"CARE, PROTECT, GROW": THE U.S.COMPLIANCE BLOG

Safety Committees – Tips for an Effective Team

Safety Committees can be a multifaceted tool within any organization’s Health and Safety program. According to an article from EHS Today by Guy Burdick, “Having one could reduce the number of workplace injuries and illnesses and workers’ compensation claims while bolstering your compliance with federal or state occupational safety and health regulations.” However, there is an even greater benefit that occurs from a committee: fostering management involvement and employee engagement. This is really what is needed for the long-term success

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Contingency Plans & Quick Reference Guides

In order to facilitate the response to a potential emergency, all Large Quantity Generators (LQGs) are required to submit a Contingency Plan. According to Title 40 CFR §262.261, a “contingency plan must describe the actions facility personnel must take to comply with §§262.260 and 262.265 in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility.” Requirements apply to all hazardous waste generators,

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TRI Reporting: Lead and the “Qualified Alloys”

Background The Toxics Release Inventory (TRI) is a national, publicly available database that summarizes toxic chemical releases reported annually by industrial and federal facilities. It is a great resource that distributes vital information to the public and is used to inform decision-making by communities, government agencies, and others. Unfortunately, completing the annual July 1 disclosure report (commonly known as the TRI Report) that contributes to the database can be quite a headache for regulated industries. The TRI report is required

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DOT Hazardous Materials – Understanding the Core Requirements

The transportation of hazardous materials (HazMat) within the United States is governed by the Hazardous Materials Transportation Act, with its purpose being to “protect against the risks to life, property, and the environment that are inherent in the transportation of hazardous material.” The regulations, which were created under the passage of this act, can be found in Title 49 of the US Code of Federal Regulations (CFR). These standards set forth the requirements for material classification and labeling, provide for

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Parametric Monitoring: What It Is and How to Manage Abnormal Readings

The Clean Air Act (CAA) was established to protect public health and the environment from hazardous and harmful emission releases into the atmosphere. As part of the CAA, stationary source emissions monitoring was implemented; this provides data and information from a source to demonstrate compliance with certain regulatory requirements in federal or state rules, or in an operating permit. Parametric Monitoring Systems Parametric monitoring systems use observations of an operational parameter of an emission unit, emission process, or air pollution

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Environmental Reporting and Covid-19

The upcoming environmental reporting season includes major obligations for most programs. With business as usual disrupted for the past couple of months, it is important to prepare the necessary information in order to submit accurate reports despite furloughs and temporary closures. With the expiration of the EPA’s COVID Temporary Enforcement Policy on August 31, 2020, it is important to understand how regulatory agencies are exercising their enforcement. Are regulatory deadlines in effect? Yes. There has been consistent communication that all

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Ergonomics: Keys to Injury Reduction

Whether we spend our day sitting in an office chair or working on a production floor, we are all affected by ergonomic factors. Poor management of ergonomic risk factors may lead to Work-Related Musculoskeletal Disorders (WMSDs) such as repetitive stress injuries, lower back injuries, vibration syndromes, subluxation, and neck and shoulder injuries. In order to protect ourselves and our employees, we need to understand what ergonomic risks we are exposed to, and more importantly, how to control these risks to

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Am I Required to Prepare and Implement a Spill Prevention Control and Countermeasure (SPCC) Plan?

The purpose of an SPCC Plan is to establish a comprehensive program that mitigates oil spills from reaching navigable waters and describes the necessary equipment, engineered controls, and procedures in place to prevent oil spills from occurring. The SPCC Rule is controlled under The Oil Pollution Prevention Regulation, which is outlined in Title 40, Part 112 of the Code of Federal Regulations. For a facility to be applicable under the SPCC Rule, they must: Be non-transportation-related; Have aggregate bulk oil

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Reducing Zinc and Total Suspended Solids in Stormwater Runoff

Many states require facilities covered under a general industrial stormwater permit to collect stormwater samples and have them analyzed for common pollutants. Stormwater pollutants vary by facility and industry because the potential pollutants will be dependent on the materials and equipment stored inside and outside of the facility. Two common stormwater pollutants are zinc and total suspended solids (TSS). It is not always clear where a pollutant is coming from, which makes lowering the level of that pollutant in the

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Refrigerant Management: The Scientific Basis to the Current Regulation

Chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) have historically been used in a variety of refrigeration applications in manufacturing, from large process chillers to small office air conditioning units. Sections 608 of the Clean Air Act and subsequent federal regulations under 40 CFR 82 regulate these refrigerants to minimize detrimental atmospheric changes caused by releases. As recent regulations have changed, it is important to understand the mechanisms by which the refrigerants can cause atmospheric changes and how to manage facility use. Understanding

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SPCC Transformers: Am I Responsible?

It is becoming increasingly common to find electric transformers at large commercial, institutional and industrial facilities. Although the transformer is located on the facility’s property, it is sometimes unclear who actually owns the transformers and is responsible for the maintenance and spills. The transformer may be owned by the facility, typically seen on older properties or those that require multiple transformers with high voltage, or by the local power company. Units that contain oil are called “wet” transformers as they

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Ozone Nonattainment: Impact to Air Permitting

Under the Clean Air Act, the U.S. Environmental Protection Agency (EPA) sets National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the environment. Any city or county that does not meet a NAAQS is classified as a nonattainment area. Ozone is one of the six criteria pollutants with NAAQS and is formed when nitrogen oxides (NOx) and volatile organic compounds (VOCs) react in the atmosphere in the presence of sunlight. The EPA set the 2008

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