What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

Mar 18, 2024

hazardous cleanup emergency

Being prepared for emergencies at your facility is vital, and having that plan communicated to your employees is even more critical.  OSHA references a couple of different plans in its regulations, one is the Emergency Action Plan and then OSHA’s HAZWOPER standard mentions requirements for an Emergency Response Plan.  So, what’s the difference between these two plans?

HAZWOPER emergency response team

Emergency Action Plans (EAP)

When reading the OSHA standards for Emergency Action Plans, it’s easy to be confused because they can be pretty complicated.

EAP requirements are found in 29 CFR 1910.38(a).  They are part of Exit Routes and Emergency Planning in Subpart E.  A number of OSHA standards require that you have an EAP, including the regulations related to Process Safety Management, Fixed Extinguishing System-General, Fire Detection Systems, Grain Handling, Ethylene Oxide, Methylenedianiline and 1,3-Butadiene.

In 29 CFR 1910.157, Portable Fire Extinguishers, there is mention of needing EAPs as an alternative to teaching your employees how to fight fires.  There are a bunch of if/then conditions, but OSHA really puts it plainly in their online eTools that the only way a company wouldn’t have to have an EAP is if you have an in-house fire brigade where every employee was trained and equipped to fight fires.  So basically, it doesn’t matter which regulations require EAPs, if you don’t have an in-house fire brigade where every employee is trained to fight a fire, you’re going to need an EAP.

So, Then What’s in an EAP?

This standard says that an EAP must be in writing, kept in the workplace, and available to employees for review.

At a minimum, EAPs need to include procedures for:

  • Reporting a fire or other emergency;
  • Emergency evacuation, including type and exit routes;
  • Employees who remain to operate in critical plant operations before they evacuate;
  • Accounting for all employees after evacuation;
  • Employees performing rescue or medical duties; and,
  • Name and job title of every employee who may be contacted by employees who need more information about the plan or their duties under the plan.

Employers with more than 10 employees are required to have an employee alarm system with a distinctive signal.

As an employer, you must train employees in the safe and orderly evacuation of other employees.  You must review the EAP with every employee covered by the plan when they are initially assigned to a job, when that employee’s responsibilities in the plan have changed, or whenever you make any changes to the plan.

If you have 10 or fewer employees you can communicate the plan orally to employees however, it’s a good practice to still have it in writing because when you get your 11th employee unless you’re super organized, it’s unlikely that will trigger a reminder to put your plan in writing.

HAZWOPER Emergency Response Plan

The OSHA HAZWOPER (Hazardous Waste Operations & Emergency Response) standard at 29 CFR 1910.120 goes into detail about Emergency Response Plans.

If you are going to have your employees respond to releases and spills, you are required to have an Emergency Response Plan.  This also applies to employees that are dispatched to an incident such as from a fire station, fire brigade, or emergency medical service. This plan describes what the employees are expected to do in an emergency response.

If your facility intends to evacuate everyone from the danger area when there’s a release and have someone else do the emergency response portion, then you just need an Emergency Action Plan.  Otherwise, if you are having employees respond, you need the Emergency Response Plan.

HAZWOPER emergency response

Emergency Response Plans need to include procedures/instructions for:

  • Pre-emergency planning and coordination with outside parties;
  • Personnel roles, lines of authority, training, and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up; and,
  • PPE and emergency equipment.

Emergency response organizations may use the local emergency response plan or the state emergency response plan or both, as part of their emergency response plan to avoid duplication. The HAZWOPER plan has also been adopted by EPA’s SARA regulations at 40 CFR 311 for state and local government employees in federal-OSHA states and their volunteers.

Other Emergency Response Plans Required

These are just two plans from a whole laundry list of emergency-related plans required by OSHA, EPA, DOT, and several other agencies.  Want to learn more?  Read our blog about all the other emergency plans required here.

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Hazardous Waste Biennial Reports Due March 1

Hazardous Waste Biennial Reports Due March 1

Jan 15, 2024

Every even-numbered year, large quantity hazardous waste generators must submit their Biennial Hazardous Waste Reports by March 1.

The rule is part of EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations. It requires facilities to report the nature, quantities and disposition of hazardous wastes generated every 2 years. Treatment, storage, and disposal facilities (TSDFs) are also required to make a report of the wastes they’ve received from off-site.

Your facility must complete biennial hazardous waste reports if you generate 2,200 lbs. of hazardous waste in any calendar month. You may have additional state requirements and thresholds to consider as well.

Biennial hazardous waste reporting typically applies to large quantity generators, but state regulations may vary for small quantity generators, conditionally exempt small quantity generators and other state-specific categories of generators.

These reports are sent to your authorized state agency or EPA regional office, depending on where your facility is located and your state rules.

Need help in determining if you’re subject to this reporting? Need help filling out the paperwork and submitting it? Let iSi take care of this report for you! Contact us today for more information and pricing.

 

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Inspection Data Shows Common Hazardous Waste Violations

Inspection Data Shows Common Hazardous Waste Violations

Nov 28, 2023

We decided to take a look at some of the EPA enforcement sites to review hazardous waste violations issued across the U.S. within the past couple of years.  We wanted to see if there were some common themes that readers should be on the lookout for because sometimes the best lessons can be learned from the experience of others.  We chose, at random, sites from all across the U.S. and looked at the federal citations (not state citations) noted.  

Here are some of the most common items we found.  How well is your company managing these items?

Container and Labeling Issues 

The top 2 areas that kept coming up, maybe because they could be considered low hanging fruit, were related to container management and labeling.  

Container issues included:

  • Keeping containers closed
  • Keeping containers in the waste storage area past the required time limit per generator status
  • Keeping incompatible wastes separated during accumulation
  • Not enough aisle space between drums
  • Container condition issues such as cuts and dents
  • Not having proper spill and leak prevention and cleanup supplies
  • Not immediately cleaning up spills and leaks

Labeling issues were basically incorrect labels to not having any labels at all.  Improper labeling examples included not marking drums as “Hazardous Waste” or not marking used oil storage containers as “Used Oil.”  This was not limited to just hazardous waste, but also included not marking universal wastes what they were, such as spent bulbs.  There were also several instances of containers not having the accumulation start dates marked on them.

Inspections

One of the next most popular items cited was hazardous waste inspections.  Companies either didn’t do them at all, did not document them, or did not do them adequately.  

Make sure this is something you are doing and documenting.  Make sure your inspectors are just not going through the motions and checking the same boxes.  Are the items considered out of compliance showing up on the checklist each week?  If so, why aren’t they being addressed?  If you find items out of compliance, were they noted on the last inspection and why or why not?

Training

Many companies were cited for not providing training or not providing it annually, where applicable.  Different levels of generators have different training requirements depending on federal regulations and specific state regulations, however, it was one of the areas most cited. 

In one instance, a company was fined for not having job titles and job descriptions for each position in the facility related to hazardous waste management.  This is a requirement for large quantity generators on a federal level (and may be an additional state requirement depending on which state you’re in). We have seen job titles and descriptions asked for in DOT hazmat inspections as well.  This is to help inspectors determine who at the facility needs to have training. Then once they know who needs training they will ask for employee start dates to determine timeframes so they can calculate when initial and refresher trainings should have been conducted.

Waste Determinations

Several companies were fined for not conducting waste determinations.  This is one of the first things you need to be doing so that you know the hazards of the waste you’re storing and how you will need to properly manage it.

Contingency Plans

A number of companies had contingency plan issues.  Some of these included:

  • Not having a contingency plan when required to
  • Not describing what the company’s response would be to fires and explosions in the plan
  • Not including an evacuation plan
  • Not listing emergency equipment capabilities in the plan

Tanks and Air Emissions 

Many tank-related issues were cited, but not only about the tanks themselves, but the air emissions issues related to tanks.  In a previous blog, we wrote about how there are air emissions regulations written into the hazardous waste regulations.  Subparts BB and CC of the RCRA air regulations pertain to tanks.   EPA’s 2021 compliance initiatives included a statement that said a number of facilities were not complying with RCRA air requirements and as a result, inspectors were being directed to look at these items in inspections. Some of the air-related violations included:

  • Failing to comply with emissions control standards for tanks
  • Failing to comply with regulations regarding leaks such as marking equipment subject to Subpart BB air emissions standards
  • Not developing a monitoring plan for valves that are difficult or unsafe to monitor
  • No calibration testing
  • Not passing the required leak test requirements and not having records showing passing scores every 30 days for the past 12 months
  • Not doing required monthly monitoring

Some examples of the tanks-only (not related to air) violations included:

  • Storing hazardous waste in a tank for more than 90 days
  • Not doing daily inspections
  • Not having hazardous waste tank inspection records
  • Not doing periodic testing and monitoring of spill prevention equipment or containment sumps
  • Not having a qualified engineer assess the integrity of an existing tank used to store hazardous waste
  • Not conducting annual line tightness testing for underground storage tanks

Other Items

There were a number of other items cited that appeared less often, but are still worth mentioning.  They include:

  • Storing hazardous waste without a permit or without notifying the local authority that they had hazardous waste onsite
  • Not following the conditions of their hazardous waste permit
  • Not complying with manifest requirements and not completing them correctly
  • Not following hazardous waste transportation regulations or following regulations for proper disposal
  • Not meeting land disposal requirements
  • Not submitting biennial reports

Conclusion

With the majority of the cases, more than one item was cited.  Some of the fines for single violations fell within the $5,000 area while most with multiple citations were $50,000-$100,000.  Some companies were allowed to pay about half in fines and then spend the other half to do supplemental purchases of emergency response equipment for their local fire departments.  That was used in a few instances, especially in the central states.

Does your facility have any of these issues?  Do you need help with a contingency plan? Do you need to get caught up on your worker training?  Do you need someone to come evaluate your entire program to see where your gaps are?  iSi can help with all things hazardous waste.  Contact us today with any questions or for some pricing for us to lend you a hand.

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What the Haz?

What the Haz?

May 19, 2023

A Deeper Dive Into the “Haz” Words in OSHA, EPA and DOT and Where They Can Crossover

Every once in a while, we will get a call from someone looking for “Hazmat” training.   To you, the word hazmat may mean one thing, but we guarantee to someone else it probably means something completely different.

iSi’s mission is to help companies navigate compliance with EPA, OSHA and DOT regulations.  Once you start familiarizing yourself with those regulations, you will find that the definition of hazmat can be different for different agencies and different situations.   You will also see that there are a number of words that include “haz” that can creep into the picture and be used interchangeably.  An even deeper dive will show that each agency will either make up their own definition or borrow from one another.

Each Agency Has Its Own Focus

Regulations and their definitions are typically written in the perspective of the focus of the agency.  Each agency has its own role to play in the workplace and how they use their haz words will often be reflective of that.

