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Compliance Archives - September 2011

9/28/2011

Question of the Week: Mixing Used Oil & Hazardous Waste

Q. If I have some used oil and mix it with hazardous waste, can I still manage it as used oil? Or is the whole mixture now a hazardous waste?
 
A. The answer is, it depends. Some mixtures of hazardous waste and used oil must be managed as...

9/28/2011

OSHA Extends Comment Period for Injury & Illness Recording and Reporting Rule Amendments

By request of the National Automobile Dealers Association, OSHA has reopened the rulemaking docket on it’s June 22, 2011 (76 FR 36414 proposal to modify the injury & illness recording and reporting program. Among the proposed changes, OSHA has...

9/22/2011

Question of the Week: Shipping Samples Under 49 CFR 172.101(c)

Q. I have a material I need to ship off site that might be a DOT hazmat, but I’m not sure. I want to send a sample to a laboratory for testing, but how do I do that if I don’t know what its properties are? What do I have to do to ship this sample in compliance with the DOT’s regulations when I don’t know what kind of hazmat it is in the first place...

9/16/2011

Updates to DOT Hazmat Rules

On September 13, 2011, at 76 FR 56304, the U.S. Department of Transportation’s Pipeline and Hazardous Material Safety Administration (PHMSA) published its annual cleanup rule in preparation for the October 1, 2011, recodification of 49 CFR.
 
This final rule, “Minor Editorial Corrections and Clarifications”...

9/15/2011

Hazmat Special Permits Update 2011

On January 5, 2011, at 76 FR 454, PHMSA made a series of changes to the special permit application system. One of the new rules required all applicants to name the CEO or president of the company when filing for a special permit (including extensions, modifications, and party-to applications). PHMSA’s intent here was “…to ensure...

9/15/2011

Question of the Week: Comparing CWA Control Technologies: BPT, BCT, BAT, BADCT

Q. If I am subject to National Pollutant Discharge Elimination System (NPDES) permitting requirements under the Clean Water Act, which of the many control technology acronyms am I subject to?
 
A. Short Answer: Check your permit, do what it says.
 
Long Answer: The type of water treatment controls you need depend on...

9/14/2011

Question of the Week: Hazard Communication: GHS Is Coming

Q. I’ve heard that OSHA is about to finalize a new Hazard Communication Standard that will change everything we’re currently doing under the standard. Is that true?
 
A. OSHA is planning to finalize a new Hazard Communication Standard (29 CFR 1910.1200) before the end of 2011; however...

9/2/2011

New Rules for Ozone?

The Obama administration placed themselves in a very interesting policy position on September 2, 2011 in announcing the withdrawal of the EPA’s proposed revisions to the National Ambient Air Quality Standard for ozone. Citing the current economic conditions, the president’s decision was made based on his desire to establish strong environmental protection regulations without...

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Lawrence Patterson

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EHS Manager

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Frances Mona

Shipping Manager

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