The Container Is Empty, but Is It RCRA Empty?
Although it sounds like a trick question, it’s not. A container that seems empty of all its hazardous waste contents may not be empty enough to avoid being managed as a hazardous waste.
Tag: CFR
Boiler MACT
Q. Will a source having four large gas fired boilers with fuel oil back up trigger the Boiler Maximum Achievable Control Technology Standards (MACT) if it burns oil to avoid high natural gas prices?
RMP Changes Are Here … Almost
It has been 3 years since the ammonium nitrate explosion in West, Texas, killed 15 people, injured hundreds, and caused widespread damage. Just a few months after that event, President Obama’s Executive Order (EO) 13650 set into motion actions by numerous government agencies designed to enhance the safety and security of chemical facilities and reduce […]
Protecting Workers from Lead Exposure Would Have Saved This Employer from Additional Citations
At a municipal storage facility in Danville, Pennsylvania, a painting contractor was conducting abrasive blasting to remove paint from water tanks. An Occupational Safety and Health Administration (OSHA) inspection showed that the workers were overexposed to airborne lead—and to other airborne contaminants as well. If the employer had paid attention to its lead compliance, it […]
These Workers Were Overexposed to Lead … By Any Standard
At a municipal storage facility in Danville, Pennsylvania, a painting contractor was conducting abrasive blasting to remove paint from water tanks. An Occupational Safety and Health Administration (OSHA) inspection showed that the workers were overexposed to airborne lead. As a result, OSHA issued several serious and willful violations against the employer for violations of the […]
The Headworks Exemption
Q. Does the headworks exemption at 40 CFR 261.3 (a)(2)(iv)(A) and (B) apply only to those spent solvents identified in the regulation? If you are below the threshold for the identified solvents, can other solvents be considered exempt?
Employers and GHS: Down to the Wire
The final deadline for the Occupational Safety and Health Administration’s (OSHA) phased-in compliance approach to implementing the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is around the corner—just about 1 month away. This is the deadline that affects all employers covered by OSHA’s Hazard Communication Standard (HCS). Is your organization ready? Here’s […]
Machine Guarding for Robotic Devices
Recently, one of our subscribers asked the following question:
DOT’s New Hazmat Reverse Logistics Rule—What Retailers Need to Know
The U.S. Department of Transportation (DOT) recently finalized efforts to make reverse logistics easier for retailers that have to ship hazardous materials. Yesterday we provided an overview of the new reverse logistics rule. Today we review some specific requirements for those retailers who choose to avail themselves of this new rule’s regulatory flexibility.
PHMSA Issues Rule for Returning Consumer Hazardous Materials
In a final action taken largely in response to a petition it received in 2008, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a final rule establishing a new section (49 CFR 173.157) in its hazardous materials regulations (HMRs) covering reverse logistics highway shipments of certain hazardous materials hazardous materials.