Practical EHS Tips, News & Advice. Updated Daily.
An EHS Hero® subscriber recently asked our experts at BLR® what regulations, if any, applied to a 500 gallon propane tank used for an emergency generator. Do aboveground storage tank (AST) rules apply? What about Spill Prevention, Control, and Countermeasure (SPCC) plans or programs? The answer is brief, but helpful—not only to this individual, but […]
Civil Penalties With a few exceptions, most violations of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) hazardous materials regulations (HMRs) carry a civil penalty of up to $75,000 per day per violation for knowingly violating one of the HMRs. If the violation results in death, serious illness, or severe injury to any person or […]
There is much confusion concerning who an offeror is under the Pipeline and Hazardous Materials Safety Administrations (PHMSA) Hazardous Materials Regulations (HMRs). PHMSA has numerous interpretation letters that attempt to clarify this issue for individual scenarios. We found two letters we think are pertinent to help you determine whether you are an offeror under the […]
Used oil generators include all persons who produce used oil through commercial or industrial operations and vehicle services. The regulations exempt household “do-it-yourselfers,” farmers under certain conditions, vessels at sea or at port, and mixtures of used oil and diesel fuel under certain conditions. If used oil is mixed with hazardous waste, it must be managed […]
The federal regulations you should consider when developing management practices for ASTs include: Clean Air Act (CAA) regulations for tank vapor control, air toxics, and pollution reduction The Emergency Planning and Community Right-to-Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance reporting requirements The Clean Water Act (CWA)-incorporated OPA that […]
How to Qualify for RMP Program Level 1 After determining that a propane storage facility is subject to the RMP regulation, the next step is to identify which program level applies. The U.S. Environmental Protection Agency (EPA) established three program levels that reflect different levels of risk and, subsequently, the level of effort required to […]
RMP Applicability for Propane Storage Facilities As early as November 2013, seven states had already declared states of emergency to allow for delivery of more propane, and that was a month before a massive ice storm struck, affecting power for more than 1.5 million people. By the time winter was over, the National Oceanic and […]