  • OSHA – OSHA’s focus is safe and healthful working conditions for workers
  • EPA – EPA’s focus is on human health and the condition of the environment
  • DOT – DOT’s focus is on the safe, efficient, sustainable and equitable movement of people and goods

Once you know the perspective for each, that will help you be able to better understand regulations when they crossover or refer to one another.

Hazmat

Hazmat is a shortened version of “hazardous materials.”  Each agency refers to hazardous materials a little differently.

In OSHA, the term hazmat can refer to hazardous materials or hazmat teams.  OSHA says a hazardous material is something that can be a health hazard or a physical hazard.  However, a hazmat team is an organized group of employees who perform work to handle and control spills or leaks of hazardous substances.  Individually trained members of the hazmat team are called hazardous materials technicians.  Later we’ll look at the OSHA HAZWOPER standard where many of these definitions are found.

To DOT, hazmat means “a substance or material capable of posing an unreasonable risk to health, safety, and property when transported in commerce…”  It also can include hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials listed in the Hazardous Materials Table, and materials meeting their criteria for hazard classes and divisions. The term Hazmat employee in the regulations are those persons who package or prepare, physically transport, load, unload, design or makes packages for, fills out paperwork for or ensures the safe transportation of hazardous materials.

To EPA, a hazardous material is any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

From the definitions, you can see that OSHA was focused on people, DOT was focused on transportation and EPA was focused on the environment.

HazCom

Another shortened haz word is HazCom.  This is short for the OSHA Hazard Communication Standard.  This standard is all about hazardous chemicals, that is, any chemicals that are a physical or health hazard. The HazCom Standard deals with Safety Data Sheets (SDS), labeling, markings, training and more.

EPA’s Emergency Planning and Community Right to Know Act, or EPCRA, regulations refer to OSHA’s hazardous chemicals when it comes to which chemicals apply to the EPCRA regulation.  Those which fall under the HazCom standard and have SDSs associated with them are included in EPCRA reporting requirements.  Some companies also refer to HazCom training by the term Employee Right to Know training.

Hazardous Waste

Another haz is hazardous waste. The term hazardous waste comes from EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.  There’s a lengthy determination process one must go through to even determine if something can be defined to be a hazardous waste.  You’ll see all of those criteria and the roadmap in the definition of hazardous waste at 40 CFR 261.2.

EPA’s website says, “Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and may come in many forms, including liquids, solids gases, and sludges.”

Hazardous waste must be discarded and must be a solid waste.  To be a solid waste, it must be a material that has been abandoned, recycled, is inherently waste-like or is a military munition.

Once you determine that it’s discarded and a solid waste, there are another set of questions to ask to make the determination if a waste is hazardous or not.  This process is quite important and is required to be completed and documented for each of your wastes.

OSHA mentions hazardous waste in their HAZWOPER standard, calling hazardous waste anything that’s found to be a hazardous waste by the EPA definition or anything that DOT calls a hazardous waste in their definition.

In DOT regulations, DOT says hazardous waste is defined under EPA’s definition and that to ship hazardous waste a hazardous waste manifest is required.  Hazardous waste is a hazardous material that is regulated for transportation. So when a vendor comes to pick up your hazardous waste, your company is the one technically shipping it and are therefore subject to all of the DOT hazmat regulations the same as if you were shipping any other hazardous material.

Hazardous Substances

All 3 agencies use the term hazardous substance.

In EPA, a hazardous substance is “Any substance, other than oil, which, when discharged in any quantities into waters of the U.S., presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, shellfish, wildlife, shorelines and beaches (Section 311 of the Clean Water Act); identified by EPA as the pollutants listed under 40 CFR Part 116.”  Hazardous substances are referred to in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, aka Superfund), the Clean Water Act (CWA), the Clean Air Act (CAA), the RCRA hazardous waste regulations, and the Toxic Substances Control Act (TSCA).

OSHA makes it easy.  They say a hazardous substance is whatever EPA CERCLA says it is, whatever DOT says are hazardous materials, whatever EPA says a hazardous waste is, or any other biological or disease-causing agent that could lead to things like death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions or physical deformations in such persons or their offspring.

DOT says a hazardous substance is a hazardous material when that material is listed in their Appendix A and when its single package exceeds the reportable quantity listed in the Appendix. They also have other considerations if it’s a mixture or solution or a radionuclide.

HAZWOPER

And finally, there’s HAZWOPER.  Although it’s one of our more popularly discussed haz words, we left this for the end because this regulation actually uses all of the haz words in one place and seems to be one standard that incorporates so many different requirements from all 3 agencies within it.

HAZWOPER stands for Hazardous Waste Operations and Emergency Response.  HAZWOPER is found in the 1910 General Industry Standards under Subpart H, Hazardous Materials.  An identical copy can be found under a different subpart in the 1926 Construction Standards.

There are 3 main pieces or goals to HAZWOPER:

  1. Rules for conducting cleanup operations at sites determined to be EPA RCRA hazardous waste cleanup sites, cleanup operations at sites contaminated by hazardous substances on uncontrolled hazardous waste sites that EPA or another government agency have required to be cleaned up, or conducting voluntary cleanups at those same types of uncontrolled waste sites;
  2. Operations at treatment, storage and disposal facilities (TSD) regulated by EPA RCRA; and,
  3. Emergency response to releases of hazardous substances at any facility, any location.

Being an OSHA regulation, HAZWOPER is all about protecting the worker and the public during the cleanup, so all the guidance centers around preparing for and safely cleaning up hazardous substances.

The regulation mentions the term Hazmat teams in relation to those responding to the emergency responses found in part 3 of the standard.

HAZWOPER says any materials cleaned up and containerized into drums must meet appropriate regulatory requirements for DOT transportation, RCRA hazardous waste and OSHA safety regulations.  Waste must be transported per DOT regulations while self-contained breathing apparatuses used by workers to protect themselves during work are to comply with DOT standards.

The DOT’s Emergency Response Guidebook is mentioned and often consulted for emergency response information and guidance.

If a company has prepared a contingency plan per EPA requirements and that plan includes emergency response information, the company can use that contingency plan as part of its emergency response plan so that efforts are not duplicated.

On the EPA side, because OSHA regulations don’t apply to local and state governments, EPA has adopted the HAZWOPER standard into 40 CFR 311 to apply to those local and state governments and any of those not covered by a state OSHA-approved plan.

Also in EPA, emergency spills trigger a whole host of reporting requirements as well as emergency response plans and training to protect the environment from hazardous waste spills, oil spills, pipeline leaks and chemical releases to water, air or land.

Conclusion

This is not an exhaustive list of haz references or examples where all 3 agencies cross over, but hopefully it gave you an idea of how these terms and the rules related to them can be so different in some cases, but so intertwined in others.  The haz words used can differ depending on the situation.

So, if you call us asking for hazmat training, you’re likely to get a lot of questions from us about your end goal.

What haz words have you come across?  What examples did we miss?  We’ll be posting this on our Facebook, LinkedIn, Twitter and Instagram pages.  We’d love to hear from you!  

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EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

Dec 1, 2022

EPA has issued Final Rule updates to 40 CFR Part 63, subpart HHHHHH, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.  This NESHAP standard applies to companies coating miscellaneous parts/products made of metal, plastic or a combination, anyone stripping paint using methylene chloride, or conducting motor vehicle/mobile equipment refinishing.

EPA issued the changes as part of its technology review.  They didn’t find any new developments in practices, processes or controls that warranted changing existing rules, but they did decide to take the opportunity to update and clarify some of the items in the current requirements.

Here is a summary of what has changed in the regulation:

Electronic Reporting

Rather than mailing reports to EPA, you will now be required to be submit electronically through the CEDRI/CDX platform.  This includes initial notifications, notifications of compliance status changes, annual notification of changes reports and the report required in 40 CFR 63.11176(b).

HAP Content

EPA updated the definition of a “target HAP containing coating” to clarify that compliance is based on the hazardous air pollutant (HAP) content of the coating applied to the part, not the content purchased.

Spray Gun Cups and Liners

For spray guns with disposable cap liners, EPA amended “spray-applied coating operations” to clarify that the allowance to use spray guns outside of a spray booth is based on the volume of the spray gun cup liner, not volume of the cup itself.  They also clarified that repeatedly refilling and reusing the 3.0 fl. oz. cup or cup liner, and/or using multiple liners for a single spray-applied coating operation will be considered trying to circumvent the regulation and you can be fined for this.

Exemptions Became Easier

If motor vehicle/mobile equipment spray coating operations don’t spray apply coatings that contain the target HAP, rather than the current petition for exemption process, the rule now allows companies to submit notifications to the Administrator.  This process is meant to be simplified and easier.  All records to support the notification shall still be kept as a backup to support the notification, but those records don’t need to be sent to the administrator.

Military Equipment: Tanks and Submarines

The NESHAP no longer applies to surface coating or paint stripping on tanks and submarines when that work is conducted onsite at military installations, NASA, or at the National Nuclear Security Administration.  It also doesn’t apply when conducted offsite where military munitions or equipment are manufactured by or for the Armed Forces and that equipment is directly and exclusively used for the purposes of transporting military munitions.

OSHA Carcinogen References

EPA removed references to OSHA’s carcinogens because OSHA no longer spells out what those are.  Instead, EPA will be putting in their own list.  These will include target HAPs that must be counted if they’re present at 0.1% by mass or greater.  All other HAPs will be counted if present at 1.0% or greater by mass.

No Non-HAP Solvents

The term “Non-HAP solvent” will be removed because there’s no requirement in the standard to use them and there is no other place where this is used.

Filter Test Method

EPA updated the spray booth filter test method to the most recent ASHRAE method, ANSI/ASHRAE Standard 52.2-2017 Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size.  The standard also now includes a reference to EPA Method 319-Determination of Filtration Efficiency for Paint Overspray Arrestors as an alternative method.  EPA Method 319 is the same one referenced in the NESHAP for Aerospace Manufacturing and Rework to test paint spray booth filters for hexavalent chromium emissions.

For more information about changes to the rule, you can find the final rule in its entirety here.

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Chemical Hygiene Plan: What You Need To Know

Chemical Hygiene Plan: What You Need To Know

Nov 25, 2022

What is a chemical hygiene plan?

A Chemical Hygiene Plan (CHP) is a written document required by the Occupational Safety and Health Administration (OSHA). It outlines specific safety procedures that workers must follow while working with hazardous chemicals, in order to minimize risk of exposure to potentially dangerous substances.

The CHP covers topics such as personal protective equipment, engineering controls, safe work practices, health and hygiene, medical surveillance, chemical labeling and storage, spill response plans, hazardous waste disposal and more. It is important to have a comprehensive and up-to-date CHP in place as it ensures that workers are aware of the hazards associated with their job duties and how to protect themselves against them.

