OSHA has many worker protection standards, and it is not uncommon to find two or more standards addressing the same hazards in different ways. In such cases, which standard must an employer comply with?
Category: Hazardous Waste Operations
Q: What pre-medical test should be done for DOT shippers, warehouse people, field inspectors, archaeologists, oil spill clean up crew (i.e. those with a chance of encountering and/or cleaning up hazardous waste)?
After more than 6 years of developing new electronic manifest (e-manifest) regulations and the technology to make electronic submission possible, the EPA is set to launch the national e-manifest system on June 30th. The Final Rule, issued on January 3, 2018, is one of the last steps in the implementation of the e-manifest system. It […]
One motivation behind EPA’s comprehensive revisions of its certification requirements for applicators of restricted use pesticides (RUP) is the need for the federal regulations to catch up with authorized state programs. Issued under authority of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 1974, the original RUP applicator certification requirements (40 CFR part 171) […]
Yesterday we took a closer look at three aquatic or reproductive toxins for which the U.S. Environmental Protection Agency (EPA) will be conducting a new health and environmental assessment under Toxic Substances Control Act (TSCA) reform. The EPA chose 10 chemicals for its first round of evaluations; the remaining 7 chemicals are all known, probable, […]
The U.S. Environmental Protection Agency (EPA) has announced the first 10 chemicals it will evaluate for potential risks to human health and the environment under Toxic Substances Control Act (TSCA) reform. The chemicals were drawn from EPA’s 2014 TSCA Work Plan, a list of 90 chemicals selected based on their potential for high hazard and […]
The final Hazardous Waste Generator Improvements Rule (Rule), published in the Federal Register on November 28, 2016, contains two of what the U.S. Environmental Protection Agency (EPA) refers to as “voluntary programs”—meaning that generators of hazardous waste have the choice of whether to comply with the new programs’ requirements. The first program is a set […]
Q. Because of removing excess chemical inventories one month this year, I changed from being a small quantity generator (SQG) to a large quantity generator (LQG). Which set of requirements should I comply with and for how long?
Q. Can a cell phone be used to meet the communication device requirement for LQG 90 day areas?
The Hazardous Waste Generator Improvements Rule (Rule), finalized on October 28, 2016, will require hazardous waste large quantity generators (LQGs) and small quantity generators (SQGs) to make many changes as to how they manage their hazardous waste. Because the current generator requirements will be in place in most states for months and months to come—that […]