Lion News
2/25/2014
Management Strategies for Using RCRA Exclusions
At first glance, managing hazardous waste in a way that relieves the generator from some RCRA regulations may seem very appealing. In some cases though, these management strategies may not provide as much relief as initially believed and may make subsequent management decisions even more difficult. One scenario that raises this challenge is the EPA’s exclusion for certain de-characterized hazardous wastes...
2/18/2014
Package and Container Communication: DOT vs. GHS
When dealing with hazardous constituents, hazard communication is a must to protect workers, property, and the general public. Both the Department of Transportation (DOT) and the Occupational Safety and Health Administration (OSHA) have standards for how to communicate the dangers of goods and products they consider “hazardous....gif?width=800&height=533&ext=.gif)
2/11/2014
Greenhouse Gas Reporting in 2014
This week, Lion News continues to examine the ongoing cycle of Federal and State reporting requirements under major US EPA regulatory programs. Last month, we addressed the March 1 deadline for submitting Tier I and II chemical inventory reports under EPCRA. In this article, we discuss the next major approaching deadline, which applies to annual greenhouse gas reporting (GHG) under the Clean Air Act (CAA)...
2/4/2014
The Next Phase of GHS Hazard Communication
The first GHS deadline has passed. By December 1, 2013, all affected employers were required to train their employees on GHS labels and Safety Data Sheets (SDSs). If you have employees subject to GHS who have not been trained on these new elements, you need to get them trained as soon as possible...
1/28/2014
Simplify Your Approach to Waste ID
Identifying hazardous waste and assigning waste codes is one of the most complex responsibilities in waste management. Many factors need to be considered when making this determination, including the waste’s properties, the hazards it poses, and even the industry in which it was generated.
The EPA’s Resource Conservation and Recovery Act (RCRA) regulations provide a complex system of lists that personnel must use to...
1/21/2014
Protecting Your Packages from Incidents in Transit
The bottles, cans, jars, and test tubes inside of your combination packaging must remain closed when they are subject to shocks, vibrations, and changes in temperature and pressure during transportation. A box rattling along a bumpy road in the back of a truck, climbing to 35,000 feet in a matter of minutes inside of an airplane’s cargo hold, heating up on a train stopped on the tracks in the desert, or rolling with the waves on a ship may experience extreme conditions that could...
1/14/2014
EPCRA Inventory Reports Due March 1
Each new calendar year begins a new cycle of EPA Federal and State reporting requirements. EH&S personnel at companies that manufacture, process, use, or dispose of hazardous chemicals must be aware of the reporting deadlines and requirements that apply to their facilities. The first report many facilities must compile and submit is the...
1/13/2014
Moving Forward with GHS Hazard Communication
Dec. 1 GHS Deadline Has Passed – What Now?
The December 1, 2013 deadline for employers to train workers on changes to OSHA’s Hazard Communication Standard (HCS) has come and gone. Still, reports show many companies have not yet trained employees on the updated “HazCom” rules, which were revised when OSHA adopted international standards from the...
1/7/2014
Injury Reports Must Be Posted by February 1
At the end of each calendar year, many employers must create, certify, and post an annual summary of work-related injuries and illnesses logged during the year. Throughout the year, employers record workplace incidents using the OSHA 300 log and at year’s end summarize this data to create the OSHA 300-A Summary Form. By February 1, 2014, covered employers must post a summary of incidents that occurred during 2013...
1/6/2014
OSHA Memo: New Combustible Dust Hazard Classification
On December 27th, 2013, OSHA distributed an internal memo to its compliance officers intended to clarify the Administration’s standards regarding combustible dusts. What Is Combustible Dust?
When OSHA amended the Hazard Communication Standard (HCS) to align with the Globally Harmonized System for the Classification and Labeling of Chemicals (GHS), the Agency amended the...
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