What are the objectives of a chemical hygiene plan?

A Chemical Hygiene Plan (CHP) is an organized and comprehensive plan designed to protect laboratory workers from the potential health hazards posed by hazardous chemicals in the work environment. It outlines safety protocols for working with hazardous materials, identifies any special procedures or precautions that need to be taken when dealing with them, and provides guidance on how to safely handle common laboratory operations such as waste disposal and emergency response.

A CHP establishes the safety procedures that must be followed in order to ensure that laboratory personnel are adequately protected from hazardous chemical exposure, while also ensuring compliance with relevant laws and regulations.

The main objectives of a CHP include minimizing employee exposure to hazardous chemicals, reducing the potential for accidental spills or exposures, identifying appropriate personal protective equipment (PPE) for each type of operation, and providing training for personnel on the appropriate use of hazardous materials.

What should a chemical hygiene plan include?

A CHP should include a written policy outlining the responsibilities of personnel, recommendation on protective clothing and equipment, training requirements for workers, methods for labeling and storing chemicals, emergency procedures in case of spills or other incidents, and equipment maintenance protocols.

In addition, the CHP should document any hazardous chemical exposures that have occurred. By following these guidelines, workplaces can ensure that personnel are adequately protected from exposure to hazardous substances and minimize the risk of injury or illness due to chemical use.

What does a chemical hygiene officer do?

A Chemical Hygiene Officer (CHO) is an important role in any organization that works with hazardous chemicals. Their primary responsibility is to ensure the safety of personnel and protect the environment by designing and implementing chemical safety programs, policies, standards, and procedures.

The chemical hygiene officers also oversee compliance with all applicable laws related to health and safety in the workplace. They are responsible for monitoring chemical use, storage, and disposal; performing safety audits; conducting safety training; and providing expert advice on safe chemical handling practices.

In addition to these core duties, the CHO may coordinate with other departments such as Human Resources and Environmental Health & Safety in order to ensure compliance across the organization and present health and safety requirements.

What is the OSHA chemical safety plan?

The OSHA Chemical Safety Plan is a set of steps that employers must take to ensure the safety and health of their workers, as well as the workplace itself, when handling hazardous chemicals. It outlines the preventive measures that employers should implement in order to protect employees from exposure to hazardous materials.

This plan includes training for workers on proper handling and storage of chemicals; personal protective equipment (PPE); emergency response plans; and other safety measures. Proper implementation of the OSHA Chemical Safety Plan can help to reduce incidents and injuries caused by hazardous chemicals, as well as ensure a safe environment for all employees. The plan also serves to keep businesses compliant with federal regulations set forth by the Occupational Safety and Health Administration.

What is the OSHA laboratory standard for chemical exposure?

The Occupational Safety and Health Administration (OSHA) sets a standard for chemical exposure and protective laboratory practices in the workplace. This includes keeping employees safe from any kind of hazardous chemical, whether it be by inhalation, ingestion or skin contact. OSHA enforces this standard through its Hazard Communication Standard, which requires employers to provide workers with information about the chemicals they use, including proper storage, labeling and handling instructions.

The OSHA lab standard also sets limits on the amount of exposure an employee can have to certain chemicals, ensuring that workers remain safe from any potential harm. To make sure these standards are met, employers must provide adequate training and ensure that employees follow safety protocols when working with hazardous materials.

What are the 10 steps to chemical safety?

Chemical safety is an important part of any workplace environment. Knowing and understanding the 10 steps to chemical safety can help ensure that all employees are safe while handling hazardous materials.

  1. The first step to chemical safety is to identify potential hazards by reviewing the Material Safety Data Sheet (MSDS). The MSDS includes detailed information about the properties of a given chemical, including its health hazards, protective measures, and emergency response information.

  2. The second step is to use the right personal protective equipment (PPE) when working with hazardous materials. This may include safety glasses, respirators, gloves, lab coats, and other items that are necessary for safe handling of chemicals.

  3. Thirdly, it’s important to keep all containers of chemicals labeled and sealed properly. Labels should include the name of the chemical, concentration, date prepared, and appropriate hazard warnings.

  4. The fourth step is to practice good housekeeping in the lab or work area by keeping all areas clean and free from debris that might contaminate products. All spilled materials must be removed from the work area as soon as possible.

  5. The fifth step is to make sure that all employees are trained on the proper handling of chemicals in their work area. This includes understanding how to use protective equipment and safety measures to reduce exposure.

  6. The sixth step is to provide good ventilation in the lab or work area. Poor ventilation can increase exposure to hazardous materials, so it’s important to keep areas well-ventilated.

  7. Seventhly, emergency equipment should be readily available in case of an incident. This includes items like fire extinguishers, eye wash stations, and spill kits to contain hazardous materials.

  8. The eighth step is to create a culture of safety by ensuring that all employees are aware of the dangers associated with handling hazardous materials. All workers should understand the proper safety procedures, and regular training should be conducted to reinforce these procedures.

  9. The ninth step is to monitor employee exposure levels by providing personal protective equipment and conducting periodic air quality tests. This will help ensure that all workers remain safe while working with hazardous materials.

  10. Finally, the tenth step is to document all safety measures taken in a detailed hazard assessment report. This report should include a description of the potential hazard, control measures taken to limit exposure, and any additional safety precautions that were implemented.

By following these 10 steps to chemical safety, employers can ensure that their employees remain safe while handling hazardous materials in the workplace.

What are 4 hazardous chemicals?

Chemical safety is an important topic in any work environment, as exposure to hazardous chemicals can have serious effects on a person’s health and wellbeing. To protect workers and customers alike, it is essential that businesses identify the potential risks associated with their products or services, and take steps to minimize them. One way to do this is by identifying the four main classes of hazardous chemicals: corrosives, flammables, oxidizers, and toxic materials.

Corrosives are substances that can cause severe damage to the skin or eyes upon contact. These can include acids, alkalis, and other caustic materials. Flammables are extremely combustible liquids or gases that can ignite easily and burn rapidly under certain conditions. Oxidizers are substances that can cause rapid or spontaneous combustion when they come into contact with flammable materials. Finally, toxic materials are substances that can cause chronic or acute health problems if ingested, inhaled, or absorbed through the skin.

What are the five rules of chemical safety?

Chemical safety is a critical part of all standard operating procedures. It helps ensure the safety and health of personnel, as well as protects equipment and materials from potential hazards. There are five basic rules of chemical safety that must be followed in order to minimize risk and maintain a safe working environment.

  • Read the labels and material safety data sheets (MSDSs) for any chemicals that you plan to use. Be sure to understand the hazards of each chemical as well as the proper disposal or storage requirements.
  • Wear the appropriate protective clothing and equipment when working with dangerous chemicals. This includes gloves, goggles, and an apron or lab coat. Additionally, it is important to ensure that your work area is well-ventilated.
  • Never mix chemicals, even if they are similar. This can lead to unpredictable and potentially hazardous reactions.
  • Store chemicals properly in order to prevent spills or other accidents. Always follow the manufacturers’ instructions regarding recommended storage temperatures and containers.
  • Always clean up any spills immediately and properly dispose of all chemicals after use. This includes cleaning any equipment or surfaces that may have been exposed to hazardous materials.

Adhering to these five basic rules of chemical safety can help ensure a safe working environment for everyone in your laboratory.

What is a common hazardous chemical in healthcare?

Healthcare workers are exposed to all kinds of hazardous substances. These can range from pesticides used in the garden, to chemical cleaners used in bathrooms and kitchens, to toxic drugs and medicines. One of the most common hazardous chemicals found in healthcare is formaldehyde.

Formaldehyde is a colorless, odorless gas that has many industrial uses such as preserving specimens for research laboratories and embalming. It can also be found in some furniture, carpets, cleaning supplies and even cosmetics.

In healthcare settings, formaldehyde is often used as a disinfectant to prevent the spread of infections. Exposure to high levels of formaldehyde can cause respiratory irritation, headaches and nausea. Healthcare workers must take extra precautions to protect themselves from exposure by wearing personal protective equipment such as respirators, eye protection and gloves.

Additionally, employers should use ventilation systems to reduce exposure levels in the workplace. By following these simple steps, healthcare workers can help protect themselves from dangerous chemical hazards and potentially hazardous chemicals.

Another hazardous chemical that is often found in healthcare is ethylene oxide. Ethylene oxide is a colorless gas with a sweet odor and bitter taste. It is used in healthcare as a sterilizing agent for medical equipment and supplies.

However, exposure to high levels of ethylene oxide can cause skin irritation, headaches and dizziness. Healthcare workers must take precautions to protect themselves from any potential health risks associated with this chemical by wearing protective clothing such as respirators, masks and gloves when handling ethylene oxide. Proper chemical hygiene training and a chemical hygiene plan are crucial for employee safety.

What are 5 top laboratory hazards?

Laboratories are places for experimentation and research, but they can also be dangerous. Understanding the potential hazards that exist in a laboratory is essential to ensure safety. The five top laboratory hazards include chemical exposure, fire, radiation, biological agents, and electrical shock.

Chemical exposure is a significant hazard in any laboratory situation due to the use of hazardous materials such as acids, solvents, and other hazardous compounds. It is important to wear the appropriate protective gear such as safety glasses, gloves, and an apron when working with chemicals to reduce potential exposure.

Fire can cause serious damage in any laboratory setting due to the presence of volatile materials. Laboratories should be equipped with fire extinguishers and personnel should be trained on how to use them. In addition, flammable materials should be stored in proper containers and away from direct sources of heat.

Radiation is a potential hazard in laboratories that use radioactive materials or radiation-generating devices such as X-ray machines. It is important for personnel using these devices to wear protective gear such as lead aprons and glasses, and follow safety protocols.

Biological agents can also be a hazard in certain laboratory settings. It is important to wear protective clothing when working with biological materials and to practice proper hygiene such as washing hands regularly and avoiding contact with eyes, nose, or mouth. Additionally, it’s important to dispose of infectious waste properly and use safe disposal methods for sharp objects such as needles.

What are the 10 lab safety rules?

It is important to understand the 10 lab safety rules in order to ensure a safe and productive laboratory environment. The 10 lab safety rules are:

  1. Wear proper protective gear – including clothing, eye protection, and gloves – whenever handling chemicals or working with equipment that generates heat, sparks, and open flames.
  2. Read labels carefully before using any chemical or equipment.
  3. Follow the instructions provided and adhere to safety protocols in the lab and laboratory safety manual.
  4. Keep chemicals away from sources of heat, ignition, and open flames.
  5. Know how to properly handle and dispose of hazardous materials according to safety protocol.
  6. Know the location of emergency exits, fire extinguishers, spill kits, eyewash stations, and first aid kits.
  7. Never work alone in the lab; always ensure that someone else is present in case of an emergency.
  8. Do not touch or taste any chemicals without permission from a qualified supervisor.
  9. Report any accidents or spills to your supervisor immediately.
  10. Clean up all equipment and materials after use and before leaving the laboratory with prior approval.

