Posts Tagged ‘Regulatory Compliance’

Total Environmental & Safety, LLC (Total) Can Give Your Facility a Check-Up to Strengthen Your Overall EHS Regulatory Compliance Readiness

Wednesday, October 15th, 2014

Let Total conduct a cost effective Environmental and Health & Safety (EHS) Regulatory Compliance Gap Analysis, which is a process that identifies high level gaps in your EHS program. If you don’t have an existing program or your program is limited, the gap analysis will identify regulations and requirements that apply to your facility.

For more information contact Ralph Carito at 908-442-8599 or

EPA, OSHA and ATF provide information and lessons learned about the safe storage, handling and management of ammonium nitrate

Sunday, September 15th, 2013

The U.S. Environmental Protection Agency, the Bureau of Alcohol, Tobacco, Firearms and Explosives and OSHA have issued a chemical advisory (*PDF) that provides information on the hazards of ammonium nitrate storage, handling and management. This action supports the goals of President Obama’s August 2013 executive order on “Improving Chemical Facility Safety and Security.” The advisory provides lessons learned for facility owners and operators, emergency planners and first responders from recent incidents, including the ammonium nitrate explosion in West, Texas, in order to prevent similar incidents.

“Ammonium nitrate can be very dangerous, and it’s imperative that employers, workers and first responders all understand the hazards,” said Dr. David Michaels, assistant secretary of labor for occupational safety and health. “With this understanding, together they can control these hazards and save lives and limbs.” Read the EPA press release for more details.



Federally Regulated Waters – Far Beyond What Congress Intended in the Clean Water Act

Sunday, September 1st, 2013

Senate Republicans have dusted off and reintroduced a bill (Preserve the Waters of the United States Act, S. 1006) that would prohibit the EPA and the Army Corps of Engineers (Corps) from finalizing a jointly issued draft guidance that according to the lawmakers, stretches the definition of “federally regulated waters” far beyond what Congress intended in the Clean Water Act (CWA). The compact bill–190 words in its entirety–would also prohibit the agencies from using the guidance or any “substantially similar guidance” as the basis for any final rule.

As used in rulemaking, the phrase “waters of the United States” most often refers to waters subject to CWA Section 404 dredge and fill permitting as implemented by the Corps and subject to EPA approval. But in the draft guidance, the agencies make it clear that the phrase extends to other major programs administered under the CWA, including water quality standards and implementation (Section 303), oil and hazardous substance liability (Section 311), and National Pollutant Discharge Elimination System (NPDES) permitting (Section 402). (more…)

Hurricane Preparedness Tips For Businesses

Thursday, August 15th, 2013

The meanest stretch of hurricane season, when the tropics burst with activity, has arrived, and right on cue two disturbances were brewing on Tuesday, one in the Caribbean and one in the Atlantic.

Have you ever considered the catastrophic effects a hurricane may have on your business, your employees and your life?

Almost every business is required to have an emergency action plan (EAP). If fire extinguishers are required or provided in your workplace, and if anyone will be evacuating during a fire or other emergency, then OSHA’s 29 CFR 1910.38 requires you to have an EAP.  Businesses would be wise to add a section to their emergency action plan on hurricane preparedness. (more…)

Lists of Hazardous Wastes You Should Know

Sunday, August 11th, 2013

The Environmental Protection Agency (EPA) has established two ways of identifying solid wastes as hazardous under the Resource Conservation and Recovery Act (RCRA) regulations; keeping in mind that according to EPA’s definition of a solid waste, a solid waste can be either a liquid or solid.

