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Compliance Archives - July 2012

New GHS Labels vs. DOT Labels

7/31/2012

New GHS Labels vs. DOT Labels

Q. I have a 55-gallon drum of a flammable chemical that I plan to ship to a customer. I know I am required to have a GHS label on the outside, as well as DOT markings and labels. I was told that the flame pictogram on the GHS label cannot be on the drum since there is already a Flammable Liquid label as required by the DOT. Is this true...

7/26/2012

DOT to Adopt Old Special Permits into Hazardous Materials Regulations

In previous installments of LionBlog’s coverage of the Moving Ahead for Progress in the 21st Century (MAP-21) highway bill, we discussed rising civil penalties and Congress’ take on the DOT’s Enhanced Enforcement Authority. Today, we will take a look at instructions Congress had for the DOT’s hazmat Special Permits program...

7/24/2012

Frequency of Hazardous Waste Tanks Self-Inspections

Throughout Parts 264 and 265 of 40 CFR, the U.S. EPA requires persons who store hazardous waste, including large and small quantity generators, to periodically self-inspect waste containment units. These periodic self-inspections are your opportunity to ensure that you stay in compliance with RCRA and head off any...

7/19/2012

Congress Weighs In on DOT’s Enhanced Enforcement Authority

In the MAP 21 highway bill passed earlier this month, Congress further defined the DOT’s Enhanced Enforcement Authority, including placing limits how and when that authority can be used.  The Enhanced Enforcement Authority, or “Package-Open Rule,” was published as a final rule in the Federal Register on March 2, 2011, and authorizes...

7/17/2012

What's so Great About Excepted Quantities?

Q. What are Excepted Quantity shipments? How do I prepare small packages as excepted quantity shipments by ground and by air?
 
A. Did you know there is a way to avoid almost all of the hazardous material regulations, to ship hazmat with no special packaging, no hazard labels, and no special shipping papers? There’s only one catch...

7/12/2012

EPA Completes Greenhouse Gas Phase-in

Today, the Environmental Protection Agency completed Step 3 of its phase-in approach to permitting greenhouse gas emissions. The Agency is NOT lowering the ‘tailored’ threshold for determining the applicability of the Title V permit program. And will continue to regulate...

7/12/2012

EPA Extends Deadline for Chemical Data Reports

On June 18, 2012, the Federal Register published a Final Notice extending the reporting deadline for the revised TSCA Chemical Data Reporting Rule (CDR). The new deadline is August 13th, 2012, six weeks beyond the original deadline of June 30, 2012.
 
The purpose of CDR is for the EPA to collect quality, screening-level, exposure-related data on a wide range of chemical substances. But, who is subject to the rule and what are the requirements...

7/9/2012

New Highway Bill Raises Civil Penalties for Hazmat Violations

On Friday, President Obama signed into law the Moving Ahead for Progress in the 21stCentury (MAP-21) highway bill.  This bill made significant changes to the hazmat portions of the current highway law, including increasing civil penalties for hazmat violations...
Updating Safety Data Sheets

7/3/2012

Updating Safety Data Sheets

Q. With the new GHS rules, who has to create Safety Data Sheets and what kind of information must go into them?
 
A. Now that the Occupational Safety and Health Administration (OSHA) has adopted the Globally Harmonized System (GHS) into the Hazard Communication Standard, employers and chemical manufacturers must take several steps to ensure they...

7/2/2012

DOT Training Requirements for Signing a Waste Manifest

“I have an employee that is responsible for signing the manifest for our off site shipments of hazardous waste. I have heard that this employee is subject to DOT training. If this is true, what training must I provide to this employee?”
 
This is a common question that is asked by compliance managers at sites dealing with...

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