Adhering to these 10 lab safety rules is essential for ensuring a safe and productive workplace in any laboratory setting. Always be aware of the potential hazards and use caution when handling hazardous materials or working with dangerous equipment.

How often should a workplace or laboratory chemical inventory conducted?

It is important to conduct a workplace or laboratory chemical inventory at least once a year. This helps to ensure that all chemicals stored onsite are accounted for, and any expired or unwanted materials can be safely disposed of. Additionally, employers should update the list as soon as a new container of hazardous material is received.

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Hazmat Employee Training Requirements Every Employer Must Know

Hazmat Employee Training Requirements Every Employer Must Know

Oct 22, 2022

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What does HAZMAT stand for?

Hazmat stands for HAZardous MATerials, and is a term commonly used to refer to materials that could be dangerous to people, the environment or property. These types of materials may include explosives, flammable liquids, radioactive substances and infectious agents.

It is important for individuals who handle, dispose, and transport hazardous materials to have the proper training and certifications in order to ensure the safety of themselves, others and the environment. Hazmat personnel must also be aware of any applicable laws regarding the transportation and handling of haz materials in order to stay compliant with regulations.

The term is used across multiple industries, including healthcare, construction, manufacturing and mining. The HAZMAT designation can help save lives and reduce potential damage from hazardous materials.

What defines a hazmat employee?

A hazmat employee is any person who is responsible for the transport, storage, and handling of hazardous materials in accordance with all applicable laws and regulations. Hazmat employees must be trained to recognize and respond to hazards posed by hazardous materials they may encounter on the job.

They must also possess knowledge about safe practices related to identification, packaging, labeling, documentation, shipping papers, and emergency response. In order to ensure safety, hazmat employees must pass tests regarding hazardous materials regulations and complete refresher courses on a regular basis.

Furthermore, they are expected to follow all applicable laws and regulations to the letter in order to protect public health and the environment. By having an accurate understanding of what it takes to be a responsible hazmat employee, businesses can ensure that their operations remain safe and in compliance.

Hazmat Training Requirements:

Hazmat training is an important part of safety and awareness for anyone who works with potentially hazardous materials or substances. The US Department of Transportation (DOT) requires that all hazmat personnel receive specialized hazardous materials transportation safety training before they are allowed to handle such materials, as well as periodic retraining every three years.

This includes general awareness/familiarization training, transporting hazardous material training, in depth security training, safety training, function-specific training, security training and in-depth safety training. All employees with hazardous materials responsibilities must have the necessary knowledge and skills to safely handle these materials and be knowledgeable about the applicable regulations.

Hazardous Materials Handler certification is also required for any personnel involved in packaging, labeling, marking or loading of hazardous material shipments.

What are the required categories of hazmat employee training?

The four required categories of hazardous materials employee training include: General Awareness/Familiarization, Function-Specific Training, Safety Training and Security Awareness. All employees who handle hazmat must understand basic safety rules and procedures related to the hazardous materials they handle, as well as emergency response protocols that could arise should an incident occur.

Additionally, personnel involved in loading and unloading operations must understand applicable regulations to ensure safe, secure and compliant operations. Function-specific training is also mandatory for employees who perform activities related to the identification, packaging, labeling, marking, handling, storage and transportation of hazardous materials.

How often do hazmat employees need to be trained?

Hazmat employees are required to complete initial training within 90 days of hire and annually thereafter. Initial training must include topics such as hazard recognition, basic containment principles, emergency response, proper handling and storage of haz materials, and personal protection equipment.

Hazmat employees should also receive additional training whenever there is a change in job duties or when they are exposed to new hazards.

Hazmat Employee Training (49 CFR 172.704)

Hazmat employee training (49 CFR 172.704) is an important part of the hazardous materials transportation regulations mandated by the U.S. Department of Transportation.

Hazmat training must be completed by all employees involved in transporting dangerous goods and hazardous materials, including those who prepare shipments, load/unload, package, mark/label containers or placards, provide emergency response information, and perform any related duties.

Training must include instruction in the applicable regulations, safety precautions, emergency response procedures, how to recognize and respond to haz materials incidents, and other related topics as necessary. Hazardous materials employee training must be provided before initial job assignment and at least once every three years thereafter.

Employers are responsible for ensuring that hazmat employees remain qualified and are knowledgeable about the haz materials they handle. Hazmat employee training is an important factor in ensuring the safe transportation of hazardous materials and preventing accidents related to their transportation.

Is proof of training required?

When it comes to the question of whether proof of training is required for Hazmat Employees, the answer depends on the severity and potential hazards associated with the job. Generally, employers must provide proof that their employees are knowledgeable about hazardous materials regulations and understand how to safely handle haz materials before they can be allowed access to any facilities where hazardous materials may be stored or used.

This proof can take the form of certificate programs, refresher courses, or a written test. Additionally, employers may need to show that their employees have participated in emergency response drills and are knowledgeable about proper procedures for responding to spills and other haz materials incidents. In some cases, additional safety protocols such as wearing personal protective equipment and maintaining adequate ventilation may also be required.

Security Awareness Training (49 CFR 172.704(a)(4))

Security Awareness Training is an important part of any organization’s security plan. As mandated by the Transportation Security Administration (TSA), 49 CFR 172.704(a)(4) requires all personnel who work in regulated environments to complete appropriate training prior to performing their duties.

This training helps ensure that employees are aware of their roles and responsibilities when it comes to safeguarding sensitive information. Additionally, security awareness training helps to ensure that personnel are familiar with the threats and vulnerabilities associated with their role, as well as how to appropriately respond in the event of a breach or other security incident.

This type of safety training is an essential element of any organization’s overall security strategy and should not be overlooked.

The Importance of Hazardous Materials Training

Hazardous materials training is incredibly important for workers who are exposed to hazardous substances. It helps to ensure that they have the right knowledge and understanding of safe and proper methods of handling, transporting, storing, and disposing of such potentially dangerous materials.

Hazardous material trainings can also help prevent accidents or other incidents involving haz materials from occurring by equipping workers with the skills to identify hazardous materials, assess the risks associated with them, and take appropriate steps to mitigate those risks.

Ultimately, hazardous material training is essential for protecting workers and the environment by providing a good understanding of the potential dangers that could be encountered while working with these substances.

It is also important for employers to provide regular hazmaterials trainings in order to stay up-to-date with the latest regulations and safety protocols concerning hazardous materials. By doing so, employers can ensure that their workers are properly informed about how to handle these materials correctly and safely.

Need Help?

Do you need an idea of where you stand with EPA or OSHA regulations?  Do you need full-time or temporary personnel to manage the day-to-day compliance tasks?  Would your employees benefit from onsite environmental training? 

Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!

 

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Waste Disposal Facility Audit Checklist

Waste Disposal Facility Audit Checklist

Sep 10, 2022

What is a waste audit?

There are two types of audits: manual and automated.

A waste audit can be conducted in a variety of ways, depending on the organization and its goals. Generally, there are two types of audits: manual and automated. Manual waste audits involve sorting through garbage bags or dumpsters to determine what is being thrown away. Automated audits use sensors or other technology to track the types and quantities of waste that an organization produces.

The resulting data from waste audits can be used to develop a better understanding of the organization’s waste stream and how it can be improved. The data can also help organizations make informed decisions about their purchasing practices, lead to more efficient processes and identify cost-saving opportunities.

How do you plan a waste audit in an organization?

A waste audit is an analysis of a company’s waste stream where you inspect waste management and then implement waste management protocols. It gives insight into the types and amounts of materials that are being sent to landfill and helps inform strategies to reduce, reuse, and recycle more effectively.

What are the steps involved in a waste audit?

To plan a successful waste audit in an organization, there are several steps that should be added to your waste audit checklist:

1. Select your team and plan a date for the waste audit.
2. Gather your equipment.
3. Go through the garbage!
4. Calculate your diversion rate.
5. Communicate your results.

What is included in a waste audit?

Waste audits are useful for many reasons. They can provide facility managers and other stakeholders with important insights into the effectiveness of their current waste management practices and how they might be improved.

Waste audits can also help identify areas where more resources should be devoted to better manage waste, or where additional training or education is needed. By understanding the composition and volume of the waste generated, organizations can better understand how to reduce, reuse and recycle more efficiently and effectively.

Additionally, detailed audits can provide information about potential safety and health hazards within a facility’s regular waste stream.

What are the 7 principles of solid waste management?

The following are the seven principles that will effectively explain solid waste management:

  • Rethink
  • Refuse
  • Reduce
  • Reuse & recycle
  • Repurpose
  • Repair
  • Compost
  • Conclusion

Solid Waste Management is an important tool to reducing our environmental impact. By adding the 7 principles to the solid waste management checklist, we can begin to make a positive difference in the amount of waste generated and disposed of into the environment.

Rethinking how we purchase and use products, refusing those items that are not necessary, reducing the total amount of waste going into the environment, reusing and recycling items that can be either repurposed or repaired, and composting rather than throwing organic waste away are all effective methods of reducing our environmental impact without creating more waste.

By making small changes in our everyday lives, we can have a large impact on the amount of waste going into the environment. The way households and company disposes of waste will significantly aid in the improvement of the communities we live in as well as limit unnecessary waste in landfills.

What are the four criteria that the EPA uses to classify hazardous waste?

EPA’s (Environmental Protection Agency) regulations in the Code of Federal Regulations (40 CFR) identify four hazardous waste characteristic properties: ignitability, corrosivity, reactivity, or toxicity (see 40 CFR 261.21- 261.24).

As part of EPA compliance, company key members, facilities teams, and site management should identify, collect, and document all hazardous waste that is in their facility. Regular site visits and inspections helps determine is the hazardous waste management protocols are properly enforced and in good condition.

Steps following an waste disposal facility audit:

1. Determine whether the waste containers size and pickup frequency still match your needs. If your trash output changed, a different size or number of pickups could cost you less money.
2. Add recycling service to your plan. If you don’t have recycling bins as part of your waste removal plan, consider add it.
3. Set a goal for increasing your recycled waste rate.
4. Create recycling guidelines for meeting that goal and share them with your staff.
5. Set a goal for reducing the amount of waste in your largest categories.
6. Determine the steps to meet that goal and let your staff know. Implementation is key.
7. Identify any items you can reuse. For example, can you repair or recycle your electronics instead of purchasing new ones? Can you repurpose any of your packaging materials?
8. Decide on a timeline for meeting your recycling and reduction goals. One or two years usually makes sense. Plan to conduct another waste audit at that time to see if you met your goals.

