Archive for the ‘Newsletter Archives’ Category

Shipping Combustible Liquids Internationally Posted on May 22, 2013 by Lion Staff

Shipping hazmat internationally can be a challenge, especially when the U.S. DOT’s hazmat regulations differ from international standards like the IATA Dangerous Goods Regulations or the IMO’s IMDG Code. “Combustible liquids,” for example, are regulated as hazardous in the United States but are considered non-hazardous under international shipping rules. Because of this discrepancy, marking, labeling, [...]

“Form R” Deadline Approaching Fast Posted on May 14, 2013 by Anthony R. Cardno

Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Section 313(c), Toxic Release Inventory (TRI), or “Form R,” reporting is required on or before July 1 for any “designated facility” that manufactures, imports, or processes any of over 600 “toxic chemicals.” The chemicals subject to Form R reporting are found at 40 CFR 372.65, where [...]

GHS Training Deadline Looming Posted on May 07, 2013 by Joel Gregier

Before December 1, 2013, more than 40 million employees at 5 million facilities nationwide must be trained on new hazard communication standards under OSHA’s new Globally Harmonized System of Classifying and Labeling Chemicals (GHS). The December 1 deadline is the first for industrial facilities working to update their hazard communication standards this year. Many companies [...]

Managing Non-compliant Hazmat in Your Supply Chain Posted on April 30, 2013 by James Griffin

If you ship and receive hazardous materials, chances are that eventually you will receive a shipment that does not meet the DOT’s standards for hazmat packages, whether it’s undeclared, mis-declared, or damaged. Hazmat shipping mistakes are especially common in the reverse logistics supply chain, since your customers may not have the training needed to identify [...]

How to Dispose of 2-Part Epoxy Solutions Posted on April 23, 2013 by James Griffin

What Is an Epoxy Solution? Epoxy resins are common in many industries, and disposing of them under RCRA rules can be complicated. Epoxy-based resins are two-part solutions created by combining an epoxy with a hardener or “cureative.” When combined, these materials create a “thermoset plastic” material that is moldable for a short time before setting [...]

Hazmat Registrations Are Due by June 30th Posted on April 16, 2013 by Kathleen Caton

Department of Transportation hazmat registrations for the 2013-2014 year are due by June 30! Any business that will offer even one placarded hazmat shipment this year must register with the DOT. Registrations must be updated annually, and the registration period runs from July 1st to June 30th of the following year. Your registration tells the [...]

Take Advantage of NPDES Permitting Reliefs Posted on April 09, 2013 by Anthony R. Cardno

Industrial facilities at which “stormwater associated with industrial activity” is discharged are generally required by the U.S. EPA to obtain an NPDES permit, follow strict regulations, and keep exacting records. To avoid the permit requirement, EHS professionals can take advantage of an available relief known as the “No Exposure” certification. This conditional exemption can exclude [...]

What to Expect from an OSHA Inspection Posted on April 02, 2013 by Joel Gregier

The Occupational Safety and Health Administration (OSHA) is tasked with protecting employees in the workplace from the many hazards they face. As such, OSHA has the authority to inspect employers’ facilities to ensure that they are correctly following all applicable safety standards [29 CFR 1903]. Should an OSHA inspector find a facility in non-compliance, he [...]

RCRA—Waste Treatment/Minimization Posted on March 26, 2013 by Won Bae

There are many ways to use RCRA reliefs to cut costs at your facility. You can reuse spent materials, turn your waste into someone else’s product; recycle scrap metals, circuit boards, ethanol, cathode ray tubes, used oil, batteries, and other universal wastes; reclaim value from sludges and by-products; neutralize corrosive wastes; install a closed-loop reclamation [...]

DOT Basic Descriptions: Shipping Papers vs. Marks and Labels Posted on March 19, 2013 by Ross Kellogg

A common question raised in Lion’s hazmat workshops lately is how the DOT’s recent change to the order of elements for basic descriptions will affect marking and labeling procedures for packages. Read on for answers to this common question and a refresher on the package marking and labeling requirements. As of January 1st, 2013, the [...]

