion of oil meeting certain sulfur content requirements by new oil-fired boilers is considered an alternative method of meeting the PM emission standard and that such units are not required to meet the PM emission limit.
Reducing the fuel sampling and performance testing requirements such that after demonstration of initial compliance, under certain circumstances, further fuel sampling for boilers subject to a mercury emission limit and further PM performance testing for boilers subject to a PM emission limit is not required.
Providing the option of continuous emissions monitoring to demonstrate continuous compliance with the carbon monoxide (CO) emission limit.
More clearly defining the scope of the energy assessment and allowing for more streamlined assessments, including allowing sources already operating under certain energy management programs to satisfy the assessment requirement.

For Major Source Facilities (Boiler MACT): Existing sources must comply with the standards 3 years from the date of publication of the final revised standards, and if needed, may request an additional year.

With these adjustments, the EPA is:

Adding new subcategories for light and heavy industrial liquids to reflect design differences in the boilers that burn these fuels.
Adding new emission limits for particulate matter (PM) that are different for each biomass fuel subcategory to better reflect emissions during real‐world operating conditions.
Adding new emission limits for carbon monoxide (CO) based on newly submitted data that shows CO emissions from boilers vary greatly. EPA is setting new limits to more adequately capture that variability.
Allowing alternative total selective metals emission limits to regulate metallic air toxics instead of using a PM as a surrogate, allowing more flexibility and decreasing compliance costs for units that emit low levels of HAP metals.
Replacing numeric dioxin emission limits with work practice standards to reflect a more robust analysis that shows dioxin emissions are below levels that can be accurately measured.
Increasing flexibility in compliance monitoring by adding alternative monitoring approaches for demonstrating continuous compliance with the PM limit.
Adjusting PM and CO emission limits for units located outside the continental United States to reflect new data and to better reflect the unique operating conditions associated with operating these units.
Continuing to allow units burning clean gases to qualify for work practice standards instead of numeric emission limits. EPA is removing the hydrogen sulfide (H2S) fuel specification from the rule because it does not provide a direct indication of potential hazardous air pollutants (HAP) from combustion of gaseous fuel. Instead, mercury content alone is being used to determine clean gas.

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Combustible Dust Presentation for OSHA VPPPA

2012-11-09T15:43:26Z

Over the Summer of 2012, Brian Edwards, PE, Director of Engineering for CTI, had the opportunity to speak at 5 regional conferences of the OSHA Voluntary Protection Program Participants Association (VPPPA), as well as the 2012 National VPPPA conference. Video from the Region 4 conference in Chattanooga, TN has been posted on Youtube.

Please check out the presentation here: http://www.youtube.com/watch?v=PFi-RwNLkLM

Update of the Regulatory Status of Boiler Area Source (GACT) Rule

2012-07-20T16:27:40Z

Sources are required to submit a Notification of Compliance Status regarding the initial tune-up by July 19, 2012.

On March 13, 2012, the EPA issued a No Action Assurance (NAA), stating that it would not enforce the Notification. The NAA states that it remains in effect until either (1) October 1, 2012, or (2) A final rule addressing the proposed reconsideration of the Area Source Boiler Rule, whichever occurs earlier.

On July 18, 2012, EPA extended the NAA for Boiler Area Source to December 31, 2012, or until the final rule is issued whichever occurs earlier.

For more information visit www.boilermactcompliance.com.

Georgia Industrial Stormwater Permit Update

2012-04-17T21:14:32Z

The Georgia Environmental Protection Division (EPD) has revised the 2006 NPDES General Stormwater Permit for Industrial Activity. This permit expired on July 31, 2011. According to the Georgia EPD, the 2012 Industrial Stormwater General Permit No. GAR050000 (IGP) was signed on April 16, 2012 and is going to become effective on June 1, 2012. All facilities that are currently operating under the 2006 IGP are required to continue compliance under that permit’s specification until the new permit is in effect. ]]> Normal 0 false false false EN-US X-NONE X-NONE

Upon issuance of this new permit, the Notice of Intent (NOI), and No Exposure Exclusion (NEE) are due to the EPD no more than 30 days after the effective date of the permit. Due to the extended holdup of the permit, the next Annual Report deadline has been pushed back until January 31, 2013. This Annual Report will include the rest of 2012 and all of 2013.

A Stormwater Pollution Prevention Plan (SWP3) must be prepared before submitting the NOI for new dischargers. Existing permitted facilities must have an updated SWP3 within 90 days of the effective date of the 2012 IGP. Any proposed modifications need to be implemented within 180 days of the effective date of the 2012 IGP.

Under this permit, site inspections and evaluations are required to be conducted quarterly, at a minimum. These inspections should be conducted for all areas of the facility where industrial materials are exposed to stormwater, and there should be added focus on control measures during these inspections. An inspection must be conducted at least once per calendar year when stormwater discharges are occurring.