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iSi Environmental – Vacuum Truck Services

iSi Environmental – Vacuum Truck Services

Jul 20, 2022

Vacuum Truck Pick-up and Disposal Services for Liquids, High Solids, Oily Water and Sludge

Vacuum truck services are the perfect solution for picking up and disposing of liquids, high solids, oily water and sludge. Our team of professionals will pick-up and dispose of your waste from virtually anywhere including oil/water separators, clarifiers, sumps, trenches, pits, floor drains and even underground waste tanks.

Hydro excavation for your vacuuming needs

Hydro excavation is a safe and efficient way to excavate around utilities and other underground infrastructure. Our hydro excavation services can help you avoid the costly damage that can be caused by traditional excavation methods.

 

The versatile vac truck for all your waste removal needs

The versatile vac truck can be used for a variety of applications, and in many facilities, including oil/water separator cleaning, tank cleaning, pit cleaning and much more.

Contact us today to learn more about our vacuum truck services and how we can help your company with your waste removal needs.

What are vac truck services?

Vacuum truck services are a type of waste removal service that uses vacuum trucks to pick up and dispose of liquids, sludge and solids. Vacuum trucks are versatile and can be used for a variety of applications including oil/water separator cleaning, tank cleaning, pit cleaning and much more. Vac services are often paired with remediation and environmental services, are part of the formula to help facilities stay compliant with federal regulations and make certain hazardous and non hazardous waste is disposed of correctly.

How can vacuum truck services help you?

iSi Environmental’s industrial services division, named iSi Industrial Services, can help you by picking up and disposing of liquids, sludge, and solids from your property. Our team of professionals are experienced in the proper disposal of waste and can help you avoid costly damage to your property.

The different types of vacuum services include:

  • Oil/water separators cleaning
  • Tank cleaning
  • Pit/Trenches cleaning
  • Sewage disposal
  • Grease trap cleaning
  • Pumping of slurries and sludges
  • Pump clean water
  • Pumping and liquid transfer within facility
  • Hazardous materials transport
  • Dispose of non hazardous materials
  • Tank transfer services

Why choose iSi Industrial Services?

  • We offer efficient solutions to safely remove waste from your site.
  • Our team of professionals are experienced and knowledgeable in the proper disposal of waste.
  • 30 years of experience with local, state, and federal regulations.
  • Committed to any emergency request
  • iSi Industrial Services can work with your current disposal facilities locations or provide additional disposal options.
  • We have the latest vacuuming technology to get the job done right. The right equipment to tackle any job (hazardous or non hazardous).
  • We offer competitive pricing, a flexible schedule, from a convenient location near you. We serve the state(s) of Kansas, Oklahoma, Missouri, and Nebraska.
  • Quick response time and ease of onboarding for your company
  • DOT certified operators
  • Fleet of well maintained transport equipment

Message us today to learn more about our vacuum truck services, request service and schedule your job today!

 

About iSi

iSi Industrial Services and iSi Environmental have teamed to provide environmental remediation, industrial cleaning and EHS consulting services for over 30 years. Our staff of 20+ in house consultants, combined with teams of experienced remediation crews, gives us the capability to handle unique issues that arise at any facility. Headquartered in Wichita, Kansas, our 140 employees services offices in Kansas City, Tulsa, and Atlanta. Contact us now via phone (888-264-7050) or through the website and we will put your project on the schedule.

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iSi Environmental – Hazardous Waste Disposal

iSi Environmental – Hazardous Waste Disposal

Jul 1, 2022

Hazardous waste management is essential for your operations. Our responsive hazardous waste management services provide safe, compliant, and sustainable solutions for the collection, disposal, treatment, recycling, and transportation of hazardous waste materials. With three decades of experience in the industry and a national network of facilities and transportation infrastructure, our team is equipped to meet all your hazardous waste management needs.

Choose iSi Environmental for Hassle-Free Hazardous Waste Disposal!

You and your company want to be environmentally responsible, but you struggle to find reliable companies for your hazardous waste disposal. With global supply chain and transportation disruptions, all businesses are looking for responsive and reliable services, at a fair price. Today, more than ever, getting a competitive price from a waste disposal company requires sacrificing predictable transportation. It doesn’t have to be this way, and, frankly, your facility management expects more from their waste disposal company. Businesses cannot afford to have containers sitting on the loading dock, disrupting production, and causing service delays to your end customers.

iSi Environmental is a leading provider of hazardous waste industry services. Our team has over three decades of experience working with facility hazardous waste, and we are committed to providing safe, compliant, and sustainable solutions for your needs. Whether you need to dispose of electronic waste or industrial products, we have the hazardous waste experts and resources to help you achieve your goals. With our professional services, you can rest assured that your hazardous waste transportation will be handled in a responsible and compliant manner. Contact us today to learn more about our services and how we can help you!

The iSi Environmental Advantage:

– Trusted leader in hazardous waste services with over 30 years of experience

– Offers many benefits, including peace of mind knowing that your waste disposal will be managed responsibly and in compliance with all regulatory requirements

– Team of hazardous waste experts committed to finding safe, compliant, and sustainable options for the widest range of waste streams

– Nationwide network of facilities and transportation infrastructure

– Flexibility to meet all your hazardous and non hazardous waste disposal needs

– Focus on process safety, compliance, and sustainability

– Extensive experience and expertise in hazardous waste management services

– Dedicated to helping our customers achieve their hazardous waste disposal goals

– Commitment to excellence ensures that all our services meet the highest standards

– Effective and reliable hazardous waste removal solutions that are safe, compliant, and sustainable.

What is hazardous waste and why do I need to manage it?

Hazardous waste is any waste that poses a potential threat to human health or nature. It can be any type of waste, from industrial and commercial waste to household products. Managing hazardous waste presents unique challenges and is essential for protecting people and our earth from the potential hazards posed by these materials.

What are the different types of hazardous waste?

There are many different types of hazardous waste, including industrial waste, medical waste, electronic waste, universal waste products, radioactive waste, waste sludge, non hazardous waste, and household hazardous waste. Each type of waste has its own unique set of hazards that need to be managed appropriately.

How can I safely dispose of my hazardous waste?

Disposing of hazardous waste can be difficult and confusing. There are many different methods for disposing of hazardous waste, and each disposal method has its own set of risks and benefits. Hazardous waste disposal can be accomplished through a variety of methods, including treatment, landfills, recycling, and incineration. The best removal option for hazardous waste will depend on the type of waste and the specific regulations in your area. Working with professional hazardous waste disposal services can help ensure the removal of waste is handled safely and legally.

What are the benefits of using a professional hazardous waste management service?

Professional hazardous waste disposal services offer a number of benefits, including expert knowledge and guidance, cost-effective solutions, reliable transportation and storage options, and compliance with all local regulations. Whether you need removal of liquid or solid hazardous waste, non hazardous waste, or household products, working with a reputable hazardous waste experts can help ensure that your waste is handled safely and responsibly.

The Hazards of Hazardous Waste

Hazardous wastes pose many risks to human health and the planet, including contamination of soil and water, damage to ecosystems, and exposure to toxic chemicals that can cause serious health problems. Disposing of hazardous waste safely is essential for protecting people and the environment from these hazards.

Why You Can’t Afford to Ignore Hazardous Waste Management

Hazardous waste administration is a critical part of any business or organization, yet many people choose to ignore this important issue. Whether you are dealing with industrial waste, non hazardous waste, or household products, failing to manage your waste disposal responsibly can lead to serious consequences, including hefty fines, damage to your reputation, and even jail time. Ignoring hazardous waste is simply not an option if you want to protect your business or organization.

How iSi Environmental Can Help You with Your Hazardous Waste Disposal Needs

iSi Environmental is a leading provider of hazardous waste disposal services. We offer a wide range of management solutions for the collection, transportation, and disposal of hazardous waste materials. With more than three decades of experience in the industry, our team is equipped to handle any hazardous waste disposal challenge. iSi’s hazardous waste disposal experts can create a safe, cost-effective, and legal treatment approach for the disposal of your hazardous materials and byproducts regardless on their size or content. We offer responsive customer service, competitive pricing, and a commitment to compliance with all local, state, and federal regulatory guidelines. Contact us today to learn more about our hazardous waste disposal services process and how we can help you keep your organization safe and compliant. Responsive and attentive service is only one call away.

Disposal Services:

  • Radioactive Waste
  • Industrial Waste
  • Lab Packs
  • Sludge
  • Chemical Waste
  • Medical Waste
  • Toxic Waste
  • Paint Waste
  • Non Hazardous Waste Disposal
  • Hazardous Waste Removal
  • Containers and Supplies
  • Facility Management

Disposal Facility Options:

  • Recycling
  • Landfill
  • Underground Storage
  • Incineration
  • Fuel Blending Facilities

 

Questions to ask your hazardous waste disposal companies:

 

Will the onboarding and implementation process be time consuming?

iSi Environmental’s waste disposal services offers a seamless onboarding experience. Responsive client service has allowed our firm to experience continuous growth over the last three decades.

Do your disposal facilities handle radioactive waste?

With a wide variety of disposal solutions, iSi will work to find appropriate disposal options for your radioactive waste.

Do you offer on-site logistics management services?

Our Facility Support Services can help you to streamline facility operations and allow your team to better focus on supplying products to the end customers. With experience in transportation, logistics, warehousing, and onsite waste and recycling activities, we have unique experience to benefit your operations.

Do you offer a wide array of disposal facilities and treatment technologies for my waste? (landfill, incineration, recycling, or reuse facility disposal options)

We offer a wide range of disposal facilities and treatment options, including landfill, incineration, recycling, or reuse facility disposal options.

Are you familiar with my industry specific, local, state, and federal regulations?

iSi has performed waste consulting in 30+ states across the United States. Having worked in production facilities prior to consulting, our staff has wide ranging industry knowledge. As a backup, we use a software that highlights industry specific regulatory requirements by state and municipality.

Can you provide examples of similar disposal projects?

On request, we can provide examples of similar disposal or recycling projects.

What types of containers can you provide to us?

We offer a wide variety of containers, including drums, totes, bags, and boxes. We also have a wide range of capacities available, from small to large. Please feel free to contact us at 888-264-7050 and we would be more than happy to help you select the right container for your needs.

Can you provide a origin/destination workflow for my paint waste, toxic waste, sludge, chemical waste, or medical waste?

Yes, we can provide an origin/destination workflow for your paint waste, toxic waste, sludge, chemical waste, or medical waste. Please feel free to contact us at 888-264-7050 and we can discuss your specific workflow needs.

Do you offer hazardous waste removal or remediation services?

