Environmental Update
EPA e-Manifests Open to Waste Generators

Using computer near truck

Are You Ready for e-Manifests?

Paperwork – it’s one of the worst parts of dealing with hazardous waste shipments. In both Canada and the United States, hazardous wastes require a special document, the Waste Manifest that will not only serve as the transportation document for the dangerous goods/hazardous materials transportation regulations, but also allow environmental authorities to track the waste from the generator, who sends it for disposal, through the hands of the carrier, to the end receiver (in the US referred to as a TSDF, for Hazardous Waste Treatment, Storage and Disposal Facility).

In Canada, some jurisdictions have eased the burden by allowing the waste manifest to be created electronically. For example, in Ontario, the HWIN system has been used for years. However, until now, the United States has not had a system for electronic documentation, called e-Manifests. On June 30, 2018, that has changed.

The change has been a long time coming. Although the initial proposal by the Environmental Protection Agency (EPA) was made in 2001, it was not until 2012 that Congress passed the “Hazardous Waste Electronic Manifest Establishment Act.” Under the Act, a final rule was published in 2014 that approved the use of such manifests. Since then, the EPA has been working to create an online system that will allow the e-manifest to eliminate substantial chunks of the burden of manifests, as well as Continue Reading…

Environmental Update
EPA Aligns 40 CFR Part 370 with OSHA Hazcom 2012

The Environmental Protection Agency (EPA) issued a final technical amendment to 40 CFR Part 370, in June 2016 which aligns the hazardous chemical reporting regulations to the changes in the Occupational Safety and Health Administration’s (OSHA) Hazcom 2012.

These changes have a compliance date of January 1, 2018, and affect reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA), sections 311 and 312.

Section 311 of EPCRA requires facilities to submit a SDS or a list of hazardous chemicals grouped by categories of physical and health hazards. Section 312 of EPCRA requires facilities to submit an emergency and hazardous chemical inventory form yearly by March 1.

Prior to the change in 2012, the hazard communication regulations (OSHA) were performance oriented, and did not specify the language/description or format that the company had to use. Once the hazard communication regulations were updated, stakeholders requested that EPA align the wording to be consistent with the new OSHA Hazcom 2012 regulations.

Some of the changes in 40 CFR Part 370 include:

  • Technical terms have been updated (i.e., Material Safety Data Sheet to Safety Data Sheet)
  • The definition of Hazard Category has been updated
  • The “Five categories” (Fire/Sudden release of pressure/Reactive/Immediate acute and Delayed-chronic) have been changed to match the physical and health hazards outlined the Hazcom 2012
  • The Tier I and Tier II inventory forms are modified
  • Tier 2 Submit, the software will be updated, and EPA is Continue Reading…
US Report on Chemical Safety and Security Issued

On June 6, a working group of Federal departments and agencies issued a report to President Obama titled Actions to Improve Chemical Facility Safety and Security – A Shared Commitment. This report is the result of Executive Order 13650, issued in August, 2013, requesting these departments and agencies to:

  • Strengthen community planning and preparedness;
  • Enhance Federal operational coordination;
  • Improve data management within the Federal government, and improve information sharing;
  • Modernize policies and regulations, to reflect the most up-to-date practices; and
  • Incorporate stakeholder feedback and developing best practices.

The report recognizes that chemical facilities represent a serious challenge for both safety and security. For example, the recent explosion in West, Texas shows the devastation that can be caused when safety systems fail where large quantities of hazardous chemicals are stored. Therefore, government and industry must work together to make facilities and the communities around them as safe and secure as possible.

Steps taken so far include:

  • Meetings with the Department of Homeland Security (DHS) and Environmental Protection Agency (EPA) with emergency responders across the country to increase preparedness and share lessons learned.
  • Launching a regional pilot program in New York and New Jersey to allow all levels of government to coordinate chemical facility preparedness planning and response activities.
  • Sharing data to identify facilities that, based on filings, may not yet be in compliance with required regulations.
  • Updating online systems to integrate facility data and to assist facility compliance.
  • Work Continue Reading…
The Rulemaking Process

Have you ever been curious about how a rulemaking is published?  Have you ever wondered how you can participate in the rulemaking process?

We came across a link we want to share from The Office of the Federal Register. When you follow this link https://www.federalregister.gov/learn/tutorials, then scroll down to Tutorials, you will see A Guide to the Rulemaking Process containing answers to the questions below.

Gavel and books

Before the proposed rule

What gives agencies the authority to issue regulations?

How does an agency decide to begin rulemaking?

When can the public learn that an agency plans to start a rulemaking?

How does an agency involve the public in developing a proposed rule?

What is the role of the President in developing a proposed rule?

The proposed rule

What is the purpose of the proposed rule?

How is the proposed rule structured?

What is the time period for the public to submit comments?

Why do agencies re-open comments or issue multiple proposed rules?

Do agencies have additional options for gathering public comments?

Why should you consider submitting electronic comments?

Before the final rule

How do public comments affect the final rule?

What is the role of the President in developing a final rule?

The final rule

How is the final rule structured?

When do final rules go into effect?

Can an agency issue a final rule without publishing a proposed rule?

What are interim final rules and direct final rules?

After the final rule

How are final rules integrated into the CFR?

How is Continue Reading…

Carbon Monoxide Protection with Woodstoves

If you’re like me, falling leaves with shorter days and longer nights only preambles coming months of cold and snow. If you’re like most, you’re concerned about increased energy costs and how you’ll efficiently heat your home this winter. How to conserve energy while keeping warm during the colder months is a major concern for most energy conscious people. And most everyone has their view on which way is best. For wife and I, we have spent much money, time and hard work to weatherize our home with insulating and sealing materials and doors. We are gradually eliminating the energivores in our home with higher efficiency appliances and equipment – like our woodstove. Our most recent investment should benefit us with 70.1% efficiency with a heat output of 68000 BTUs for an area of 800 to 2000 ft2. Since it is Environmental Protection Administration (EPA) approved and certified, I should expect it to produce from 2 to 7 grams of smoke per hour. Compared to our old non EPA certified stove that released, I’m assuming, 15 to 30 grams of smoke per hour, we’ve taken a step in the right direction.

Wood burning stove
Wood burning stove

I’m happy with our decision to keep the electricity bill low and burn wood this winter in our new stove. How we’ll stay warm during those cold nights is one less concern. Though I Continue Reading…

TSCA Reform Proposed

A bill to amend the Toxic Substances Control Act (TSCA) has recently been introduced into the US House of Representatives.  The bill, cited as the “Toxic Chemicals Safety Act of 2010”, is meant to amend the 1976 TSCA legislation that ensures that the public and the environment are protected from risks of chemical exposure. Some of the key goals of the bill include:

  • establishing safety reviews and restrictions on chemicals that people may be exposed to
  • requires the chemical industry to share data with the EPA, which in turn can share data with other regulators, states and workers
  • encourages the development and use of safer chemicals and “green chemistry”
  • discourages the use of animal testing
  • The full text of the bill can be found at: http://energycommerce.house.gov