Posts Tagged ‘EPA’

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…)

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…)

14 AGs File a Motion to Intervene in O&G Methane Case

Wednesday, July 5th, 2017

The case against EPA’s effort to freeze the Agency’s June 2016 New Source Performance Standards (NSPS) imposing air pollution controls the oil and natural gas (O&G) industry expanded when the attorneys general (AGs) of 14 states and the city of Chicago filed a motion to intervene on behalf of the plaintiffs, five environmental groups.

“State Intervenors have unique interests in the outcome of this case that may not be adequately represented by Petitioners, and State Intervenors are uniquely situated to explain the burdens and harms of staying the 2016 Rule on those State interests,” say the AGs in their motion. (more…)

What You Don’t Know About RCRA’s Waste Analysis Requirements

Wednesday, May 24th, 2017

“According to the EPA, a “cornerstone” of the RCRA hazardous waste program is the ability of regulated entities to properly identify which hazardous waste(s) they are generating. As a result, the EPA issued regulations that compel large quantity generators (LQGs) and small quantity generators (SQGs) of hazardous waste to develop and implement a waste analysis plan (WAP) to classify the hazardous waste and ensure that it is managed properly.”

In addition, owners and operators of RCRA-permitted transfer, storage, and disposal facilities (TSDFs) may also be required to develop and use WAPs if the generator does not provide the TSDF with a complete and up-to-date waste analysis. (more…)

Getting the Most Out of Your Spill-Prevention Plan

Thursday, March 2nd, 2017

Creating a spill-prevention plan does more than just outline the methods for averting spills at a facility. It can help minimize other environmental, health and safety hazards and complement a variety of compliance strategies.

Like a multi-function knife, a well-prepared spill-prevention plan is a versatile tool that can be used for many purposes.

For example, EPA’s stormwater regulation and spill-prevention control and countermeasure regulation both have spill-prevention planning elements that can be served by a single well-designed spill-prevention plan.

On the safety side, managing chemicals and preventing spills can overlap with the facility’s hazard communication plan. And because spills are a risk factor for slips and falls, an effective spill-prevention plan can help reduce injuries and enhance the overall safety program. (more…)

Getting the Most Out of Your Spill-Prevention Plan

Tuesday, November 29th, 2016

Creating a spill-prevention plan does more than just outline the methods for averting spills at a facility. It can help minimize other environmental, health and safety hazards and complement a variety of compliance strategies.

Like a multi-function knife, a well-prepared spill-prevention plan is a versatile tool that can be used for many purposes.

For example, EPA’s stormwater regulation and spill-prevention control and countermeasure regulation both have spill-prevention planning elements that can be served by a single well-designed spill-prevention plan.  (more…)