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6/9/2011

Report on PHMSA’s Pre-UN Public Meeting

On June 8, the U.S. Department of Transportation’s Pipeline and Hazardous Material Safety Administration (DOT-PHMSA) held a public meeting to consider proposals for the 18th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations, which will be implemented on January 21, 2015...

6/7/2011

Question of the Week: When Do I have to Update My Material Safety Data Sheets?

Q. Under the Hazard Communication Standard (29 CFR 1910.1200), the Occupational Safety and Health Administration (OSHA) requires manufacturers and importers to obtain or develop material safety data sheets (MSDS) for each hazardous chemical they produce or import. Manufacturers and importers must provide these MSDS to distributors and employers with their initial shipment, and with the first shipment after the MSDS are updated.
 
How often does OSHA require manufacturer/importers to update their MSDS?

6/6/2011

Homeland Security Announces Regulatory Review Plan

In today’s Federal Register (76 FR 32331), the Department of Homeland Security announced its Preliminary Plan for Retrospective Review of Existing Regulations, pursuant to Executive Order 13563. The plan was developed in part from the public input solicited by DHS in the Federal Register on March 14, 2011, “Reducing Regulatory Burden; Retrospective Review Under Executive...

5/31/2011

Question of the Week: What’s Going to Happen to ORM-D?

Q. I’ve heard the U.S. Department of Transportation (DOT) is phasing out the Consumer Commodity (ORM-D) exceptions from the Hazardous Material Regulations (HMR; 49 CFR parts 171-180). When did this happen? When does it take effect? And does this mean that regular consumer products need shipping papers and the whole rigmarole of marks, labels, and UN specification packaging like regular hazmat...

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...

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No comparison. Lion has the best RCRA training ever!!

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The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

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