Tag: regulations

Are You Prepared for an SPCC Plan Inspection?

By Amanda Czepiel, J.D. BLR Legal Editor For many, that question will be answered during an EPA inspection. Your best bet to pass an SPCC plan inspection? Be prepared. EPA has been conducting SPCC plan inspections since 1973 in an effort to minimize oil spills from reaching U.S. waters, and in recent years, has stepped […]

The Hazmat Employee and Training—Most Misunderstood Regs

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 […]

SPCC Requirements: What Does EPA Mean When It Says …?

The determination of whether your facility has the potential to discharge, or "could" discharge, is based on the location of your facility in relation to streams, ponds and ditches (both perennial or intermittent), storm or sanitary sewers, wetlands, mudflats, sandflats, or other navigable waters. You should take into account the distance to navigable waters, volume […]

Keeping Up with SPCC Amendments

The SPCC regulations were last amended October 2011 to extend the date for SPCC compliance for farmers to May 13, 2013, effective immediately. Another recent amendment was the one made in October 2010, which extended the compliance date for certain facilities. The bulk of the recent changes were the November 9, 2009 amendments, which had […]

To Manifest or Not

Here’s the answer. Manifest procedures for shipments of containers that do not meet the EPA definition of “empty” (as defined in 40 CFR 261.7) are addressed in the federal regulations at 40 CFR 263.21(b) and 40 CFR 264/265.72. Container residues, which are residues that exceed the quantity limitations for an “empty container,” are considered a […]