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7/9/2012

New Highway Bill Raises Civil Penalties for Hazmat Violations

On Friday, President Obama signed into law the Moving Ahead for Progress in the 21stCentury (MAP-21) highway bill.  This bill made significant changes to the hazmat portions of the current highway law, including increasing civil penalties for hazmat violations...
Updating Safety Data Sheets

7/3/2012

Updating Safety Data Sheets

Q. With the new GHS rules, who has to create Safety Data Sheets and what kind of information must go into them?
 
A. Now that the Occupational Safety and Health Administration (OSHA) has adopted the Globally Harmonized System (GHS) into the Hazard Communication Standard, employers and chemical manufacturers must take several steps to ensure they...

7/2/2012

DOT Training Requirements for Signing a Waste Manifest

“I have an employee that is responsible for signing the manifest for our off site shipments of hazardous waste. I have heard that this employee is subject to DOT training. If this is true, what training must I provide to this employee?”
 
This is a common question that is asked by compliance managers at sites dealing with...

7/1/2012

Last Chance to Update Your Shipping Papers

Beginning January 2013, any shipping papers printed with the old style hazmat description (PSN first) will be subject to rejection by the transporter, enhanced inspection by the authorities, and possible civil fines.  The Pipeline and Hazardous Materials Safety Administration (PHMSA) establishes requirements for...

6/26/2012

Determining Toxicity & When to Use the TCLP Test

A solid waste exhibits the characteristic of toxicity if it contains an elevated level of a toxicity contaminant. The toxicity contaminants are listed in Table 1 at 40 CFR 261.24 and include, but are not limited to...

6/19/2012

ERI Contract Numbers

Q. I was told by my carrier that, in addition to listing an emergency response telephone number on my shipping papers, I would also need to write down my emergency provider contract number next to it. Is this true?
 
A.  Not exactly.
 
Unless specifically exempted, every hazmat shipment that needs shipping papers also needs...

6/19/2012

EPA Extends Reporting Period for 2012 CDR

On June 11, 2012 Mr. Jim Jones, EPA Acting Assistant Administrator for the Office of Chemical Safety and Pollution Prevention signed a rule to extend the Chemical Data Rule (CDR) reporting period by six weeks. The submission deadline for the report is moved to...

6/12/2012

EPA Issues New Controls for Mercury Articles

On May 30th, 2012, EPA published a Significant New Use Rule (SNUR) for elemental mercury used in barometers, manometers, hygrometers, and pyrometers. Under the terms of the Toxic Substances Control Act (TSCA), this means that beginning June 29, 2012, any “new use” of elemental mercury in certain articles must be reported to the EPA before...

6/5/2012

OSHA Form 300: How to Record Pre-existing Injuries

Q. If I have an employee who has a pre-existing injury from something non-work-related, but she becomes reinjured while doing her job, do I have to record the injury?
 
A. The Occupational Safety and Health Administration (OSHA) requires employers to record each fatality, injury, and illness that is...

5/29/2012

Shipping Dangerous Goods by Air: How to Calculate Q Values

Q. I want to ship a package that contains multiple dangerous goods in the same package. What special concerns do I have when preparing it for air shipment?
 
A. When shipping dangerous goods by air, most carriers require you to follow the...

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CAD & Environmental Manager

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