Immediate Effects of New Air Quality Standards Posted on March 12, 2013 by Scott C. Dunsmore

Question: I saw that the EPA published a final rule revising the ambient air quality standard for particulate matter and that the new standard is effective on March 18, 2013. Will this immediately affect New Source Review applications? Answer: Some aspects of this final rule will have an immediate impact on New Source Review (NSR) [...]

The Challenge of Fall Protection Posted on March 05, 2013 by Joel Gregier

For the past twenty years, fatalities related to falls have consistently ranked in the top four causes of workplace deaths. The Occupational Safety and Health Act requires employers to protect their employees from recognized hazards that may result in death or serious physical harm and to comply with OSHA standards. So which standards might the [...]

Managing Hazardous Waste as Used Oil Posted on February 26, 2013 by Brittany

In general, the EPA does not consider used oils to be hazardous waste. In establishing proper management standards for these wastes, the EPA presumed that recycling, from re-refining to burning as fuel, would occur. The used oil rules at 40 CFR 279 are less burdensome than the hazardous waste regulations (40 CFR 260-270). In some [...]

How to Classify Hazmat That Changes Its Characteristics Posted on February 19, 2013 by Brittany

Question: I have to ship some solid phosphoric acid powder. The Hazardous Material Table says it’s a Class 8—Corrosive hazardous material. I thought that Class 8 was only for corrosive liquids. What’s up with that? Answer: A material is a Class 8 hazmat if it fails the tests given in 49 CFR 173.137. The procedures [...]

Greenhouse Gas Reports Due March 31st! Posted on February 12, 2013 by Brittany

The 2013 submission deadline for 40 CFR 98, more commonly called “the Greenhouse Gas Reporting Rule,” is fast approaching. Unlike 2011 and 2012, in which the reporting deadlines were pushed back to September due to technology issues, this year the EPA requires reports be submitted by the March 31st date codified in the regulations. In [...]

Transitioning to OSHA’s New GHS Rules Posted on February 05, 2013 by Brittany

Q:I am in charge of overseeing my company’s transition to OSHA’s new GHS Hazard Communication Standard. How much of the standard will be changing? A:The overhaul to OSHA’s Hazard Communication System (HCS) has caused anxiety nationwide in many industries since the rulemaking was announced—but while many aspects of hazard communication will change, the major thrust [...]

Understanding Your Generator Status Posted on January 29, 2013 by Brittany

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a generator of hazardous waste. Waste can be produced by industrial processes or through recycling and waste treatment. Wastes can become subject to regulation without actually being produced through the closure of a process or facility or the cleanup [...]

New Requirements for Limited Quantities & Consumer Commodities Posted on January 22, 2013 by Brittany

Question: Settle a bet. My co-worker says a limited quantity hazmat package doesn’t need shipping papers; I say that exception is only for consumer commodities. Who’s right? Answer: You’re both a little bit right, and you’re both a little bit wrong. In the past, only those shipments of hazardous materials packed in limited quantities AND [...]

Prepare Your Tier II Reports Now: March Deadline Posted on January 15, 2013 by Brittany

It’s that time of year again: the March 1 deadline for submitting the Tier I or Tier II Chemical Inventory Report under the Emergency Planning and Community Right-to-Know Act (EPCRA) is fast approaching.  Tier Reporting Requirements You must comply with these reporting requirements if your facility holds a threshold planning quantity (TPQ) of any hazardous [...]

OSHA’s Yearly Summary of Injury and Illness Posted on January 08, 2013 by James Griffin

EHS managers nationwide have just three more weeks to complete and post their organizations’ annual OSHA 300-A Summary Forms. Formally known as the Summary of Work-Related Injuries and Illnesses, this form must be completed no later than February 1 and posted in “…a conspicuous place or places where notices to employees are customarily posted…” (29 [...]