The Office of Information and Regulatory Affairs (OIRA), which is part of the White House’s Office of Management and Budget (OMB), recently issued a memo clarifying how it determines if a proposed federal rule is a major rule and the level of cooperation the OIRA expects from federal agencies to assist in that determination. The […]
The EPA’s Strengthening Transparency in Regulatory Science proposal occupies a mere 7 pages in the Federal Register (April 30, 2018), and yet, among scientists, human health and environmental groups, and certain industry organizations, the proposal has been the subject of intense discussion. Congress has also been weighing in on the merits of the proposal.
OSHA has issued a final rule, published in the August 9 Federal Register, to extend the compliance date for specific ancillary requirements of the general industry beryllium standard to December 12, 2018.
The EPA recently issued its fall 2016 Regulatory Agenda, which lists 49 actions in “final rule stage.” Some of these actions are technical or noncontroversial or intended to reduce compliance burden. But a large number of them will increase or potentially increase regulatory responsibilities either for specific or multiple industrial sectors.
It makes business sense. Having a plan for emergencies is key to getting back to work with minimum disruptions. A strong emergency response/continuity plan provides the means to address the numerous issues involved in performing essential functions and services during and after an emergency. Sometimes you just have to! In addition, laws and regulations require […]
Changing environmental situations often requires the U.S. Environmental Protection Agency (EPA) to revisit policies and interpretations of regulations even if the rules themselves are not amended. A case in point is a 1997 EPA policy that precluded the regulation of bio-oils (e.g., vegetable and animal oils) that have been used as lubricants, or for other […]
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 […]
Since 1988, the UST regulations required that tanks be made of or lined with materials that are compatible with the substance stored. Since that time, many new biofuel blends have come on the market. The 2015 UST amendments add new compatibility notification, demonstration of compatibility, and recordkeeping requirements concerning certain biofuels. Notification. UST owners and […]
No longer deferred The 1988 UST regulations deferred several types of USTs from regulations. Under the 2015 amendments, three types of tanks were removed from the referral list and must comply with the 2015 UST regulations. USTs for emergency power generators. The new UST amendments removes the deferral for USTs solely to store fuel for […]
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 […]