Among many changes from the 2006 IGP, there are significant modifications to monitoring and sampling requirements. Specifically, the permit will now have sector specific benchmarks, which are target values set for stormwater sampling results. Permitted facilities must monitor for any benchmark parameter specified for their industrial sector. This benchmark data is primarily for facilities to determine the effectiveness of control measures.

In addition to sector specific benchmarks, Impaired Stream benchmarks are included in the permit. Every facility needs to evaluate if their receiving water, within 1 mile of each outfall, is impaired, even if it was not classified as impaired in the previous permit. An exceedence of these sector or impaired stream benchmark values is not a violation; however, the facility will be required to evaluate administrative and physical controls used to reduce stormwater pollution and take feasible corrective actions.

If, during a site inspection, unauthorized discharges are observed, or a facility determines that control measures need to be added or modified, the need for corrective actions must be reviewed. Within 24 hours of discovery of these unauthorized discharges or incidents of non-compliance, a facility must identify and document any triggering conditions, descriptions of the problems, and the date the problem was identified. Within 30 days of discovery, facilities must document a summary of the corrective actions to be taken, the date(s) the corrective actions are initiated, and the date(s) the corrective actions are expected to be completed. Modifications must be made no more than 90 days after discovery.

There are several other important aspects of the new permit that will affect industrial activities. A few of these components are:

· Vehicle and equipment wash water is considered an unauthorized non-stormwater discharge. If a facility is currently washing vehicles and equipment outside, that is not approved under this permit, and the facility will have to come up with a course of action for disposal.

· Waste pile leachate, over de minimus amounts, is also considered an unauthorized non-stormwater discharge and is not eligible for coverage under this permit.

· All employees who work in the areas where industrial materials or activities are exposed to stormwater must be properly trained. It is required that training be conducted at time of hire and refreshed annually for existing employees.

· Smoke/Dye testing must be performed at least once during the permit cycle to evaluate for the presence of non-storm water discharges into the storm sewer system from all floor drains, and from all sinks in industrial areas (excluding eye wash stations) that were installed prior to January 2006.

We have already begun updating the SWP3s for a number of our clients.

Please contact CTI if you have any questions or would like assistance in bringing your SWP3 and facility into compliance with the new permit.

http://conversiontechnology.com/

The US EPA "No Action Assurance" for GACT Tune-up

2012-03-19T19:01:57Z

On March 13, 2012, the US Environmental Protection Agency, Office of Enforcement and Compliance Assurance, provided notice to associations and group representatives of owners of existing Area Source (GACT) boilers that the agency will exercise its discretion not to pursue enforcement for violations of the deadline to complete initial tune-up required in the final rule by March 12, 2012. In addition, the US EPA recently published a proposed re-consideration of the Area Source Boiler Rule that would postpone the tune-up from March 12, 2012 to March 12, 2013. This "No Action Assurance" applies to only the timelines of tune-up and the US EPA notes that nothing in this "No Action Assurance" affects any other provisions in the Area Source Boiler Rule. The "No Action Assurance" is to remain in effect until either (1) 11:59PM EDT October 1, 2012, or (2) the effective date of a final rule addressing the proposal reconsideration of the Area Source Boiler Rule, whichever occurs earlier.

The Collins Amendment Does Not Pass Senate Vote

2012-03-13T15:36:47Z

On March 8, 2012, the US Senate voted by a 52-46 vote (60 needed to pass), to dissapprove the Collins Amendment (SA 1660). This Amendment requested to include the US EPA Regulatory Relief Act of 2011 in the Senate Transportation Bill (S.1813). The amendment would have given the US EPA more time to modify the Boiler MACT related rules, including the Non-Hazardous Secondary Materials that are the Solid Waste Rule.

For more information on the Boiler MACT Rules, visit www.boilermactcompliance.com

Upcoming Events

2012-02-22T21:49:27Z

I will be speaking on Combustible Dust Safety at the following conferences:

Region 8 VPPPA 2012 Conference (May 2-3 @ Greenwood Village, Colorado) - website
Region 7 VPPPA 2012 Conference (May 8-9 @ Des Moines, Iowa) - website
Region 6 VPPPA 2012 Conference (May 17-18 @ Fort Worth, Texas) - website
Region 1 VPPPA 2012 Conference (June 11-13 @ Killington, Vermont) - website
Region 4 VPPPA 2012 Conference (June 19-21 @ Chattanooga, Tennessee) - website
28th Annual National VPPPA Conference (August 20-23 @ Anaheim, California) - website

Proposed Changes to the Non-Hazardous Secondary Materials That Are Waste (NHSM) Rule

2011-12-08T20:28:29Z

On December 2, 2011, the EPA Administrator, Lisa P. Jackson, signed a notice and EPA is submitting it for publication in the Federal Register (FR). The proposed changes to the NSHM rule, include:

In the case of “clean cellulosic biomass,” EPA is identifying specific materials that EPA believes are included within the current definition and would thus be considered a traditional non-waste fuel, including: agricultural derived biomass, other crop residues (including vines, orchard trees, hulls, seeds), other biomass crops used for the production of cellulosic biofuels, hogged fuel, untreated wood pallets, wood pellets, and wood debris from urban areas.

