Posts Tagged ‘Environmental’

Transporting Class 9 Hazmat – HMEs and Registration

Friday, November 3rd, 2017

There seems to be much confusion regarding transporting class 9 hazardous materials (hazmat). Let’s take a look at two issues, one concerning the need for a hazmat endorsement and the other concerning registration.

In the classification system of the U.S. Department of Transportation’s (DOT) hazmat, class 9 hazmat includes those that don’t come under any of the other hazmat classes (e.g., explosives, flammables). But, they are still hazardous materials, and there is a placard for them. But, does the placard have to be used?  (more…)

Strategic EHSQ and Mission-Critical EHSQ – The Future of Environment, Health, and Safety Management

Friday, November 3rd, 2017

At Medgate, we’re always obsessively thinking about where the market is heading and how we can stay ahead of the curve, especially as it relates to customer requirements.

Strategic EHSQ—An Overview

Today, every industry faces ever-rising customer expectations, ever-evolving competition, and ever-changing compliance requirements. Beyond risk mitigation and compliance, effective Environment, Health, Safety, and Quality (EHSQ) programs can be a competitive advantage. Harnessing data to gain insight into—and proactively improve—operations can be the difference between market leadership and market irrelevance. (more…)

POTW NESHAP Rule Leaves Emissions Limits Unchanged

Friday, November 3rd, 2017

Following its Clean Air Act Section 112 residual risk and technology review (RTR) of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for publicly owned treatment works (POTWs), the EPA has determined that the technology-based standards in the existing NESHAP protect the public health with an ample margin of safety and that no developments in practices, processes, and control technologies were identified, which warrant revisions to the standards for this source category. Consequently, the final RTR rule contains no revisions to existing emissions limits. (more…)

Hazardous Drugs, Risky Behaviors: Why Won’t Healthcare Workers Wear Their Gloves?

Friday, November 3rd, 2017

Pharmacists who compound antineoplastic and other hazardous drugs, and the nurses who then administer them, are at high risk of occupational exposure. These exposures can cause acute health effects, from sore throats to hair loss; allergic reactions; cancer; and reproductive toxicity—including an increased risk of miscarriage. Despite this, multiple studies have shown that healthcare workers can be remarkably cavalier about the precautions that could prevent exposure, like wearing gloves. A National Institute for Occupational Safety and Health (NIOSH) survey reported that the most common reason given for failing to wear gloves was that “skin exposure was minimal”—an opinion at odds with various biological measures of worker exposures.

Yesterday we looked at the ways that healthcare workers can be exposed to hazardous drugs. Today we’ll look at some of the reasons they give for failing to comply with safe work practices that could help to prevent occupational exposures. (more…)

What Confuses Everybody About Secondary Containment

Wednesday, September 20th, 2017

What are the specific requirements for secondary containment of oil containers at SPCC-regulated facilities?

The entire containment system, including the walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs (40 CFR 112.7(c)).

Exceptions apply to qualified oil-filled operational equipment and flowlines and intrafacility gathering lines at oil production facilities.

Here’s more on simplifying secondary containment requirements. (more…)

Setting environmental objectives and targets for ISO 14001 Compliance

Wednesday, September 20th, 2017

Setting environmental objectives and targets for ISO 14001 Compliance 

What is an Objective? What is a Target?

Environmental objectives are goals that you would like to meet in the future.
Targets are the means for providing verifiable evidence that you have actually met the objective.  For example, your environmental objective may be to reduce the generation of hazardous wastes.  Your may then set your target at 20 percent reduction within 12 months.  In the parlance of ISO 14001, objectives are “documents” whereas targets are “records.”  Documents can be modified while records cannot.  For example, you can modify your objectives, but you cannot change having missed your targets. (more…)

EPA Seeks Elimination of $28 Million Monitoring Requirement

Friday, August 18th, 2017

A requirement to place wireless continuous monitors on containers at off-site waste and recovery operations (OSWROs) to detect leaks from pressure relief devices (PRDs) would be eliminated under an EPA proposal (August 7, 2017, FR).

The proposal responds to an industry petition for reconsideration of the requirement, which is included in the Agency’s 2015 residual Risk and Technology Review (RTR) of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for OSWROs. Jointly submitted by the American Chemistry Council and Eastman Chemical Company, the petition argued that the transitory nature of containers at OSWRO sites would make the installation of continuous monitoring devices technically impossible. Moreover, the petitioners said other federal regulations cover leak detection of OSWRO containers, and therefore, the RTR requirement is redundant. (more…)

Changes in Refrigerant Regulation – Are You Prepared

Friday, August 18th, 2017

The regulation of refrigeration and air-conditioning equipment is changing.  The universe of regulated refrigerants is expanding, commonly used refrigerants are being phased out, and revised refrigerant regulations are being phased in.  Is your facility prepared to cope with the changes in order to avoid penalties and enforcement actions?

The Changes

Refrigerant regulations originally addressed only ozone-depleting substances (ODSs) used as refrigerants.  However, revisions to the regulations, effective January 1, 2017, revised the definition of “refrigerant.”  The effect of this change was to extend the refrigerant regulations for ODS refrigerants to non-ozone-depleting substitute refrigerants. The change was primarily meant to address hydrofluorocarbons (HFCs), which have a very high global warming potential, but it does apply to any substitute refrigerant, other than the few that are specifically listed as exempt, and greatly expands the universe of regulated refrigerants. (more…)

11 Rules for Safe Handling of Hazardous Materials

Friday, August 18th, 2017

Do your employees know how to handle hazardous materials safely? Here are 11 basic rules all employees who handle hazardous materials should know and follow.

These 11 rules are presented in no particular order. They are all top priorities for chemical handlers. However, feel free to rearrange them in whatever order you think is best for your workplace, your workers, and your material hazards.

You’ll undoubtedly have other safety rules to add to the list. Better yet, present the list in a safety meeting and get employees involved in helping you add to the list. This will create a sense of ownership over your safe chemical handling rules.  (more…)

Updated ASTM AAI Standard Referenced by EPA

Wednesday, July 5th, 2017

In a direct final rule, the EPA is allowing the use of an updated nongovernmental consensus standard—American Society for Testing and Materials (ASTM) E2247-16, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property—to meet the All Appropriate Inquiries (AAI) requirement applicable to purchases of forestland and rural property. (more…)