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Tips for Safe Chemical Storage

Many times it’s because workers in areas with many chemicals are tempted to store chemicals alphabetically by common name to make them easy to find—but this is very dangerous practice. Here are a few tips for safe chemical storage: Always store minimum quantities, as specified by OSHA. Purchase chemicals in smallest quantities needed. Inventory chemicals […]

TSCA and the Intent to Manufacture

If you need to determine if a specific carbon nanotube is on the TSCA confidential inventory, you can submit a Bona Fide Intent to Manufacture or Import. The required contents of bona fide intents are listed at 40 CFR 720.25 and are intended to substantiate that a company genuinely intends to manufacture the substance and […]

Why You Should Be Using an Electronic MSDS System

OSHA likes the idea too–as long as employees have immediate access. “Immediate access” means that, in emergencies, the MSDS should be available during the workshift when it was requested. In nonemergencies, it should be available by the next workshift at the latest. Your electronic MSDS system should be: Reliable. Electronic systems must provide reliable access […]

EPCRA FAQ Roundup

Does EPA have any guidance for EPCRA Tier II reporting for tenant leased spaces? Who is responsible for reporting – the building owner or the tenant who has the hazardous chemicals in the leased space? We are not aware of any EPA guidance documents per se concerning Tier II reporting for leased spaces. However, EPA […]

An Easy Recordkeeping Checklist for USTs

Here’s a UST checklist to help you out with the paperwork: Have owners and operators kept on file the following information (40 CFR 280.34(b)): Corrosion expert’s analysis of site-corrosion potential if corrosion-protection equipment not used (40 CFR 280.20)? Documentation of operation of corrosion protection equipment (40 CFR 280.31)? Documentation of UST system repairs (40 CFR […]

TRI and Waste Management-Understanding Key Definitions

Waste management is included under the TRI definition of toxic chemicals that are otherwise used, which refers to activities that are not manufacturing or processing. TRI requires that subject facilities report releases and other waste management of listed chemicals. Facilities must also report transfers of toxic chemicals for waste management to off-site locations. Waste management […]

GHG Standards for Big Trucks

The Standards MD/HD vehicles are typically grouped into seven classes based on gross vehicle weight rating (GVWR), and ranging from 8,501 to 10,000 pounds (Class 2b) to more than 33,001 pounds (Class 8). However, for the purposes of standard-setting, the agencies divided the industry into three discrete regulatory categories: combination tractors, heavy-duty pickups and vans, […]

Getting Organized and Other EHS Recordkeeping Tips

Surprise! Don’t get caught without the necessary records in the event of a surprise EPA or state agency inspection. Here are some tips for getting and keeping your records organized. Employee training records should be filed by date and topic. In an effort to keep employee records organized, most supervisors put employee training records in […]

Some Dos and Don’ts of EHS Recordkeeping

Dos DO talk to your legal counsel before destroying any records. Although federal and state law may require record retention for only a specific period (usually 3 to 5 years), DO talk to your legal counsel before destroying any records. For example, environmental experts advise that biennial reports be kept indefinitely as these reports provide […]

What to Expect from EPA over the Next 5 Years

Now, to achieve these goals, EPA promises to “Pursue vigorous civil and criminal enforcement that targets the most serious water, air, and chemical hazards in communities. Assure strong, consistent, and effective enforcement of federal environmental laws nationwide.” The FY 2011–2015 EPA Strategic Plan is accompanied by five crosscutting fundamental strategies that seek to adapt into […]