Outside of disposal services, we have a separate division within iSi that can assist with the removal of hazardous waste and perform remediation service at your facility

How quickly can you deliver lab packs to my facility?

Depending on facility location, iSi can usually deliver lab packs as soon as 24 hours. Please feel free to contact us and we would be more than happy to confirm availability and delivery time for your specific needs.

Do you offer containment materials and PPE for purchase?

Our convenient software platform provides all the containment materials and PPE a facility could need. We participate in a consortium of buyers that allows our clients to receive a competitive price on all available items.

Would you be able to share business references from companies similar to mine?

We would be happy to share business references from companies similar to yours. Reach out to us at 888-264-7050 and we will provide you with any information you need.

Do you offer bulk on-site liquid storage containers?

Yes, we offer a variety of bulk on-site liquid storage containers. Our service partners carry a variety of container types and sizes. We would be happy to discuss options with you.

Can you assist in a zero waste to landfill program?

iSi is available to assist your management team in pursuit of sustainability and your ‘zero waste to landfill’ strategy. Our years of experience inside industrial settings can aide in the removal of defaulting to landfill for your hazardous waste disposal needs and shift the focus to recycling and reuse.

Where can I dispose of paint in Wichita KS?

Chemical waste is not acceptable. Instead bring it to the local household waste disposal facility, located at 801 Stillwell, Wichita, KS 67213. The cost is zero.

Are there Kansas hazardous waste disposal options?

Services are available statewide and across the region. Specific cities served in this region include:

  • Wichita, Kansas
  • El Dorado, Kansas
  • Kansas City Metro Area
  • Omaha, Nebraska
  • Oklahoma City, Oklahoma
  • Tulsa, Oklahoma

What is considered hazmat waste?

Hazardous waste are materials that may be harmful to human health and environmental conditions. Hazardous waste can be solid, liquid. They are a collection of discarded materials, such as cleaning fluids or chemicals, as well as byproducts from manufacturing processes.

What is a Subtitle C landfill?

Subtitle C landfills include Hazardous Waste Landfills. These are specialty sites that accepts hazardous waste for disposal. This waste disposal system has no use as a waste dump.

How do I dispose of old CNC coolant?

If a fluid waste is not considered nonhazardous, the material may be disposed at the treatment plant or if the sewer is allowed into the water supply, discharged into the municipal sewer system for non hazardous waste disposal.

How do you get rid of chemical waste?

Chemical waste is regulated under the Resources Conservation and Recovery Act of the United States (RCRA). The materials are not acceptable for disposal at sewage treatment stations or in the normal garbage collection. Almost all chemical waste is disposed of as EHS hazardous waste.

How do companies get rid of chemicals?

Since industrial biproducts may cause harm to humans and the planet, environmental protection agencies are imposing restrictions on industrial chemicals. The most common disposal procedures are burning waste incinerated land or infiltration of underground water.

How do you get rid of a biohazard?

All biohazard liquids are preferably autoclavable before disposal.

How do companies get rid of toxic waste?

The Environmental Protection Agency has restricted the disposal of industrial chemicals. Incineration is a common treatment process and land and underground injection holes are also available to remove waste.

What certifications do your drivers have?

Our drivers are certified in hazmat transportation. Please feel free to contact us at 888-264-7050 and we would be more than happy to help you with your specific needs.

Need Assistance?

Let iSi’s EHS team help you improve your company’s hazardous waste compliance.  How can we help?  Contact us!

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Laboratory Safety Checklist

Laboratory Safety Checklist

Jun 9, 2022

What You Need To Know:

What is a safety audit checklist?

A safety audit checklist is a document used by companies to ensure their workspaces are compliant with industry health and safety standards.

The purpose of a safety audit checklist is twofold: first, to ensure that all areas of potential danger have been identified and addressed; and second, to provide a record of due diligence in the event of an accident or injury.

Many companies use safety audit checklists as part of their regular safety program, while others only implement them in response to an incident.

What should be included in a lab safety checklist?

Lab safety is of utmost importance in any laboratory setting. A lab safety checklist helps to identify and minimize chemical, biological, physical and radioactive hazards present in a laboratory facility.

It helps ensure that the laboratory complies with environmental standards to prevent overexposure to hazardous chemicals, injuries and respiratory-related illnesses or fatalities.

What are the 5 major areas of lab safety?

Cuts:

Laboratory accidents are one of the most common types of workplace accidents. In severe cases, nerves and tendons may be severed.

Often, these injuries occur as a result of attempting to force a cork or rubber stopper into a piece of glass tubing, thermometer or distilling flask thus the result can be broken glass.

To prevent this accident from occurring, workers should make a proper-sized hole, lubricate the cork or stopper, and use gentle pressure with rotation on the glass portion along with any removal of broken glass after an incident.

Toxic fumes:

Chemical fumes can be extremely dangerous, and it is important to take the necessary precautions when working with them especially while working inside. Fumes can cause serious health problems if they are inhaled, so it is important to make sure there is proper ventilation in the lab and to maintain a safe distance when pouring chemicals. Fumes can also be an environmental health issue.

Skin Absorption of Chemicals:

It is important to be aware of the physical injuries that can occur in the laboratory. Chemicals can cause burns, and even if they are not corrosive, exposure can cause allergic reactions or other problems if absorbed by the skin. This can cause acute or immediate effect on the person.

Remember that gloves may be permeable to certain chemical reagents – even without visible deterioration – so trade out any gloves that have come into contact with such chemicals for a new pair immediately. Never touch your face or eyes until your hands are clean of all chemicals or solvents.

Explosions and fires:

In a lab, it is important to be aware of the dangers of flammable liquids. Vapors can travel long distances and may ignite if they reach a flame or spark. Be sure to keep a fire extinguisher on hand and ensure each individual in the laboratory knows its exact location to prevent fires from spreading.

The appropriate personal protective equipment (PPE), like a flame-resistant (FR) lab coat, should also be worn.

Chemical or thermal burns:

Chemicals are an important part of laboratory work. They can be used to create reactions or to purify substances. However, they also can be dangerous if not handled correctly. Burns, chemical spills, and unsafe laboratory conditions are all potential hazards and you should immediately report any incident with you chemical or thermal burns.

It is therefore important to exercise caution when working with chemicals and to always wear the appropriate personal protective equipment (PPE).

What are the major overlooked lab safety issues and hazards?

Ergonomic safety:

Musculoskeletal disorders or MSDs are a serious problem in the workplace, and they can be caused by many different things.

One of the most common causes is repetitive awkward postures, which can occur when employees are not properly trained on ergonomics safety. This type of injury can lead to discomfort and loss of productivity, and it is important for employers to take steps to prevent them.

Laboratory waste disposal:

One of the most important aspects of ensuring a safe and healthy work environment is properly managing hazardous waste. Improper disposal of these materials can have serious consequences for both employees and the environment.

Pathogenic diseases and chemical reactions are just two examples of the many dangers posed by hazardous waste if it is not handled correctly. By implementing a comprehensive waste management program, employers can mitigate many of these risks.

Dress code safety:

Proper dress codes can be overlooked when trying to protect students and protect employees. In order to maintain a safe laboratory environment, adding the dress code to the daily lab checklist is a must.

Employees must ensure all safety equipment including goggles, face shields, safety gloves, body, and respiratory protection are in good condition before entering the laboratory.

Proper labels:

Labels are an important part of, not only general safety but also laboratory safety. Putting a proper label on gas cylinders or any substance that is harmful will ensure compliance and meet laboratory standards which will eliminate lab risks.

Record of an incident:

Another overlooked issue that should be on the lab maintenance checklist is proper record-keeping. You should be keeping records of the following: Damaged equipment, equipment malfunction, toxic contamination, radioactive materials leaked, chemical exposures, chemical spills, laboratory cleanliness, maintenance of labs, and any other issues along with the person responsible.

Conclusion:

Laboratory safety, chemical safety, biological safety, radiation safety, and general safety begin with a proper checklist. Starting with regular self inspections can help tremendously but don’t shy away from outside help if you feel you need it. Safety officers and safety consultants can help you with basic requirements for you laboratories, maintain laboratory health, help you achieve a good inspection checklist, cultivate emergency procedures, and ultimately prevent laboratory risks to help you avoid unwanted legal action again your company. Following tips safety consultants provide is paramount. Maintaining a lab, keep it in peak condition, and keeping employees safe is always the utmost priority.

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Do you need an idea of where you stand with EPA or OSHA regulations?  Do you need full-time or temporary personnel to manage the day-to-day compliance tasks?  Would your employees benefit from onsite environmental training?  Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!

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RCRA Air: What Air Regulations are in the Hazardous Waste Standards?

RCRA Air: What Air Regulations are in the Hazardous Waste Standards?

Sep 23, 2021

In our blog article about EPA’s compliance initiatives, EPA said a number of facilities were not complying with RCRA air requirements and as a result, inspectors were being directed to look at these items in inspections.  So, what are the RCRA air requirements, and who is affected by them?

RCRA air regulations pertain to organic air emissions from equipment used for hazardous waste.  There are 3 different standards – Subparts AA, BB and CC – and each are specific to the type of equipment being used. 

Subpart AA deals with process vents used for treating/recycling hazardous waste, Subpart BB deals with equipment leaks and Subpart CC deals with tanks, containers and surface impoundments. All Subparts are focused on controlling emissions from the specific Subpart processes.

Subpart AA

Some equipment examples for this Subpart would include vents associated with solvent extraction, air stripping, steam stripping, thin-film evaporation, and distillation and fractionation columns. 

To be regulated, the unit must:

  • Be permitted or in interim status;
  • Be a recycling unit at a facility that has a RCRA permit or is operating under an interim status due to some other hazardous waste management operation (such as a RCRA-permitted storage tank); or,
  • Be a 90-day container or tank.
  • The hazardous waste being treated or recycled must contain at least 10 ppmw total organics.

Exemptions:

  • The recycling unit is at a facility that has no RCRA permit and is not operating under an interim status; or,
  • Your facility is equipped and operating with air emissions controls complying with other air regulations (CAA, NSPS, NESHAP, MACT) in 40 CFR Parts 60, 61 or 63 for each affected process vent.

Requirements:

If this regulation applies to you, then you’re required to first determine the emissions from all of those vents and if it’s less than 3 lbs/hour and 3.1 tons/year, no controls are required.  However, if it’s that rate or more, your facility must either find a way to reduce those emissions or use control devices that will reduce total organic emissions from all affected process vents by 95%. 

Subpart BB

This subpart is about equipment found in hazardous waste pipelines or the ancillary equipment associated with a hazardous waste tank.  These can be valves, pumps, compressors, pressure-relief devices, flanges, connectors, sampling connection systems or open-ended lines/valves.

