Tag: reporting

Safety culture

Reporting Safety Performance to Your Customer: A Modern Approach

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.

Mercury

TSCA Mercury Reporting Rule Finalized

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 […]

One E-Reporting System Proposed for MATS

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). […]

September Is National Preparedness Month

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 […]

Is Bio-oil Mixed with Motor Oil Used Oil?

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 […]

EPCRA Lessons Learned

#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, […]

UST Amendments—What You Need to Know about Biofuels Compatibility

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 […]

How to Avoid RMP

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 […]