First, a waste may be considered hazardous if it exhibits certain hazardous properties or “characteristics.” EPA’s regulations define four hazardous waste properties that, if exhibited, identify a waste as a “characteristic hazardous waste”. They include Ignitability, Corrosivity, Reactivity, and Toxicity

The second way to tell if a waste is hazardous is if it is included on a specific RCRA list that EPA has determined are hazardous. These “listed wastes” are placed on a list because EPA finds them to pose substantial present or potential hazards to human health or the environment, as summarized below. (more…)

Nutrient Trading: EPA and State Roles

Saturday, July 20th, 2013

Some water experts believe that restoring the quality of U.S. waters is not possible without aggressive state-run nutrient trading programs. Trading currently exists in many states that have developed approaches consistent with their waters, the sources that discharge nutrients into those waters, and their obligations under the Clean Water Act (CWA).

The Environmental Protection Agency (EPA) has encouraged states to develop nutrient trading structures for years. When states apply nutrient trading in their CWA programs (e.g., NPDES permitting or total maximum daily loads [TMDLs]), the EPA has oversight authority – that is, the EPA can approve the trading program or require that the state first make improvements. (more…)

A VPP Success Story

Monday, January 28th, 2013

Over the past month Total Environmental & Safety, LLC (Total) had the unique opportunity to assist a major chemical company with the renewal of their OSHA VPP Star status. Five years had passed since the company was awarded this prestigious status and management wanted to continue benefitting from what has proven to be a very successful program for them. The five-year mark triggered the scheduled audit by OSHA to check on their continued efforts in the program. (more…)

OSHA’s Standards Improvement Project – Phase IV

Sunday, December 16th, 2012

“Nobody made a greater mistake than he who did nothing because he could only do a little.” (Edmund Burke, 1729-1797)

Beginning December 6, 2012 and ending February 4, 2013, we have a small window of opportunity to improve the system by letting OSHA know of any construction standards that are out of date, duplicative or inconsistent.

OSHA is requesting assistance from the public, including employers, employees, and employee representatives involved in the construction industry, to submit recommendations for revisions to or removal of existing construction standards, including the rationale for these recommendations. The Agency is targeting primarily construction standards that are confusing or outdated, or that duplicate, or are inconsistent with other OSHA standards or the standards issued by other agencies. (more…)

PSM Enforcement in the Chemical Industry

Monday, September 24th, 2012

Chemical plant managers who have found themselves missing their friendly neighborhood U.S. Occupational Safety and Health Administration (OSHA) inspector need worry no more.

OSHA announced the nationwide expansion of its process safety enforcement program for the chemical industry, formally known as the Process Safety Management (PSM) Covered Chemical Facilities National Emphasis Program (NEP), or the chemical NEP. The national program is based on a previously piloted program in 16 states.

The origin of the program has its roots in the Texas City Refinery accident of 2005 and the resulting increased scrutiny towards process safety enforcement in the refining industry, which culminated in the refinery NEP.

What Facilities Are Targets?

OSHA has identified four sources of information that it will draw from to develop a list of facilities that will be inspected:

1. Facilities that have submitted a U.S. Environmental Protection Agency (EPA) program Level 3 risk-management plan.

2. Facilities with an explosives manufacturing North American Industry Classification System Code.

3. Facilities that have been previously cited by OSHA for a PSM violation.

4. Local office knowledge of PSM-covered chemical facilities.

Excluded from that list are refineries (refineries have already been scrutinized via the refinery NEP), chemical facilities that participate in OSHA’s Voluntary Protection Program (VPP), and chemical facilities that have been inspected within the past two years. Unfortunately, all other facilities will have no way of knowing whether or not their number is up until the OSHA inspector knocks on their door. (more…)

Does Your Facility Generate Hazardous Waste?

Monday, June 11th, 2012

Is your facility a hazardous waste generator, and if so, do you know what kind of generator you are? Many companies are often surprised to discover that they generate regulated waste and exactly how much they generate. A facility can be considered a hazardous waste generator if they generate trigger amounts of less hazardous substances like oil-based paint to the most extreme hazardous substances like hydrofluoric acid.

If a company generates a certain amount of hazardous waste they’re required to register with the United States Environmental Protection Agency (EPA) and obtain an EPA Identification Number (EPA ID Number). State and local agencies may also have registration, fee, and regulatory requirements that need to be adhered too. (more…)