To be regulated, the equipment must:

  • Be part of a permitted or in interim status unit;
  • Be part of a recycling unit at a facility that has a RCRA permit or is operating under an interim status due to some other hazardous waste management operation (such as a RCRA-permitted storage tank); or,
  • Be part of a 90-day container or tank.
  • The hazardous waste in the equipment must contain at least 10% total organics by weight.
  • The equipment must be in contact with or contain the hazardous waste for at least 300-hours per calendar year.

Exemptions:

  • The recycling unit is at a facility that has no RCRA permit and is not operating under an interim status;
  • The equipment is operated, monitored or repaired in accordance with air regulations (CAA, NSPS, NESHAP, MACT) for fugitive equipment leaks from 40 CFR Part 60, 61 or 63; or,
  • The equipment is in vacuum service because leaks would go back into the equipment.
  • If the facility can document that the equipment is flushed out between campaigns so that it contacts or contains the hazardous waste for less than 300-hours per calendar year, it is exempt.

Requirements:

If this regulation applies to your company, you’ll be required to implement an LDAR program (Leak Detection and Repair) for the applicable equipment.  LDAR programs are a significant effort and have their own design standards, tagging, and recordkeeping, reporting, inspection and monitoring requirements.

Subpart CC

This regulation applies to hazardous waste tanks, containers and surface impoundments (lagoons, holding/storage pits, ponds, etc).

To be regulated, the equipment must:

  • Be part of a permitted or in interim status unit; or,
  • Be a 90-day container or tank.

Units must receive hazardous waste containing greater than or equal to 500 ppmw volatile organics at the point of waste origination.  For generators, the point of origination is the same as the point of generation.  For TSDF facilities, the point of origination is where the owner accepts delivery/takes possession of hazardous waste.

Exemptions:

  • Satellite accumulation containers;
  • Small Quantity Generators’ 180/270 day tanks and containers;
  • Containers with a design capacity of less than or equal to 26.4 gallons;
  • Units used solely for the onsite treatment or storage of remediation wastes under state or RCRA corrective action or CERCLA;
  • Units not subject to substantive RCRA standards, including wastewater treatment units, elementary neutralization units, immediate response units and totally enclosed treatment units;
  • Units that receive radioactive mixed wastes; or,
  • Equipment with air emissions controls in accordance with air regulations (CAA, NSPS, NESHAP, MACT) in 40 CFR Part 60, 61 or 63.

Requirements:

If this regulation applies to your company, you’ll first need to determine the volatile organic concentration for every hazardous waste managed in one of these units.  If the concentration of every waste entering a unit is less than 500 ppmw, no emission controls will be required. 

Even if your tank contains less than 500 ppmw, if anywhere along the way to the tank from point of origination is 500 ppmw or more, you’ll need the emissions controls.

Tanks

For low vapor pressure wastes, a tank with a fixed roof with no gaps or openings between the roof edge and tank wall can be used.  For all other wastes, there are several options (floating roof, fixed roof with control device, enclosure vented to enclosed combustion device or pressurized tank). Control devices can be a flare or carbon adsorbers.

Containers

There are 3 levels of standards, based on container size.  Level 1 is low vapor pressure wastes in small capacity containers (26-121 gal), 55 gal drums, roll off boxes for soil, and containers greater than 121 gal.  For this level you must use DOT containers, they must have tight fitting covers with no visible holes or gaps, and they need to be closed.

Level 2 is for more volatile wastes in greater than 121 gal containers.  An example would be a tank truck with spent solvent. Here, use DOT containers, they must be closed having no detectable organic emissions, and you must prove they’re vapor tight on an annual basis.

Level 3 is where hazardous waste is being stabilized. They must be connected to a closed vent system to a control device and meet special requirements for being managed in an enclosure.

Surface Impoundments

Emission controls for surface impoundments must have an air-supported or rigid cover that’s vented to a control device or be an HDPE or similar floating membrane with a minimum thickness of 2.5 mm.

Does This Apply to You?

iSi can help you determine if you’re subject to RCRA Air regulations, and which Subpart you’re required to follow.  Contact us today for a price quote!

Do You Need to Comply With This?

Is this regulation something you need to be complying with?  iSi’s consultants can help you figure that out, and help you determine if you qualify for one of the exemptions.

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Sarah Winfrey
Sarah Winfrey

Contributing:

Bria Weast

Environmental and Safety Consulting Manager

A member of our Consulting Services division, Bria works with client facilities for annual environmental reporting and day-to-day environmental compliance assistance.  She also manages iSi project managers.  Bria has conducted well over 100 Phase I environmental site assessments for iSi and is one of the trainers for our Hazardous Waste Management class.

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EPA Discusses Current Compliance, Enforcement Priorities and Initiatives

EPA Discusses Current Compliance, Enforcement Priorities and Initiatives

Sep 17, 2021

At the recent KDHE Environmental Conference, Dave Cozad, Director of the Enforcement and Compliance Assurance Division with Region VII EPA gave an update outlining EPA’s upcoming compliance and enforcement priorities.

Compliance Inspections & Public Posting of Reports

EPA was scheduled to go back out to do more onsite inspections, but the resurgence of COVID put a delay on that.  For the past year they had been doing some announced remote inspections to evaluate compliance.  However, unannounced inspections will eventually resume.  Inspectors will have Smart Tables preloaded before they go onsite.  Their goal is for the report of findings be available in less than 60 days after inspection.

One important comment made was that EPA is working on implementing the public posting of inspection reports.  That is, what is found at your site during an inspection and what’s on your report will eventually be available for anyone to see.

Executive Orders Provide Roadmap

EPA has been given several directives through Executive Orders (EOs), and the issues EPA will focus on will very much be related to these.

These EOs include the following guidelines:

  • Hold polluters accountable, including those who disproportionately harm communities of color and low-income communities.
  • Strengthen and enforce environmental violations with disproportionate impact on underserved communities
  • Create a community notification program to monitor and provide real-time data to the public on current environmental pollution
  • Strengthen enforcement in communities with environmental justice concerns
  • Tackle climate change and enforcement of climate change-related issues

The term “environmental justice”, or EJ, goes along with these directives and will be applied to daily decision making.  To meet the directives, EPA will be spending more of their time looking at regulated industries in these underserved communities and will be strengthening enforcement of violations for cornerstone environmental statutes and civil laws.  Thus, the number of air, wastewater, and hazardous waste inspections in these areas will increase and items such as air monitoring results may be posted for the public to review.

EPA plans on going into these areas and speaking with the people about their enforcement case concerns rather than just determining themselves what EPA thinks they need, as they historically have done.

In the area of climate change, they’ll be targeting cases with greenhouse gas-related requirements and a ban on importing hydrofluorocarbons.  Climate-focused mitigation and resilience will be a part of the efforts.  For example, taking a look at situations like floods where there are chemical plants in floodplains or where sewer systems could have major overflows.

National Compliance Initiatives

National Compliance Initiatives are set goals that follow a certain process and include the states. Because of this, they  are much harder to change from administration to administration.  Some of these have been initiatives for the past 2 years, but give an idea of certain targets of inspections.

RCRA Air

This is hazardous waste emissions via air, where there are regulations related to the quantity of VOCs emitted.  This is for facilities with tanks, surface impoundments and valves.  Inspectors have started making a concerted effort to look at these during their inspections and it’s one of the lesser items focused on by some facilities. Right now 30% of facilities being inspected are not complying with this part of the regulation, and the fines can be $255,000.  What is RCRA Air? Learn more here.

Chemical Accident Reduction – RMP

EPA will be checking that Risk Management Plans are in place and implemented properly for those that are required to have them.  This is related to Clean Air Act section 112(r) for the prevention of accidental releases of chemicals.  Facilities that store and handle large quantities of listed regulated substance in a process, over certain threshold amounts.  EPA inspection data is showing that 50-75% of facilities are not complying fully with RMP.

Creating Cleaner Air for Communities and Drinking Water

We listed these 2 initiatives together because they will be treated similarly under the umbrella of EJ.  Making air and water cleaner has always been a goal, but considering the EOs, a focus on issues with public water systems, lead-based paint and air emissions from inner-city factories helps EPA accomplish more than one goal.  Plus those kinds of issues will affect a large amount of people at once. It becomes a more bang for their buck item, so to speak.

Mobile Source Aftermarket Defeat Devices

EPA is looking to conduct enforcement on companies who make, develop and sell aftermarket devices that bypass, defeat or renders inoperative any emission control device in order to enhance engine performance.  Examples would be plates that partially block a portion of exhaust gas stream, kits that enable the removal of the catalytic converter or the diesel particulate filter or tuners that stop signals from going to the   vehicle’s computer that usually would turn on the check engine light or put the vehicle in limp mode.  EPA’s news updates have been announcing fines for a number of companies recently for violations so this initiative is up and running.

NPDES Permit Compliance

EPA is looking to reduce the significant non-compliance they’re seeing with National Pollutant Discharge Elimination System (NPDES) permits. In an EPA memo to regional administrators regarding this initiative, they identified they wanted to reduce the non­compliance baseline rate by 50% by the end of FY 2022, while assuring that the worst violators are timely and appropriately addressed.

EPA wants its regions and states to work together.  Each state’s rate will be looked at as will its approaches (past and future) to reduce the non-compliance rate, the completeness and accuracy of its compliance data (and why it’s wrong/missing), and how and when they plan on addressing the more severe non-compliance violations.

Over 60% of the non-compliance is attributed to “non-receipt” of Discharge Monitoring Reports (DMRs).  Interestingly, EPA speculates that some of this isn’t all about companies not turning in their reports, but the way the states communicate or handle getting the information into the EPA’s tracking system.  However, make sure you get your DMRs in as this is something that’s on the radar.

If any of these initiatives can be tied back to those EOs, then all the better for EPA and their compliance goals.  For example, in the press release announcing a settlement for one of the companies found selling mobile defeat devices, part of the settlement was for the company to “…replace 3 school busses in a Columbus, OH in the areas of environmental justice concern.” In that same release, the regional administrator said she was “…pleased that the settlement will reduce the impact of pollution in already overburdened neighborhoods.”

EJScreen

EPA has a screening and mapping tool to help them identify areas that may be candidates for environmental justice-related consideration, outreach or programs. EJScreen is considered to be “…a consistent tool that can be used by EPA, its governmental partners and the public to understand environmental and demographical characteristics of locations throughout the United States.”

EJScreen was actually developed in 2010 as a response to an Executive Order by the Clinton Administration.  It is geared to help users identify areas with minority/low income populations, potential environmental quality issues and places where environmental and demographical indicators are greater than usual.  EPA plans to use EJScreen to implement permitting, enforcement, compliance, outreach and enhance geographically-based initiatives.  Facilities who lie within an EJScreen target area will be the ones who will receive the most inspections.

