Say the words, “reporting to your customer” around most VPs or directors of EHS and get ready for the frowns, the grins, and perhaps the expletives. It’s not that they don’t value transparency. It’s that the whole process of reporting safety performance data to customers is often highly administrative, time-intensive, and even contentious.
Q. I manage our filter cake waste as a hazardous secondary material (HSM) and notified the EPA and state environmental protection agency before managing the waste as a HSM. Are there any other reporting requirements after the initial notification?
Section 8(b)(10) of the amended Toxic Substances Control Act (TSCA) directs the EPA to develop an inventory of mercury supply, use, and trade in the United States and, based on that inventory, recommend actions, including proposed revisions of federal law or regulations, “to achieve further reductions in mercury use.” To create the inventory, the section […]
Responding to recommendations from owners and operators (O/Os) of electric power plants subject to the Mercury and Air Toxics Standards (MATS), the EPA is proposing final regulations to require the submission of compliance data through a single electric reporting system rather than through two systems as established by the original MATS (February 16, 2012, FR). […]
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 […]
#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, […]
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 […]
Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]