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03/05/2013

The Challenge of Fall Protection

For the past twenty years, fatalities related to falls have consistently ranked in the top four causes of workplace deaths. The Occupational Safety and Health Act requires employers to protect their employees from recognized hazards that may result in death or serious physical harm and to comply with OSHA standards. So which standards might the employer need to consider in addressing workplace fall protection....

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02/26/2013

Managing Hazardous Waste as Used Oil

In general, the EPA does not consider used oils to be hazardous waste. In establishing proper management standards for these wastes, the EPA presumed that recycling, from re-refining to burning as fuel, would occur. The used oil rules at 40 CFR 279 are less burdensome than the hazardous waste regulations (40 CFR 260-270). In some circumstances, the EPA even allows...

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02/19/2013

How to Classify Hazmat That Changes Its Characteristics

Q. I have to ship some solid phosphoric acid powder. The Hazardous Material Table says it’s a Class 8—Corrosive hazardous material. I thought that Class 8 was only for corrosive liquids. What’s up with that?
 
A. A material is a Class 8 hazmat if it fails the tests given in 49 CFR 173.137. The procedures for those tests are calibrated for...

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02/12/2013

Greenhouse Gas Reports Due March 31st!

The 2013 submission deadline for 40 CFR 98, more commonly called “the Greenhouse Gas Reporting Rule,” is fast approaching. Unlike 2011 and 2012, in which the reporting deadlines were pushed back to September due to technology issues, this year the EPA requires reports be submitted by...

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02/05/2013

Transitioning to OSHA’s New GHS Rules

Q: I am in charge of overseeing my company’s transition to OSHA’s new GHS Hazard Communication Standard. How much of the standard will be changing?
 
A: The overhaul to OSHA’s Hazard Communication System (HCS) has caused anxiety nationwide in many industries since the rulemaking was announced—but while many aspects of hazard communication...

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01/29/2013

Understanding Your Generator Status

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a generator of hazardous waste. Waste can be produced by industrial processes or through recycling and waste treatment. Wastes can become subject to regulation without actually being produced through the closure of a process or facility or the cleanup...

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01/22/2013

New Requirements for Limited Quantities & Consumer Commodities

Q. Settle a bet. My co-worker says a limited quantity hazmat package doesn’t need shipping papers; I say that exception is only for consumer commodities. Who’s right?
 
A. You’re both a little bit right, and you’re both a little bit wrong...

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01/15/2013

Prepare Your Tier II Reports Now: March Deadline

It’s that time of year again: the March 1 deadline for submitting the Tier I or Tier II Chemical Inventory Report under the Emergency Planning and Community Right-to-Know Act (EPCRA) is fast approaching. 
 
Tier Reporting Requirements
 
You must comply with these reporting requirements if your facility holds a threshold planning quantity (TPQ) of...

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Get to know the top 5 changes to OSHA’s revised GHS Hazard Communication Standard at 29 CFR 1910.1200 and how the updates impacts employee safety at your facility.

The GHS HazCom Transition Five “Must Know” Changes