Compliance Archives - May 2011
5/31/2011
Question of the Week: What’s Going to Happen to ORM-D?
Q. I’ve heard the U.S. Department of Transportation (DOT) is phasing out the Consumer Commodity (ORM-D) exceptions from the Hazardous Material Regulations (HMR; 49 CFR parts 171-180). When did this happen? When does it take effect? And does this mean that regular consumer products need shipping papers and the whole rigmarole of marks, labels, and UN specification packaging like regular hazmat...5/24/2011
Question of the Week: Using a Mass Balance Approach for RCRA Tanks
5/17/2011
Question of the Week: Changes for Combustible Liquids?
Q. We ship a mineral spirits product that has a flashpoint of 120ºF in 55-gallon drums. The product has no other DOT hazards and is only shipped by highway. We have been using the opportunity that the DOT provided at 49 CFR 173.150(f) to reclassify our product as a combustible liquid so that we can take advantage of the exception at 49 CFR 173.120(b)(2). We heard that the DOT is eliminating the combustible liquid designation. What will this mean for our shipments?5/10/2011
Question of the Week: Toxic Chemical Inventory (TRI) Reporting
Q. We are a facility that is subject to the toxic chemical inventory reporting requirements at 40 CFR Part 372. During the previous calendar year we mixed 24,800 pounds of a listed toxic chemical into one of our product formulations. In late December, we did add 200 more pounds into a batch processing unit. However...5/3/2011
Feature Article: Get Ready for Summer Workplace Safety
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