Practical EHS Tips, News & Advice. Updated Daily.
Who Will Be Paying the Compliance Costs? The EPA estimates $160 million in annual compliance costs for the final UST regulation. Motor fuel retailers, which account for roughly 80 percent of UST systems, are expected to bear approximately 70 percent of the total costs. Previously deferred tanks—emergency generator tanks, airport hydrant fuels distribution systems, and […]
Note: This article is directed toward businesses looking to build or expand possibly on remediated brownfields, not those that are interested in purchasing a site and cleaning it up themselves. EPA Grants The EPA recently announced its latest round of brownfields grants. Grants investments totaling $54.3 million went to 243 projects in 147 communities nationwide. […]
According to the EPA, anyone who ships hazardous wastes off-site needs to comply with both EPA’s training requirements for generators and the U.S. Department of Transportation’s (DOT) requirements for training hazardous materials employees. The generator’s certification language on the manifest is essentially the same certification language that the DOT refers to as the “shipper’s certification.” […]
BMPs for Storing Anhydrous Ammonia Good Housekeeping Maintain good housekeeping practices. Ensure good housekeeping procedures are followed in the compressor/recycle rooms and in the immediate vicinity of the evaporators. Accumulated supplies, equipment, and debris delay detection of equipment damage or ammonia leaks. Maintain complete and accurate piping and instrumentation diagrams (P&IDs) of the ammonia refrigeration […]
DOT’s Hazardous Materials Regulations (HMRs) require that hazmat employees receive “adequate training” for their specific job duties. As a hazmat employer, you are left in the dark as to what “adequate training” actually means. As a matter of fact, DOT has written a letter of interpretation that states the agency’s position on the meaning of […]
Note: The OSHA industry standards for asbestos do not protect certain state and local government employees. The worker protection requirements under the Toxic Substances Control Act (TSCA) ensure that the OSHA General Industry and Construction Industry Standards under 29 CFR 1910.1001 and 29 CFR 1926.1101 are applied to such employees, including those performing asbestos-related work […]
Facilities that are required to develop a Facility Response Plan (FRP) must include a facility response training program with drills and a testing program, and document the program in the FRP. Draft PREP Changes The requirement to develop and implement a program of response drills and exercises, including evaluation procedures, can be met by implementing […]
Emergency responders must be trained before their participation in emergency response operations. Their training must be based on the functions and duties they will be expected to perform. Examples of activities emergency responders could be involved in include: Responding to the spill of a highly toxic substance from an overturned 55-gallon drum Responding to a […]
HAZWOPER applies to employers involved in three general categories of work operations: Hazardous waste site cleanup operations (e.g., Superfund, voluntary cleanups, and corrective actions under RCRA) Operations involving hazardous waste at TSDFs (e.g., a landfill that accepts hazardous waste), and Emergency response operations for releases of, or the threat of release of, hazardous substances at […]
When you think of RCRA, you think of manifests, “cradle to grave” hazardous waste management, transportation, container management, and endless hours of recordkeeping. However, one important aspect of RCRA for EHS managers is training. There are specific training requirements for personnel at hazardous waste TSDFs and large quantity generators (LQGs). Small quantity generators (SQGs) are […]