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5/24/2011

Question of the Week: Using a Mass Balance Approach for RCRA Tanks

Q. Does a hazardous waste storage tank need to be emptied every 90 days (or 180 days), or can a ”mass balance approach” be taken?
 
A. EPA stated in the January 11, 1982 issue of the Federal Register (47 FR 1250) that generators must remove all wastes from the tank within...

5/17/2011

Question of the Week: Changes for Combustible Liquids?

Q. We ship a mineral spirits product that has a flashpoint of 120ºF in 55-gallon drums. The product has no other DOT hazards and is only shipped by highway. We have been using the opportunity that the DOT provided at 49 CFR 173.150(f) to reclassify our product as a combustible liquid so that we can take advantage of the exception at 49 CFR 173.120(b)(2). We heard that the DOT is eliminating the combustible liquid designation. What will this mean for our shipments?

5/10/2011

Question of the Week: Toxic Chemical Inventory (TRI) Reporting

Q. We are a facility that is subject to the toxic chemical inventory reporting requirements at 40 CFR Part 372. During the previous calendar year we mixed 24,800 pounds of a listed toxic chemical into one of our product formulations. In late December, we did add 200 more pounds into a batch processing unit. However...

5/3/2011

Feature Article: Get Ready for Summer Workplace Safety

The summer months will soon be upon us. This means that we will soon be faced with managing outside workplace safety issues. In the great outdoors, some of the hazards we will need to navigate are soot and air pollution, the cancer-causing ultraviolet rays of the sun, heat stress, poison ivy and other toxic plants, insect-borne diseases, and dangerous wildlife.
 
While the Occupational Safety and Health Administration (OSHA) has safety standards for ladder safety, fire exits, noise exposure, arc welding, chemical exposures, and many other hazards...

5/2/2011

Post-Rapanos Guidance from EPA and Army Corp of Engineers

In today’s Federal Register (76 FR 24479) the Environmental Protection Agency and the Army Corp of Engineers announced new guidance on the jurisdiction of the Clean Water Act...

4/29/2011

Question of the Week: Recycling Lead Batteries: Part 266 vs. Part 273

Q. EPA gives several options for managing spent lead-acid batteries. What is the benefit of choosing Universal Waste management rules versus the lead-acid battery rules in 40 CFR 266? 
 
A. Spent lead-acid batteries are exempt from the hazardous waste regulations and do not count towards a generator’s status determination as long as the generator follows either...

4/19/2011

Are You Ready for This Year’s Annual Registration Deadline for Hazmat Shipments?

Each year shippers and carriers of certain quantities and types of hazardous materials must comply with the registration requirements at 49 CFR 107, Subpart G. Registration, including a registration fee, is required for any person that offers or transports...

4/12/2011

Feature Article: Inventory Update Reporting

Facilities that manufacture or import chemical substances should be preparing for the pentennial (once every five years) Inventory Update Reporting (IUR) requirements [40 CFR 710]. The Toxic Substances Control Act (TSCA) requires the EPA to maintain an inventory of every chemical substance manufactured or imported into the United States [TSCA §8(b)].
 
If your site manufactured or imported a chemical substance in a quantity greater than or equal to...

4/6/2011

ATA Petitions for Reduced Regulations

On April 1, the American Trucking Association (ATA) filed a petition with the U.S. Department of Transportation (DOT) to repeal obsolete and overly burdensome regulations.
 
This petition was filed in response to the President’s Executive Order 13563...

4/5/2011

Question of the Week: What is the Chemical Safety and Hazard Investigation Board?

Q. I heard in the news that the Chemical Safety and Hazard Investigation Board (CSB) was sending a team to investigate a workplace fire in Tennessee. So, what is the CSB, and what does it do?
 
A. The Chemical Safety and Hazard Investigation Board (CSB) is an independent agency of the Federal Government that investigates the root causes of chemical accidents at industrial facilities and makes safety recommendations to prevent future accidents...

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Senior Environmental Engineer

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