Lion News
3/1/2011
Question of the Week: Employer Provided PPE
Q. As an employer in a hazardous work environment, do I always have to provide personal protective equipment (PPE) for my employees or can I deduct the cost of new and replacement equipment from their wages?A. Under OSHA rules at 29 CFR 1910.132(d), employers are required to assess the hazards in their workplace, and...
2/22/2011
Question of the Week: Determining Significant Waste Codes
Q. When I send my hazardous waste to the treatment facility for disposal, they charge me separately for each waste code I report. Since I know some of the treatment standards overlap, is there anyway to avoid the expense and hassle of double-treating my hazardous waste?A. There are different reasons for recording and communicating waste codes (e.g. manifests, LDRs, etc.) It is likely that you are...
2/15/2011
Pointing in the Right Direction
Q. Our pick-and-pack operation ships lots of different kinds of hazardous material in many arrangements. Some of our boxes have up arrows, some do not. When do we need to use up arrows? Is there any time we can’t use them?A. Orientation arrows, or “up arrows,” are required whenever you ship hazardous materials in one of these packages...
2/1/2011
Question of the Week: Communicating Unknown Hazards
Q. When an employer discovers that a chemical product has a hazard that is NOT indicated on the manufacturer’s Material Safety Data Sheet (MSDS), what should he or she do?A. The Hazard Communication Standard (HCS: 29 CFR 1910.1200(h)) requires chemical manufacturers to assess the hazards of their products and prepare the MSDS accordingly. The MSDS must report...
1/21/2011
Question of the Week: Calculating Generator Status
Q. What is "generator status," and how do I calculate it?A. Each and every person who produces hazardous waste is a generator and must determine his or her generator status each calender month. A facility’s generator status determines how stringently it is regulated and how long it may accumulate hazardous waste on site without a permit...
1/19/2011
PHMSA Publishes HM215-K, International Harmonization Rule
On January 19, 2011 (76 FR 3308), the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule incorporating into the Hazardous Material Regulations changes based on the 16th Revised Edition the UN Model Regulations, Amendment 35-10 to the International Maritime Dangerous Goods Code, and the 2011-2012 edition of the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air.
1/11/2011
Greenhouse Gas Emission Rule Updates
With the calendar switching over to 2011, the EPA’s regulation of greenhouse gas emissions is kicking into high gear. Several final rules promulgated in 2009 and 2010 will have obligations for regulated entities in 2011. In the latter days of 2010, the EPA promulgated several final actions, and the EPA is not finished. The Agency is planning more...
1/5/2011
IATA Publishes Addendum to the 52nd Edition of the Dangerous Goods Regulations
On December 30, 2010, IATA published an addendum to the 52nd Edition of its Dangerous Goods Regulations (DGR), an adaptation of the ICAO Technical Instructions for carriage of dangerous goods by aircraft. These revisions became effective on January 1, 2011.
Highlights of the Addendum include...
1/5/2011
DOT Revises Special Permit Application Requirements
On January 5, 2011, the U.S. DOT Pipeline and Hazardous Material Safety Administration (PHMSA) published a final rule revising and clarifying its procedures for special permit applications [76 FR 454]. The revisions will require the applicant to provide more information that will be used by PHMSA to determine...
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