Tag: EPA

Getting Organized and Other EHS Recordkeeping Tips

Surprise! Don’t get caught without the necessary records in the event of a surprise EPA or state agency inspection. Here are some tips for getting and keeping your records organized. Employee training records should be filed by date and topic. In an effort to keep employee records organized, most supervisors put employee training records in […]

What to Expect from EPA over the Next 5 Years

Now, to achieve these goals, EPA promises to “Pursue vigorous civil and criminal enforcement that targets the most serious water, air, and chemical hazards in communities. Assure strong, consistent, and effective enforcement of federal environmental laws nationwide.” The FY 2011–2015 EPA Strategic Plan is accompanied by five crosscutting fundamental strategies that seek to adapt into […]

Beyond the Border—Managing Your Product for Import

The relentless advance of importation calls for a shift from the traditional emphasis on border inspections of imports to an approach that identifies high-risk segments in a product’s life cycle and verifies the safety of the product at those junctions. That’s the view of eight federal agencies, including EPA, which in 2009 issued a draft […]

EPA Rules and the National Power Grid

According to critics, at least eight proposed or final EPA rules (air, water, and waste) may force the retirement of up to 81 gigawatts (GW) of coal-fired generating capacity. (The Energy Information Administration says the total installed generating capacity of the U.S. electric power grid is about 1,119 GW with approximately 330 GW coal-fired.) About […]

What You Get Out of an EMS

Not Required But Still a Good Idea It is important to keep in mind that ISO 14001 is not a legal requirement. It is a voluntary set of management standards that may improve your environmental performance. EPA encourages industries to adopt these standards but offers no specific incentives (such as reduced frequency of inspections) in […]

Taking the Confusion Out of ‘Closed Containers’

Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]

The Controversial Contained-In Policy

One way, called the contained-in policy, attempted to smooth over the pre-existing position held by the Agency that contaminated soil that either contained a listed hazardous waste or exhibited a hazardous waste characteristic must be managed and disposed of according to all regulations governing hazardous waste (RCRA Subtitle C). Also, soil that contained listed hazardous […]

Determining Your Generator Status

Are You a LQG? If you generate 1,000 kg (about 2,200 pounds) or more of hazardous waste or more than 1 kg of acutely hazardous waste in any calendar month, you are a large quantity generator (LQG). LQGs must comply with all of EPA’s hazardous waste management rules although a partial exemption from some rules […]

Hazardous Waste Generators FAQ Roundup

After the decision is made to vent propane from a cylinder, up until it is vented onsite, does a propane cylinder need to be managed as D001 hazardous waste? Because the container of D001 hazardous waste does not yet meet the “RCRA empty standard” (as explained at 40 CFR 261.7) the container must be managed […]

Hazardous Waste Recordkeeping Checklists for RCRA, Exporters, and Land Bans

Here’s a quick checklist of the paperwork you should have for your RCRA, hazardous waste exporting, and land ban requirements. RCRA Have you kept the following hazardous waste records for specified periods of time (if applicable)? Copies of a small quantity generator’s “reclamation agreement” for at least 3 years after the agreement’s termination or expiration […]