Category: Ask the Expert

Closure Plan

Q. Are there compliance issues that would prevent our installation of a compressor on a concrete slab on which our (now clean-closed) RCRA-permitted hazardous waste boiler sat? Our Closure Plan states that we will close the slab when the facility closes.

Spills During Delivery

Q. If there is a spill of 50 gallons during delivery, do we need to add that in the spill history in the Spill Prevention, Control, and Countermeasure (SPCC) Plan?

Q&A: Storage of DEF Fuel Additives

Recently, one of our subscribers asked the following question: Are there any regulations regarding the storage of DEF fuel additives? This was our answer:

Q&A: Eyewash Locations

Recently, one of our subscribers asked the following question: Is there anywhere specific an eyewash station needs to be placed in a facility? This was our answer:

Q&A: Anhydrous Ammonia Leaks

Recently, we received the following question from a subscriber: What does OSHA say about initial entry into an area with a suspected gas leak of anhydrous ammonia of unknown quantity and the use of an SCBA?

Is Paint a Hazardous Waste?

Q. We spray paint small items such as pumps and motors and puncture the empty paint cans to capture the remaining teaspoon or so of paint that is placed in a drum. Is this remaining paint a hazardous material, and if so, how should we label the drum?

Q&A: Electronic Recordkeeping Rule

Recently, we received the following question from a subscriber about OSHA’s new Electronic Recordkeeping rule: What is the new OSHA tracking rule all about, and when will it go into effect? This was our response:

Q&A: Flammable Liquids in Spray Bottles

Recently, one of our subscribers asked the following question: We have a lacquer thinner solution, a Category 2 flammable liquid, and plan to dispense it from an ordinary quart-sized spray bottle. The solution will be used as a cleaning solution; spray on and wipe off. Will this be a violation of any sort, NFPA or […]

SPCC: Trucking Terminal

Q. Does a trucking terminal need an SPCC plan? A. Although the SPCC regulations are geared to non-transportation-related facilities, in the transportation sector, SPCC rules also apply to many terminals and maintenance facilities, depending on their location and the amount of oil stored on site. A trucking terminal is subject to the rule if it […]