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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

Q. Does a hazardous waste storage tank need to be emptied every 90 days (or 180 days), or can a ”mass balance approach” be taken?
 
A. EPA stated in the January 11, 1982 issue of the Federal Register (47 FR 1250) that generators must remove all wastes from the tank within...

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

The summer months will soon be upon us. This means that we will soon be faced with managing outside workplace safety issues. In the great outdoors, some of the hazards we will need to navigate are soot and air pollution, the cancer-causing ultraviolet rays of the sun, heat stress, poison ivy and other toxic plants, insect-borne diseases, and dangerous wildlife.
 
While the Occupational Safety and Health Administration (OSHA) has safety standards for ladder safety, fire exits, noise exposure, arc welding, chemical exposures, and many other hazards...

5/2/2011

Post-Rapanos Guidance from EPA and Army Corp of Engineers

In today’s Federal Register (76 FR 24479) the Environmental Protection Agency and the Army Corp of Engineers announced new guidance on the jurisdiction of the Clean Water Act...

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