Tag: CAA
Most Misunderstood Regs: The Mercury ‘Beyond-the-Floor’ Standard
Under the CAA’s maximum achievable control technology (MACT) approach to reducing emissions of air toxics, the MACT floor must be at least as stringent as the average emission limitation achieved by the best performing 12 percent of existing sources in the category (for which EPA has emissions information) or the best performing 5 sources for […]
Can Your Clothes Make You Sick? GAO Looking at Formaldehyde in Clothing
While there are no federal limits on formaldehyde in clothing, a recent report by the Government Accountability Office (GAO) may cause Congress and advocacy groups to put pressure on the Consumer Product Safety Commission (CPSC) to revisit the feasibility of imposing such limits. Formaldehyde is a heavily regulated substance and one of a handful of […]
Key Elements of EPA’s Academic Lab Rule
Note that the rule is not regarded by EPA as more stringent than existing regulations. This means that states authorized to run the federal RCRA program are not required to adopt the rule. In fact, while some states have adopted it since promulgation, others have expressed their opposition to it, and the rule may not […]
Taking the Confusion Out of ‘Closed Containers’
Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]