Tag: CFR

The Ups, Downs, Ins, and Outs of Safe Flammable Chemical Storage

Under the Occupational Safety and Health Administration’s (OSHA) revised Flammable Liquids standard (29 CFR 1910.106), every chemical with a flash point below 199.4°F (93°C) is flammable; the word “combustible” is no longer used. But, as before, some chemicals are more flammable than others, and storage and handling requirements are defined by flash point and boiling […]

But It Wasn’t Flammable Before! GHS Changed the Meaning of ‘Flammable Liquids’

A chemical that meets the definition of “flammable” requires special precautions in handling, use, transfer, and storage. But the Occupational Safety and Health Administration (OSHA) has changed the definition of “flammable” throughout its general industry and construction standards to align them with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Most employers […]

Oil Spill Bi-Products and Municipal Landfills

Under the used oil management rules at 40 CFR 279.22(d), upon detection of a release of used oil to the environment (e.g. soil) that is not subject to the underground storage tank requirements of 40 CFR 280, generators of used oil must (among other requirements) “clean up and manage properly the released used oil and […]

Is it safe to say that the RCRA regulations on recyclable materials from which precious metals are reclaimed have not been affected by the 2015 DSW Final Rule?

The 2015 Definition of Solid Waste Final Rule (2015 Final Rule) does not significantly affect the recycling exemption from full RCRA Subtitle C regulation found at 40 CFR 266.70 for precious metals being reclaimed in accordance with the 40 CFR 266.70 provisions. When in the process of revising the 2008 DSW rule, however, EPA did […]

Does My Shipment Qualify for PHMSA’s Small Quantity Exception?

When are you subject to the U.S. Department of Transportation (DOT) hazardous materials requirements? Some of the more onerous regulations environmental, health, and safety (EHS) managers face are the tangled and confusing Hazardous Materials Regulations (HMR) under DOT’s Pipeline and Hazardous Materials Administration (PHMSA). Yesterday we reviewed PHMSA’s responses to three scenarios concerning hazmat transportation […]

Hazmat Transportation Training

When are you subject to the U.S. Department of Transportation’s (DOT) hazardous materials (hazmat) requirements? Some of the more onerous regulations environmental health and safety managers face are the tangled and confusing Hazardous Materials Regulations (HMRs) under DOT’s Pipeline and Hazardous Materials Administration (PHMSA). Today we’ll tackle hazmat transportation training by reviewing PHMSA’s responses to […]

Is Bio-oil Mixed with Motor Oil Used Oil?

Changing environmental situations often requires the U.S. Environmental Protection Agency (EPA) to revisit policies and interpretations of regulations even if the rules themselves are not amended. A case in point is a 1997 EPA policy that precluded the regulation of bio-oils (e.g., vegetable and animal oils) that have been used as lubricants, or for other […]

Used Oil FAQs

The RCRA used oil management standards can serve as a road map to guide used oil handlers (generators, transporters, burners, marketers, processors, and re-refiners) through the various storage, recordkeeping, and cleanup procedures to ensure used oil is handled safely. The used oil regulations are based on the presumption that used oil (i.e., oil contaminated by […]