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05/08/2012
It’s that time again. July 1st is the deadline for submission of the Toxic Release Inventory. Here’s a reminder of the Who, What, and When of TRI....
04/10/2012
On February 16, 2012, U.S. EPA issued a new Construction General Permit for Stormwater Discharges, replacing the 2008 Construction General Permit that expired on February 15, 2012. Clean Water Act permits typically must be renewed every...
03/13/2012
Q. Under the Safe Drinking Water Act, the Environmental Protection Agency establishes quality standards for public water supply systems. The EPA sets two kinds of standards: “Primary” and “Secondary.” What’s the difference...
02/14/2012
Yes, it’s that time again! The annual hazardous chemical inventory report required under the EPCRA rules at 40 CFR 370 is due on March 1, 2012. The inventory reporting rule applies to any facility that is required to prepare or have available a material safety data sheet (MSDS) for a hazardous chemical under...
Yesterday, the Federal Register finally published the Fall 2011 Regulatory Flexibility Agendas, as required by the Regulatory Flexibility Act (5 USC 602). Compared to the Unified Agenda published last month (and discussed ), the Flexibility Agendas only include rules that have a significant economic impact on a substantial number of small entities (SEIOSNOSE) or are otherwise identified as significant rulemakings. Ever since the OMB took the lead on managing the agendas...
01/31/2012
Twice each year, the departments and independent agencies of the Federal government publish public agendas of their rulemaking activities. These semiannual agendas both review recent new rules and announce upcoming rule activities. While each agency and department creates its own agenda...
01/10/2012
On August 16, 2011 (76 FR 50816), EPA published its new Chemical Data Reporting (CDR) Rule, replacing the previously existing Inventory Update Report (IUR) Rule. While the form for submitting data remains the same (the Form U), some key information has changed...
12/13/2011
As the year comes to a close, we take a moment to look back and reflect on what the U.S. Environmental Protection Agency has done, and not done, over the past twelve months...
11/29/2011
Personally, the last month of the year usually means entry into the year–end holiday season. For EHS managers, this should also mean preparing your 2012 compliance calendars. These calendars will likely include various reporting obligations. While many of your reporting obligations and frequencies are site–specific (e.g., NPDES discharge monitoring reports and Clean Air Act Title V certifications), some events...
11/08/2011
On October 31, 2011, the EPA finalized a general permit under the Clean Water Act National Pollutant Discharge Elimination System (NPDES) for pesticide applications [76 FR 68750, November 7, 2011]. This action is the final step in fulfilling the Agency’s obligations in response to...
What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising state and Federal penalties.