Adding a process for an owner or operator of a facility to petition EPA to categorically list non-hazardous secondary materials as being a non-waste when used as a fuel, including allowing other relevant factors beyond those used in the original rule - EPA is proposing to create a rulemaking petition process that would provide persons an opportunity to submit a rulemaking petition to the Administrator, seeking a categorical determination for additional NHSMs to be listed as non-waste fuels. To be successful, the petitioner would need to demonstrate that the NHSM has not been discarded, and either meets the previously established legitimacy criteria, or, after balancing the legitimacy criteria with other relevant factors, the NHSM is not a solid waste when used as a fuel.

Identifying two secondary materials, resinated wood products and tires managed under the oversight of established tire collection programs, as non-wastes when used as a fuel - EPA is proposing to categorically list several NHSMs as not being solid waste when burned as a fuel in a combustion unit where the Agency has sufficient information to determine that discard is not occurring when these materials are being used as fuels.

Revising the legitimacy criteria to expressly allow the comparison of groups of contaminants and clarifying that contaminant comparisons may be made for any traditional fuel for which a combustion unit is designed to burn - EPA is clarifying that similar groups of pollutants (such as volatile organics, semi-volatile organics) can be compared rather than individual contaminants. The proposal also clarifies that in cases where a unit can burn traditional fuels from several categories, such as a boiler that can burn either coal or biomass, contaminant comparisons could be made using data from either fuel category at the combustor’s discretion. In other words, if a facility burns biomass in its combustion unit, but that same combustion unit could also burn coal, the facility could compare its secondary material to either traditional fuel.

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OSHA Combustible Dust Rule Moving Forward

2011-11-14T15:20:33Z

I spoke to an OSHA rulemaker who is working on the long-storied Combustible Dust Safety Rule that has been in the works for over 2 years now (Link to CTI's Blog on the ANPR). The latest news I was told is that the proposed rule is scheduled to move to a Small Business Regulatory Enforcement Fairness Act (SBREFA) review panel in December of 2011.
]]> It is worth noting that the Combustible Dust rule has been slated for SBREFA review before, and delayed. At the beginning of 2011, the rule was on schedule for panel review, but this was delayed in order to hold an Expert Forum (Link to CTI's summary on the Expert Forum).

What does a SBREFA review mean? The below excerpt is taken from OSHA's website (Link to OSHA's SBREFA Page)

OSHA next convenes a Small Business Advocacy Review Panel, consisting of officials from the agency, the SBA's Chief Counsel for Advocacy, and the Office of Management and Budget's (OMB) Office of Information and Regulatory Affairs. The panel hears comments from small entity representatives and reviews the draft proposed rule and related analyses prepared by OSHA. A written report of this interagency panel is submitted to OSHA within 60 days. OSHA reviews the report, makes any appropriate revisions to the rule and publishes the proposed rule along with the panel’s report in the Federal Register.

The SBA's Chief Counsel participates in the small business advocacy review panels and identifies the small entities that the panel should consult. The chief counsel also submits comments on agency proposals. These comments can be viewed on the Office of Advocacy's home page. Concerns about proposed regulations can be addressed to the SBA’s Chief Counsel for Advocacy, 409 3rd. St., S.W., Suite 7800; Washington, DC 20416; or faxed to the Chief Counsel at (202) 205-6928.

H.R. 2250 - EPA Regulatory Relief Act of 2011

2011-10-03T16:20:06Z

On September 13^th, the House Subcommittee on Energy and Power approved H.R. 2250 – The U.S. EPA Regulatory Relief Act of 2011. There is also a companion bill, S.B. 1392, in the U.S. Senate. This proposed legislation, if passed, will stay the Boiler MACT/GACT, Incinerator MACT, and Non-Hazardous Secondary Materials rules. Currently all but the Boiler GACT rules have already been stayed by the EPA. This legislation would stay all four rules for at least 15 month and instruct the EPA to revise the rules according to achievable results. Until the legislation passes, the Boiler GACT deadlines are still in effect. The deadline for initial notification of applicability is still September 17, 2011 and the deadline for compliance is March 21, 2012. H.R. 2250 is expected to be voted on this shortly.