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Will the RMP Amendments’ Audit Provisions Stand?

Based on the settlement in a recent enforcement case involving violations of the Clean Air Act (CAA) Risk Management Program (RMP) discussed in yesterday’s Advisor, it seems likely that the U.S. Environmental Protection Agency (EPA) will maintain the controversial third-party audit provisions of the RMP amendments. Let’s take a look at these requirements and industry […]

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?

California’s Proposed Electronic Recordkeeping Rule Seeks to Provide Guidance

On October 10, 2018, California’s Division of Occupational Safety and Health (DOSH) issued an emergency proposal that would amend its State Plan to require designated employers in the state to electronically submit to federal OSHA their Cal/OSHA Form 300A, which contains data on occupational injuries and illnesses that occurred in 2017; under the proposal, the […]

Proposed Rule Puts States Back in Power Under the CWA Permitting Process

In following President Joseph Biden Jr.’s Executive Order (EO) 13990 on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, on June 2, 2022, the EPA announced a proposed rule to update the regulatory requirements under the Clean Water Act (CWA) Section 401 Certification Rule. The proposed rule will strengthen […]

Protecting Retail Employees on Black Friday

November 25, this year. Retailers have it marked on their calendars and look forward with excitement and dread. Black Friday can often mean big profits for stores, but it can also mean extra danger for their employees and customers because of the rush to get that “special” toy or other item. In addition, the Occupational […]

What You Should Know About Changing Your HazWaste Generator Status?

Stuff happens. One day you’re a conditionally exempt small quantity generator (CESQG) of hazardous waste, and then the next day you realize you’re a small quantity generator (SQG) of hazardous waste. Only it’s not one day that’s the issue; it’s one month, as hazardous waste generator status is determined by the volumes of hazardous waste […]

CourtWatch Judge Rules U.S. Forest Service Violated CWA Regulations

In May, U.S. District Judge Dana Christensen of the U.S. District Court in Montana ruled the U.S. Forest Service (USFS) violated the Clean Water Act (CWA) in its use of fire-retardant materials in areas with waterways without a National Pollutant Discharge Elimination System (NPDES) permit. The judge also ruled the USFS can continue to use […]

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Faces of EHS: Chip Darius Highlights the Joys of Safety Training

Even the most thoroughly developed health and safety program can fall flat without effective training. While on the surface, getting a training program off the ground can seem straightforward, in reality, it’s anything but. Every business has unique contingencies, and, if you don’t take the time to understand and plan for them, any training program […]

Building Managers on the Hook for Lead Paint Safety Requirements

Property management companies (PMC) performing or offering to perform regulated renovations without EPA certification in pre-1978 housing or child-occupied facilities will be subject to stronger enforcement and compliance regulations of the lead-based paint Renovation, Repair, and Painting (RRP) Rule in the future, according to a November 4, 2021, EPA news release. “Health impacts from exposure […]

New Antiretaliation Recommendations from OSHA

Even as OSHA faces ongoing legal action over its electronic recordkeeping and antiretaliation standard, the agency has issued recommended practices to help employers create an environment where employees feel comfortable speaking up. Get more here.