Practical EHS Tips, News & Advice. Updated Daily.
What are the regulatory requirements for making changes on hazardous waste manifests? Your question doesn’t specify whether you are the generator who is preparing the hazardous waste manifest or the designated facility (TSDF) that is receiving the hazardous waste shipment. Assuming you’re the generator, it is the generator’s responsibility to ensure that the shipment is […]
Are direct supervisors of hazmat employees also hazmat employees for purposes of training? Continue reading to find out.
Are reverse operations moving forward for retailers? If you manage a retail operation, you are confronted with waste and hazardous materials problems that can be confusing for even the most seasoned manager. Yesterday we looked at reverse distribution and how even one of the largest retailers with legal and environmental health and safety staff got […]
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 […]
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 […]
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 […]
Problem # 1: Have you crossed the line to hazmat offeror? You’re a hazardous waste generator and you have hired a hazardous waste transporter to pick up your waste and haul it off. You’ve checked everything off your Resource Conservation and Recovery Act (RCRA) checklist and you’re ready for the waste to be out of […]
According to the EPA, anyone who ships hazardous wastes off-site needs to comply with both EPA’s training requirements for generators and the U.S. Department of Transportation’s (DOT) requirements for training hazardous materials employees. The generator’s certification language on the manifest is essentially the same certification language that the DOT refers to as the “shipper’s certification.” […]
For much of the 20th century, opioid painkillers were primarily used to ease chronic cancer pain and relieve acute pain. In the 1990s, new formulations of opioid medications became available, leading to the steeply increased use of opioid painkillers (for example, OxyContin) for chronic pain—and to a steep increase in accidental poisoning deaths. According to […]
DOT’s Hazardous Materials Regulations (HMRs) require that hazmat employees receive “adequate training” for their specific job duties. As a hazmat employer, you are left in the dark as to what “adequate training” actually means. As a matter of fact, DOT has written a letter of interpretation that states the agency’s position on the meaning of […]