Tag: CFR

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?

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 […]