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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...

6/15/2011

NACD Also Objects to PHMSA’s Cargo Tank Unloading Rule

Following up from yesterday’s post, the National Association of Chemical Distributors (NACD), like the ATA, is also objecting to overreaching elements of PHMSA’s proposed regulations for cargo tank loading and unloading...

6/14/2011

Coast Guard Forms Chemical Transportation Advisory Committee (CTAC)

The U.S. Coast Guard is establishing a Chemical Transportation Advisory Committee (CTAC) to advise the Department of Homeland Security and the Guard on the safe and secure transportation of hazardous materials in bulk...

6/14/2011

California: Draft MSP Program

The California State Water Board has released the first draft of a proposed permit for small municipal storm water dischargers, including...

6/14/2011

ATA Opposes Proposed Rules for Loading/Unloading Hazmat Cargo Tanks

On June 9, the American Trucking Association (ATA) filed comments with the Pipeline and Hazardous Materials Safety Administration, criticizing its proposal to require...

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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