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1/3/2012

Recording Injuries Away From Work

Q. We have employees who work in the office about half the time, but work off-site the other half. If they were hurt driving for work, would I have to record this injury?
 
A. As always, it depends on the situation.
 
Under Occupational Safety and Health Administration (OSHA) rules, all employers are required to...

12/30/2011

DOT Publishes Clarification to HM-218F Rule

PHMSA published a rule in Wednesday’s Federal Register (December 28, 2011). It was meant to amend and clarify the July 20, 2011 HM-218F rulemaking. According to PHMSA, “…[T]he July 20, 2011 final rule [was meant to] promote...

12/30/2011

DOT Clarified Harmonization Rulemaking

The U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) is promulgating a final rule that amends the January 19, 2011 harmonization rulemaking.
 
The new rule does many things, but most notably, PHMSA is extending the phase out period for...

12/27/2011

RCRA State Authorization

Did you know that each U.S. state can enforce its own hazardous waste program and that each State program is unique and can vary from Federal standards?
 
When Congress first gave the U.S. EPA authority to regulate hazardous waste in the United States (the Resource Conservation and Recovery Act of 1976), they included provisions for...

12/20/2011

Keeping Up With the Changes to International Dangerous Goods Regulations

Q. How much longer can I ship something as a Consumer Commodity, ORM-D?
 
A. On January 19, 2011, the Department of Transportation (DOT) promulgated a new regulation that phases out the ORM-D classification [76 FR 3308]. In the past, this classification has applied to packages of...

12/13/2011

Environmental Regulations Year in Review

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...

12/8/2011

EPA Guidance Document: How Do I Keep My RCRA Waste Containers "Closed"?

Whether it is your 90-day storage area, your 180-day storage area, or your satellite accumulation area, all containers that contain hazardous waste must remain “closed,” except when adding or removing waste [40 CFR 265.173(a)].
 
The word “closed” is...

12/6/2011

Are You Ready for OSHA's GHS Adoption

Q. How will the Globally Harmonized System (GHS) affect my HazCom Standard communications?
 
A. The Hazard Communication (HazCom) Standard is a rule designed by the Occupational Safety and Health Administration (OSHA) to...

12/2/2011

PHMSA Restricts Hand-Held Mobile Phone Use for Commercial Drivers

Today, December, 2, 2011, two agencies under the Department of Transportation amended their rules to restrict the use of hand-held mobile telephones by drivers of commercial motor vehicles.
 
Promulgated by the Pipeline and Hazardous Material Safety Administration (PHMSA) and the Federal Motor Carrier Safety Administration (FMSCA), this rule modifies ...

11/29/2011

Preparing for 2012 Reporting Obligations

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...

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