Tag: Compliance

Nanomaterials and TSCA—It’s the Little Things

What are nanoscale materials? Nanomaterials are chemical substances that have structures with dimensions at the nanoscale—approximately 1 to 100 nanometers (nm). To get an idea of their size, a human hair is approximately 80,000 to 100,000 nm wide. The thinking is that nanomaterials may have properties different from the same chemical substances with structures at […]

9 Tips for Keeping Cool Refrigerant Records, con’t

Compliance with refrigerant handling and appliance and equipment repair requires a lot of paperwork and recordkeeping. Exclude Purged Refrigerants Tip 8: If you own refrigeration equipment and want to exclude purged refrigerants that are destroyed from annual leak rate calculations, keep these records: Records sufficient to support the amount of refrigerant you claimed you sent […]

9 Tips for Keeping Cool Refrigerant Records

EPA’s regulations for safeguarding and repairing the stratospheric ozone layer include provisions for the servicing and disposal of refrigeration and air-conditioning equipment. Under these regulations, a “refrigerant” is defined as any substance consisting of, or is part of, a Class I or Class II ODS that is used for heat transfer purposes and provides a […]

What Is an EHS and Why Would I Want to Know?

The CAA’s Chemical Accident Prevention Program requires that any facility that has listed substances above threshold quantities in any single process prepare a Risk Management Plan (RMP). The listed substances contain 77 toxic chemicals with thresholds ranging from 500 pounds (lb) to 20,000 lb and 63 flammable substances with a threshold quantity of 10,000 lb. […]

Does EPA Listen to Citizen Complaints?

So, are citizens’ tips a major component of enforcement programs? Primarily, the average citizen is not able to identify anything beyond the most blatant environmental problems. For example, the EPAinforms aspiring citizen inspectorsthat possible signs of an environmentalviolation include: Strong, offensive, or unusual chemical odors; Large numbers of dead animals, including birds or fish; Pipes […]

10 Steps to Prepare for an EPA Inspection

Recent enforcement statistics from the EPA show that during fiscal year (FY) 2014, enforcement actions required companies to invest more than $9.7 billion in actions and equipment to control pollution and clean up contaminated sites. Companies paid $63 million in combined administrative, civil, and criminal fines. And that’s just on the federal level! Follow these […]

Money Chatter: What Industry Says Are the Real Costs of EPA’s Proposed Ozone Standard

Note: The current health-based ozone standard is 75 parts per billion (ppb). The groups discussed in this article all recommend that the EPA retain the current ozone standard. National Association of Manufacturers (NAM) NAM commissioned a study concerning the costs of EPA’s proposed ozone standards.  The initial (July 2014) and updated (February 2015) study was […]

Money Chatter: What EPA Says Is the Real Cost of the Proposed Ozone Standard

By law, the EPA cannot consider costs when setting a health-based National Ambient Air Quality Standard (NAAQS).  Nonetheless, to inform stakeholders, the Agency typically calculates the costs of meeting the NAAQS as well as the monetary benefits. Note: The current health-based ozone standard is 75 ppb. The EPA estimates costs at $3.9 billion in 2025 […]

Calculating Your Monthly Hazardous Waste Generation

Counting Hazardous Waste You know you generate hazardous waste at your facility and you want to keep your disposal costs down. Well, then, you have to keep down the amount of hazardous waste you have on-site each month. If you are a large quantity generator (LQG), your responsibilities and costs will be greater than if […]

8 Tips for Reporting Your P2 Activities

While it is our contention that in this day and age most facilities are engaged in some sort of P2 to reduce chemical use and waste production, as we reported in yesterday’s Advisor, only 16% of all TRI facilities reported their P2 activities for reporting year 2013. The EPA would like to up that percentage […]