EPA Unveils Its PFAS Action Plan: What You Need to Know
The EPA recently launched its Action Plan for per- and polyfluoroalkyl substances (PFAS). PFAS are a large class of manufactured chemicals that are very effective in several industrial applications, but have also posed risks to human health through drinking water sources around the United States. The Action Plan mainly uses the Safe Drinking Water Act […]
Deadline for Submission of EPCRA Tier II Forms is March 1
March 1 is the deadline for submission of EPCRA Tier II forms. If you have hazardous chemicals at your facility that mandate a Safety Data Sheet (SDS), you may need to submit Tier II forms under the Emergency Planning and Community Right-to-Know Act (EPCRA). Only chemicals that are in excess of established thresholds need to […]
New Rule for Hazardous Waste Pharmaceuticals
Once upon a time, EPA attempted to make pharmaceutical waste a universal waste. This proposal and draft rule (which attempted to make management of pharmaceutical waste less onerous for healthcare facilities) died on the vine and will likely never be finalized by EPA. Just in time for the holidays, however, EPA changed its strategy and […]
4 Goals Pursued by the New Federal Lead Action Plan
On Dec. 19, the Trump administration unveiled its new Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts. “The Federal Lead Action Plan will enhance the Trump Administration’s efforts to identify and reduce lead contamination while ensuring children impacted by lead exposure are getting the support and care they need,” EPA Acting […]
Goodbye, paper manifests!
The US Environmental Protection Agency’s (EPA) hazardous waste manifest system is designed to track hazardous waste from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat or dispose of the hazardous waste. In 2014, the EPA established a national system for […]
New Hazardous Waste Requirements, and Flexibility
One of the biggest environmental regulations that we deal with every day is the Resource Conservation and Recovery Act (RCRA). Passed in 1976, RCRA is as a solid waste disposal law that addresses the management of both solid waste and hazardous waste. The implementing regulations took effect in 1980. RCRA was intended to be implemented […]
No Chemical Spill Plans, For now…
In case you missed it, on June 15, (now former) U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt signed a proposed action to establish no additional regulatory requirements under the Clean Water Act (CWA) section 311(j)(1)(C) authority for CWA hazardous substances (HS) discharge prevention. The EPA published the Notice of Propose Rulemaking (NPRM) on June […]
SPCC Training: Who are Oil-handling Personnel?
Your engineer finally delivered the Spill Prevention, Control, and Countermeasure Plan (SPCC Plan) for your facility, and it requires that you train Oil-handling employees. Oil-handling employees? How do you determine which of your employees meet the definition of that term? BACKGROUND EPA’s SPCC regulation (found at 40 CFR 112.7) require that the owner or operator […]
What is a Class V Underground Injection Well?
If you think your facility doesn’t have a Class V underground injection well, you might want to check again. Recent enforcement action by EPA Region 9 has resulted in violations against facilities that failed to identify, register, and maintain their dry wells. If you don’t know what an underground injection well is, read on. What […]
Is root cause analysis really worth the effort as part of environmental compliance audits?
Well, we think so. Identifying the same type of compliance deficiency in multiple locations, or during each recurring audit for the same facility, can only get us so far. Assuming the deficiency was corrected following each audit, the problem is re-emerging. Perhaps if we figured out the underlying cause, we could resolve it once and […]