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Are you a “hazmat employer,” i.e., anyone who: Uses one or more workers to transport hazardous materials in commerce? Transports hazardous materials in commerce or causes hazardous materials to be transported or shipped in commerce? Manages packaging that is qualified for transporting hazardous materials (e.g., designs, manufactures, fabricates, inspects, marks, certifies, sells, reconditions, repairs, or […]
The issue of responsibility for training comes up frequently because third parties frequently enter the picture. For example, the hazmat employer may contract an outside firm to provide training to employees. Or the hazmat employer may retain subcontracted employees. Would the training company or the subcontracting company be liable if the training was found to […]
Here are some of the federal laws you should consider when storing hazardous substances: —Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), more commonly referred to as Superfund, was designed to help clean up inactive hazardous waste sites. It was modified to also require private industries to disclose to their communities and neighbors what hazardous […]
Each MSDS must contain certain information for each substance. Here’s what they’ve got to have. Chemical identity and composition The MSDS must describe the substance’s composition and, if a single substance, its chemical and common name(s). Mixtures It must describe the chemical and common name(s) of the ingredients that contribute to the known hazards and […]
What is a multimedia inspection? In multimedia inspections, the regulatory authority evaluates a facility’s overall compliance with environmental control or safety programs, rather than assess facility compliance on a media-specific basis. Multimedia inspections may also address environmental or safety performance issues, such as pollution prevention, that offer safety or environmental benefits beyond what is required […]
What are the regulations for taping/protecting the ends of batteries when preparing them for shipment/disposal? There are no requirements under EPA‘s Universal Waste regulations for taping/protecting the ends of batteries when preparing them to be sent offsite as universal waste. However, a handler of universal wastes (which includes the generator) may manage broken or damaged […]
Large quantity handlers of universal waste (greater than 5,000 kg of accumulated waste at any one time) 40 CFR 273.36: LQHUW must be thoroughly familiar with proper waste handling and emergency procedures relative to individual responsibilities during normal facility operations and emergencies. Some universal wastes are regulated by DOT as hazardous materials because they meet […]
According to the letter, responsible hazmat employers, either individually or through industry associations, are best qualified to determine the training needs of their employees. “No attempt has been made to specify the level and duration of training or testing,” states the letter. Here are 8 things from a DOT guidance document that you should keep […]
Equipment that met EPA’s definition of a mobile refueler were exempted from the sized-secondary containment requirements applicable to other types of oil-bearing equipment such as bulk storage containers or tank batteries. However, if you are a qualifying mobile refueler, you are still required to meet general secondary containment requirements. A few definitions you should know: […]