Practical EHS Tips, News & Advice. Updated Daily.
In May, 2015, the Department of Labor (DOL) issued a proposed guidance document for its personnel on complying with Executive Order 13673, Fair Pay and Safe Workplaces. The document is not yet finalized, however, it does offer insights into how OSHA and other agencies within the DOL intend to interpret and act upon the Order. […]
Hazardous waste pharmaceuticals are all over the EHS news services lately because of the U.S. Environmental Protection Agency’s (EPA) recent proposal establishing specific management requirements for healthcare facilities that generate hazardous waste pharmaceuticals. However, hazardous waste pharmaceuticals are a small percentage of the medical waste that is generated in the United States. Today we offer […]
One of the most tedious aspects of an EHS manager’s job is to keep track of a host of records. Don’t get caught without the necessary records in the event of an OSHA or EPA inspection. One of the first things inspectors will ask for is records of compliance. Good recordkeeping indicates to them good […]
Regulatory exemptions for farms are common throughout the major U.S. environmental statutes, including the Emergency Planning and Community Right-to-Know Act (EPCRA). But exemptions for farms do not apply to all requirements in the major reporting provisions of EPCRA.
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 […]
We’re revamping our newsletter lineup to be more responsive to our reader’s interests. Effective Monday, September 14, the Environmental Daily Advisor and the Safety Daily Advisor will consolidate into the EHS Daily Advisor, which will feature topics of interest to both Safety and Environmental pros, like hazardous substances, for example. For our Environmental Daily Advisor […]
The RCRA used oil management standards can serve as a road map to guide used oil handlers (generators, transporters, burners, marketers, processors, and re-refiners) through the various storage, recordkeeping, and cleanup procedures to ensure used oil is handled safely. The used oil regulations are based on the presumption that used oil (i.e., oil contaminated by […]
#1. What Went Wrong A California-based poultry company with a facility in Kelso allegedly did not meet the deadline in 2013 for reporting chemicals stored at its facility. The company apparently failed to report that it stored over 500 pounds (lb) each of ammonia and sulfuric acid, and over 10,000 lb each of carbon dioxide, […]
If you have hazardous waste at your facility, you are a generator of hazardous waste. If you decide to manage some of it as universal waste, you are automatically a universal waste handler by virtue of being a generator of universal waste. Generated universal waste is not counted in a generator’s hazardous waste quantity if […]
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 […]