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08/02/2011

Question of the Week: Hazard Communication for CESQGs

Q. We are a conditionally exempt small quantity generator (CESQG). We hold waste on site in a central storage area for up to six months before we ship everything off site, but we don’t follow the actual 180–day rules while we’re storing the waste. We mark the words “Hazardous Waste” on our containers but nothing else. Since some of the waste is flammable, do we need to label the containers with either DOT labels or OSHA hazard communication labels while we’re storing them...

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07/20/2011

Miscellaneous Amendments to Hazmat Regulations

On July 20, 2011, at 76 FR 43510 the Pipeline and Hazardous Materials Safety Administration (PHMSA) amended the Hazardous Material Regulations (HMR) to make miscellaneous amendments to update and clarify certain regulatory requirements.
 
These amendments were based on petitions from the regulated community and PHMSA’s own initiative. The amendments are intended to update, clarify, or provide...

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06/22/2011

OSHA Proposes Changes to Injury & Illness Recording Requirements

In today’s Federal Register (76 FR 36414), the Occupational Safety and Health Administration proposed a set of rule changes to the Occupational Injury and Illness Recording and Reporting requirements.
 
OSHA proposed to update Appendix A to Subpart B of 29 CFR Part 1904, containing the list of industries that are partially exempt from maintaining records of...

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05/31/2011

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...

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05/10/2011

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...

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04/12/2011

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...

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03/18/2011

EPA Extends First GHG Emission Reporting Deadline

The EPA published a final rule on March 18, 2011 that extends the deadline for the initial reports under the Mandatory Greenhouse Gas Emission Reporting rule at 40 CFR Part 98 [76 FR 14812]. The deadline has been moved from March 31 to September 30, 2011. This one-time extension is...

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03/08/2011

Extension of GHG Reporting Deadline

In a press release issued on March 1, 2011, the EPA announced their intent to extend the data submission deadline for the Greenhouse Gas Reporting Program. The original deadline for reporting on 2010 emissions was March 31, 2011...

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02/15/2011

Pointing in the Right Direction

Q. Our pick-and-pack operation ships lots of different kinds of hazardous material in many arrangements. Some of our boxes have up arrows, some do not. When do we need to use up arrows? Is there any time we can’t use them? A. Orientation arrows, or “up arrows,” are required whenever you ship hazardous materials in one of these packages...

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02/08/2011

FAQ on Annual Hazardous Chemical Inventory Reporting

March 1, 2011 is the deadline for the annual hazardous chemical inventory reporting under the EPCRA rules at 40 CFR 370. Here are the answers to some of the most frequently asked questions on this topic...

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download our latest whitepaper

Lithium battery regulations are complex and constantly evolving. If you’re just starting out with lithium battery shipping, answering the four questions in this guide will help you determine how stringently your shipment will be regulated and where to find the rules you need to ensure compliance.

How Do I Ship A Lithium Battery