Compliance Archives - February 2016
2/29/2016US 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.
2/26/2016In essence, the Addendum II comprises changes to the rules for shipping lithium batteries that will go into effect April 1, including a prohibition on lithium-ion batteries as cargo on passenger aircraft approved by the International Civil Aviation Organization (ICAO) earlier this week.
2/26/2016This year, PHMSA has responded to a number of requests-for-interpretation from industry professionals seeking clarity on specific parts of the Hazardous Materials Regulations at 49 CFR 171–181. These interpretations are a great representation of the way hazardous materials regulations intersect with the realities of managing and shipping hazmat in the real world.
2/25/2016A German lighting company now faces $117,480 in civil penalties from US FAA for alleged violations of hazmat air shipping regulations. The company offered 9.6 liters of a flammable liquid (glue) for air transport from Düsseldorf to Chicago. In a February 24 press release, FAA alleges that the shipment exceeded the quantity limits for flammable liquids shipped by passenger aircraft.
2/23/2016Under RCRA, anyone who treats hazardous waste needs a permit from the EPA. [40 CFR 270.1(c)] US EPA defines hazardous waste “treatment” as any activity that renders a hazardous waste non-hazardous, less hazardous, reduced in volume, or more amenable for transport. [40 CFR 260.10]...
2/22/2016On February 22, US EPA announced the release of a public draft inventory report of greenhouse gas (GHG) emissions in the United States from 1990 to 2014.
Greenhouses gases are one of the major focuses of US EPA’s enforcement of the Clean Air Act. EPA requires industrial facilities that emit specific pollutants to report through the Greenhouse Gas Reporting Program, or GHGRP.
2/22/2016This week, US EPA announced its National Enforcement Initiatives (NEIs) for fiscal years 2017–2019. Every three years, EPA sets these initiatives in order to reinforce the work the Agency does to regulate the release of pollutants into the environment. The NEIs reflect areas of environmental regulation where there is significant non-compliance with the law.
2/19/2016When classifying hazards under GHS, the available health and safety data may be too complex or conflicting to result in a single classification. When this happens, the manufacturer, importer, or employer should use an approach known as “weight of evidence” (WoE) to determine the level of hazard. OSHA has released guidance on using the WoE method, and is now seeking public comments on the document.
2/16/2016Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) defines a “hazardous waste” as a solid waste that exhibits specific characteristics or is described on a list. [40 CFR 261.3] In addition to criteria for identifying hazardous wastes, the RCRA regulations prescribe hazardous waste management requirements for on-site storage, marking and manifesting for off-site shipping, and recordkeeping and reporting...
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