Compliance Archives - June 2011
6/30/2011
Question of the Week: Classifying Aerosol Can Waste
Q. Are aerosol cans considered to be a D003 simply because they are pressurized?
A. When it comes to waste identification, it is the responsibility of the generator to make a waste determination based on all aspects of the material (40 CFR 262.11). RCRA programs in some authorized states simplify your waste classification process and declare that each and every aerosol can...
6/22/2011
OSHA Proposes Changes to Injury & Illness Recording Requirements
In today’s Federal Register (76 FR 36414), the Occupational Safety and Health Administration proposed a set of rule changes to the Occupational Injury and Illness Recording and Reporting requirements.
OSHA proposed to update Appendix A to Subpart B of 29 CFR Part 1904, containing the list of industries that are partially exempt from maintaining records of...
6/21/2011
Finding Out More About the Hazardous Material Regulations
There are 34 pages in the Hazardous Materials Transportation Safety and Security Reauthorization Act of 2005 [HMTA; Pub. L. 109-59] and 1,105 pages in the Hazardous Material Regulations [HMR; 49 CFR Parts 171-180] to enforce that law. These laws and rules govern every element of hazardous materials transportation safety and security. Have you ever read or skimmed through them? Do you know where to find a copy...6/13/2011
EPA Modifies LDRs for Carbamates
Today, the EPA published a direct final rule (76 FR 34147) and proposal (76 FR 34200) on LDRs for “Carbamate” production wastes and commercial chemical products containing carbamates. As existing test methods are inadequate, and it is difficult to determine the concentration of carbamates at the limits specified for land disposal, this rule modifies...6/9/2011
Report on PHMSA’s Pre-UN Public Meeting
On June 8, the U.S. Department of Transportation’s Pipeline and Hazardous Material Safety Administration (DOT-PHMSA) held a public meeting to consider proposals for the 18th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations, which will be implemented on January 21, 2015...
6/7/2011
Question of the Week: When Do I have to Update My Material Safety Data Sheets?
Q. Under the Hazard Communication Standard (29 CFR 1910.1200), the Occupational Safety and Health Administration (OSHA) requires manufacturers and importers to obtain or develop material safety data sheets (MSDS) for each hazardous chemical they produce or import. Manufacturers and importers must provide these MSDS to distributors and employers with their initial shipment, and with the first shipment after the MSDS are updated.
How often does OSHA require manufacturer/importers to update their MSDS?
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