Solvent Contaminated Wipes
Q. Does the solvent contaminated wipes 180-day accumulation limit mean we accumulate and send wipes for disposal within 180 days or accumulate for 180 days and store on site for another amount of time?
Tag: CFR
The Who, What, and When of Release Notifications
A spill or release of a chemical just occurred at your facility. What do you do? Does it need to be reported? What information needs to be reported, to whom, and how soon?
Q&A: Emergency Evacuation Maps
Are there regulations for where emergency evacuation maps have to be posted in a facility?
Workers Exposed to Chemicals, Employers Exposed to Fines: Three Recent Cases
There are many chemicals in use in modern workplaces—and there are a lot of ways workers can be exposed to them. Three employers that were cited within a 1-month period earlier this year provide instructive examples of the kinds of mistakes that lead to overexposures.
Biennial Report
Q. We store Lead Metal Scrap on our property and sell it to recyclers. Would I mark Item 12 “Notification of Hazardous Secondary Material Activity” on the 2015 biennial report as “Yes” or as “No”?
EPA Releases Proposed Changes to the Cost of RMP
The U.S. Environmental Protection Agency (EPA) recently released its proposed amendments to the Chemical Accidental Release Prevention Program, aka the Risk Management Program. Concurrently, the Agency also released a Regulatory Impact Analysis (RIA). Yesterday we reviewed EPA’s estimated costs for changes concerning third-party audits, root cost analyses, and safer technology and alternative analyses. Today we […]
OSHA Increases Fines for Failing to Report
Anticipating a large increase in severe injury reports (fatality, inpatient hospitalization, amputation, or loss of an eye), OSHA issued an internal enforcement memorandum on December 24, 2014, to help the field offices manage these reports. It provides new procedures on when to launch an inspection. Recently, OSHA revised its Interim Enforcement Procedures for New Reporting […]
Q&A: Pedestrian Travel Paths
Recently, one of our subscribers asked the following question: For pedestrian safety, how wide does a designated protected employee travel path need to be? What type of stationary protective guards are acceptable to prevent forklifts from hitting pedestrians?
SDS Requirements
Q. Can you provide some guidance on how to satisfy the requirements of the Safety Data Sheet (SDS) information without revealing the names or Chemical Abstracts Service (CAS) numbers of the chemicals we use in our mixtures?
Do you Know Which Hazardous Wastes to Count?
A generator’s hazardous waste status is based on the quantity of hazardous waste generated each month. So do all your generated hazardous wastes need to be counted? Yes, but no. The federal regulation at 40 CFR 261.5(c) and (d) sets forth a list of wastes that are exempt from being counted in connection with ascertaining […]