Tag: EHS

$12 Million Worth of Lessons Learned from a Recent Enforcement

In this case, a foundry coke manufacturer in northern New York State will pay $2.75 million for alleged CAA, CWA, and EPCRA violations—and that is just the fine. ‘Citizen Scientists’ Complained A critical point in this case is that federal and state inspections came in response to local citizen complaints. The community even did their […]

Do Your Workers Know These Important Asbestos Safety Rules?

The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPA) have adopted regulations to protect workers from exposure to asbestos-containing materials, asbestos-containing building materials, and presumed asbestos-containing materials (PACMs). An Operations and Maintenance (O&M) program is a formulated plan of training, cleaning, work practices, and surveillance to maintain the ACM in […]

Seven Tips to Make Sure Your Asbestos is Adequately Wet

Acronyms and Definitions Before we list the tips, let’s take a minute to define some asbestos terms that are applicable in demolition/renovation projects. ACM—asbestos-containing material, i.e., any material that contains more than 1% asbestos. Sometimes it is best to leave ACM in place. ACWM—asbestos-containing waste material, i.e., waste that contains commercial asbestos and is generated […]

How Employers Can Promote Alternative Commuting Options

As an employer, you can promote shared transportation among your employees in several ways. Employer-sponsored vanpools. The employer buys or leases vans, but employee/drivers may be responsible for planning routes, recordkeeping, collecting fares, and maintaining the van. Drivers are often allowed to use the vans during nonworking hours. Vanpools/Buspools. Third-party firms operate vanpool fleets and […]

15 More BMPs for Storing Anhydrous Ammonia

BMPs for Storing Anhydrous Ammonia Good Housekeeping Maintain good housekeeping practices. Ensure good housekeeping procedures are followed in the compressor/recycle rooms and in the immediate vicinity of the evaporators. Accumulated supplies, equipment, and debris delay detection of equipment damage or ammonia leaks.  Maintain complete and accurate piping and instrumentation diagrams (P&IDs) of the ammonia refrigeration […]

Six Best Management Practices for Storing Anhydrous Ammonia

Anhydrous ammonia is ammonia gas—the anhydrous part means “without water.” It is colorless, but has a very pungent smell. It can be irritating at lower levels, but very damaging at higher levels. Exposure to anhydrous ammonia between 5 and 50 parts per million (ppm) can cause headaches, loss of the sense of smell, nausea, and […]

What If Your State ‘Just Says No’ to the Clean Power Rule?

The Senate Majority Leader is itching to pass legislation that allows your state to opt out of the Obama administration’s CPP rule. Some states are trying to pass laws so that their legislatures will be able to veto the rule, and Oklahoma Governor Mary Fallin recently issued an Executive Order prohibiting the state’s Department of […]

How Does Nonattainment Affect Your Facility?

The Clean Air Act required the EPA to develop NAAQS for six pollutants commonly found throughout the United States.  These pollutants, referred to as “criteria pollutants,” are: Sulfur dioxide; Particulate matter (PM-10 and PM-2.5); Carbon monoxide; Ozone; Nitrogen dioxide; and Lead. The EPA established a primary and a secondary NAAQS for each criteria pollutant. The […]

Why Is There So Much Confusion About TSCA 8(e) Reporting?

EAB Throws Out Huge TSCA Penalty Earlier this year, EPA’s Environmental Appeals Board (EAB) reversed a $2.5 million penalty against Elementis Chromium, Inc. for the company’s failure to report under TSCA Section 8(e) information contained in an occupational epidemiology study on hexavalent chromium. The study showed that occupational exposure to hexavalent chromium is associated with […]