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3/10/2016

Hazmat Housekeeping: Should I Keep the Training Test?

The US DOT’s hazmat training standard for “hazmat employees” includes a specific provision that requires employers to certify that the hazmat employee has been “trained and tested, as required by this subpart." Hazmat employers often wonder: Is a copy of the test requried to prove to DOT that an employee has met the hazmat training standard at 49 CFR 172.704?

2/29/2016

EPA Proposes Changes to Chemical Risk Management Program (RMP)

US EPA has proposed revisions to its Risk Management Program (RMP) for facilities that manufacture, use, or store certain thresholds of hazardous chemicals. RMP came into being with the passage of the Clean Air Act Amendments of 1990, which required US EPA (and OSHA) to develop regulations and guidance for preventing large-scale chemical accidents. OSHA, for its part, created its Process Safety Management (PSM) requirements, which are similar—but not quite identical—to EPA’s RMP rules. 

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International Trade Compliance Manager

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John Brown, CSP

Director of Safety & Env Affairs

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