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Although it may seem obvious that if you ever owned or operated an underground storage tank (UST) that you are responsible for compliance or cleanup in case of a leak, the fact is that many USTs have long and complicated histories, and identifying the responsible party when, for example, the tank had multiple owners is […]
Sometimes, two heads are better than one. It ought to be that way with temporary workers, who have essentially two employers, both of whom are supposed to be looking out for their safety. But in practice, miscommunication and poorly defined responsibilities lead to gaps in worker training, hazard identification, and supervision that have served to […]
New Definition of ‘Sham Recycling’ Sham recycling refers to claims by a hazardous waste generator that the waste is being recycled when it is in fact being discarded. A new definition at 40 CFR 261.2(g) codifies EPA’s concept of sham recycling: “A hazardous secondary material found to be sham recycled is considered discarded and a […]
Yesterday, we looked at OSHA’s answers to some employers’ questions about training certification and LOTO verification. Today, we’ll look at what OSHA has to say about workers performing maintenance on plug-and-cord-connected equipment covered under an exception in the LOTO rules. Employers often write to OSHA asking for clarifications of its requirements. Sometimes, OSHA writes back. […]
Here’s a question: Your employees carry identification badges that identify the individual employee when it is swiped on an electronic reader. The badges are used for workplace security, documenting time on the clock, and recording attendance in training classes. The badge-swiping system identifies individual employees, but is not equivalent to an “electronic signature.” Is it […]
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 earliest recorded disaster involving ammonium nitrate (AN) occurred on April 16, 1947, in Texas City, Texas. A transport vessel loaded with 2,600 tons of AN caught fire; when the fire spread to the sealed storage hold, the transport exploded, killing 581 people—including all but one member of the Texas City Fire Department. We’ve known […]
The Agency has estimated that approximately 70,367 tons per year of VOCs and 9,357 tons per year of HAPs have been emitted from equipment leaks. Many federal regulations under New Source Performance Standards (NSPS) at 40 CFR 60 and National Emissions Standards for Hazardous Air Pollutants (NESHAPs) at 40 CFR 61 and 40 CFR 63 […]
Use the information in today’s Advisor to help you plan your safety training program. The Occupational Safety and Health Administration (OSHA) provides much assistance to businesses of all sizes to help them set up and manage effective safety programs. That assistance includes training programs, which you can learn more about here www.osha.gov/dte/index.html. In addition, check […]
NPDES FAQs for Fracking Operations in the Marcellus Shale—Part 1 Q: Are hydraulic fracturing, or “fracking,” operations allowed to discharge wastewater directly to waters of the United States if they have a NPDES permit? A: The Clean Water Act (CWA) prohibits the discharge of pollutants by point sources into waters of the United States, except […]