Check out EJScreen at: https://ejscreen.epa.gov/mapper/.

Other Areas

Other compliance hot topic/focus areas mentioned on EPA’s radar include:

  • Children’s health, mainly related to lead
  • Generators without proper status/notifications
  • Asphalt plants using mine tailings from CERCLA sites
  • PFAS
  • “Recycling” facilities
  • Coal combustion residuals
  • Potential return of supplemental environmental projects
  • EPA budget and staffing

Do you see any issues here that may be affecting your company?  Or are you unsure which ones may affect you?  Contact iSi today for EPA and state environmental compliance assistance and advice!

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Sarah Winfrey
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Contributing:

Bria Weast

Environmental and Safety Consulting Manager

A member of our Consulting Services division, Bria works with client facilities for annual environmental reporting and day-to-day environmental compliance assistance.  She also manages iSi project managers.  Bria has conducted well over 100 Phase I environmental site assessments for iSi and is one of the trainers for our Hazardous Waste Management class.

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EPA Warns Incinerator Backlog Could Mean Compliance Issues for Hazardous Waste Generators

EPA Warns Incinerator Backlog Could Mean Compliance Issues for Hazardous Waste Generators

Aug 25, 2021

Many of the nation’s commercial hazardous waste incinerator facilities are notifying customers they’ll no longer accept new waste for a while, says a new memo issued by EPA.  This is because there are backlogs at the incinerator facilities, and they can’t handle any more product.  EPA’s memo, dated August 10, 2021, was mailed to hazardous waste generators as an alert because this backlog is going to affect generator compliance with the regulations.

The Backlog

Incinerators cannot keep up with demand and cite several reasons.  Like most companies, they’re seeing labor shortages both on the transportation end and on the incinerator facility end.  Also, winter storms in the southern U.S. caused shutdowns and there have been additional shutdowns for scheduled and unscheduled maintenance.  Then on top of that, increased manufacturing after the pandemic is creating even more waste and the incinerators can no longer keep up. 

They estimate they won’t be able to resolve the backlog until the end of the first quarter of 2022.  This may create a big problem for manufacturers who send containerized waste for incineration.

The Compliance and Logistics Issues

Some types of hazardous waste must be incinerated to meet land disposal restriction treatment standards. 

Large quantity generators are only allowed to accumulate hazardous waste for a maximum of 90 days.  Small quantity generators are allowed 180 days, or 270 days if the waste must be transported 200 miles or more.

If some of that waste stored onsite is hazardous waste that needs to be incinerated, it presents a problem because at the current backlog estimate, it’s likely it’ll need to stay onsite for longer than those numbers of days. 

Besides going past your time window, this could become a storage issue for your facility.  Where are you going to store those drums until they can be accepted? 

Also, if you have a greater number of hazardous waste drums sitting around, how does that impact site safety and health?  What is your increased potential for spills and emergencies?  You may need to look into temporary secondary containment and alert your local emergency responders that you have more hazardous waste onsite than usual.

EPA’s Guidance

Generators are allowed to submit requests to their authorized implementing agencies (often your state environmental agency), asking for time limit extensions for a 30-day period.  Extensions are issued for “unforeseen, temporary, and uncontrollable circumstances.”  Then that agency has the power to accept or reject the extensions on a case-by-case basis. 

EPA says the agency should determine what the criteria for extensions should be and require some type of proof that you cannot get your waste shipped.  An example would be a letter from the incinerator saying they will not accept your waste due to the backlog in incinerating containerized hazardous waste.  You may be asked to change or look into your practices to reduce the amount of hazardous waste being generated.

TSDF Guidance

EPA says that TSDFs can store waste for longer than 90 days if their permit allows this type of storage activity up to their permit’s container storage capacity limit.  Once this is exceeded, TSDFs can either use temporary authorization procedures found in 40 CFR 270.42 or modify their permit in accordance with Class 2 or 3 modification procedures.  Temporary authorizations are limited to 180 days and can be extended for another 180 days if they have requested permit modifications for the condition covered by the temporary authorization.  Both options require approval by EPA or the authorized state. EPA recommends TSDF facilities notify their regulatory agency ASAP if they think they’ll need either option.

Incinerator News

Clean Harbors recently announced they are adding another 130,000 ton hazardous waste incinerator to their Nebraska facility.  This is only the second new incinerator approved in the last 25 years.  The other one was their El Dorado, AR incinerator that was approved in 2016.  It won’t come online in time to help the backlog situation, however, it should be operational by 2024.

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A Look Into the Biden Administration’s Environmental Priorities

A Look Into the Biden Administration’s Environmental Priorities

Apr 8, 2021

New year, new president, and a new push on policies. Trying to guess what will happen for the next four years into any new Administration is like trying to figure out when it will actually rain here in the Midwest. But, just like the assistance of a meteorologist, we can start to predict what we will see with the help of folks who understand and specialize in public policy.  

At the head of the Biden EPA is Michael Regan. A 20-year experienced environmental regulator, he was the head of the North Carolina Department of Environmental Quality and returns to the White House from formerly being an air quality specialist in the Clinton EPA.

Here are a few things to look for from the Biden/Regan team:

Environmental Justice (EJ)

While there are still questions bouncing around about how the Administration will carry out EJ, facilities can get ahead of the game and be prepared for what is to come. One of the biggest items that will be coming out of EJ is communities having their voices heard in environmental regulation. Something companies can start doing to prepare for this is reaching out to the communities where their facilities are located at. We understand the data we collect and how we collect it, but does the public understand it? Now is the time to educate the community you share a fence line with.

There are two major legislative proposals to keep an eye on. The Environmental Justice Mapping and Data Collection Act of 2021 will create a tool built upon the EPA’s EJScreen to identify demographic factors, environmental problems, socioeconomic circumstances and public health concerns. This data collected will help build maps of communities that are affected the most. This will help the Administration to direct appropriate funds to those communities.

Companies should be looking at the EPA’s EJScreen tool. It interprets and shows environmental indicators and demographic indicators. It is used for informing outreach and engagement practices, as well as permitting and compliance implementation, just to name a few.

The Environmental Justice for All Act will establish EJ requirements, advisory bodies and programs to address the environmental effects on human health for low-income communities. It will also provide the establishment of the Interagency Working Group on Environmental Justice Compliance.

More Inspectors on the Ground

With COVID-19, we saw fewer boots on the ground and the number of virtual inspections and audits go up throughout facilities. With vaccines rolling out and the country starting to open back up, there is going to be a drive to get inspectors back on the ground. Now is the time to go over your facility’s reporting to make sure it is accurate and to re-evaluate your risk assessment plans and make sure your facility complies with all regulations.   

Waters of the United States (WOTUS)

WOTUS is already under review for this Administration. We can expect to see extreme discussion on this since having to define WOTUS is difficult, as it is controversial.  Multiple states, tribes and environmental groups pushed back on the Trump Administration’s Navigable Waters Protection Rule, so we can speculate that the Biden Administration will want to expand the definition and scope and go for a broader rule to replace it.

Per- and polyfluoroalkyl substances (PFAS)

Expect to see the enforcement of PFAS being talked about, as well. Some questions are if the Biden Administration will use the All-of-Government approach like we are seeing in climate change, if they will revisit the 70 ppt LHA for drinking water and if the remediation of PFAS will be listed as a hazardous waste under RCRA or CERCLA. States are also getting involved with PFAS. There will be multiple legislation pieces floating around on both the federal and state level.  Regan is committed to making PFAS a “top priority” for this team and he mentioned in his Senate confirmation that part of this approach will include pursuing discharge limits and water quality values.

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Sarah Winfrey
Sarah Winfrey

Contributing:

Sarah Winfrey

Sales Development Representative

Sarah works with our Business Development and Marketing team, assisting with client and internal communications, pricing proposals, customer support and sales efforts.  She also maintains a number of iSi's contractor registrations and assists with industry and regulations research.

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2020 ERG – Emergency Response Guidebook Updates

2020 ERG – Emergency Response Guidebook Updates

Oct 28, 2020

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The new 2020 version of the Emergency Response Guidebook (ERG) is finally out, and hard copies are now available.  The ERG is published every 4 years.

What is the ERG?

The ERG contains emergency response information and is a handbook used by emergency and hazardous materials incident responders, truck drivers, railroad personnel, pipeline personnel, pilots, police and firefighters.  It is written and updated by four separate international agencies:

  • U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Transport Canada’s Canadian Transportation Emergency Centre (CANUTEC)
  • Argentina’s Chemistry Information Center for Emergencies (CIQUIME)
  • Mexico’s Secretariat of Communications and Transport

iSi uses the ERG in our HAZWOPER training as well as our DOT Hazardous Materials Transportation, Hazardous Waste Management and RCRA Refresher classes.  This is because handling emergency spills are a component of all of these classes.

Updates

The four agencies have been working on this latest version since 2017.  In 2018, all of the agencies solicited input from their public through calls for comment, listening sessions, online surveys, and articles.  From these solicitations, 100 comments were gleaned to be considered for incorporation and DOT held a public meeting as well.  Since then, sub-groups worked on the updates.

Here is a list of the planned changes and items that were up for review within each section of the book. The agencies will:

White Pages [General Information, Instructions, Recommendations, Guidance]

      • Review content for use of plain language;
      • Improved quality of illustrations in charts for railcar and road trailer identification;
      • Add new lithium battery markings;
      • New terms in the glossary section;
      • Add a decontamination section; and,
      • Add basic information about heat induced tears (HIT).

Orange Pages [Response Guides]

      • Comprehensively review of all materials and their assignments in the orange pages by FEMA/NFA, with certain items up for review in 2020 while others will be reviewed before the 2024 version;
      • Distances in the Public Safety section are now in the Evacuation Section;
      • Created a new “How to Use the Orange Guide Pages” section;
      • Guide 121 Gases – inert was merged with Guide 120 Gases – inert (including refrigerated liquids);
      • Added CAUTION sentences for specific materials;
      • Clarify sentences;
      • Address inhalation concerns for petroleum crude oil (UN1267) in Guide 128; and,
      • Reevaluate radioactive materials guides with radiological/nuclear regulatory agencies.

Yellow/Blue Pages [Materials in ID/Name of Material Order]

      • Add or remove UN numbers to align with United Nations Model regulations and North American regulations;
      • Remove UN numbers for chemical warfare agents;
      • Reevaluated guide assignments for some materials; and,
      • Review polymerization hazards for certain materials.

Green Pages [Isolation and Protective Action Distances]

      • Add distances for new Poison Inhalation Hazard/Toxic Inhalation Hazard materials added by regulations;
      • Revise Table 2 introduction;
      • Add container capacities to Table 3;
      • Make a new border to differentiate between Tables 1, 2 and 3; and,
      • Argonne National Laboratory will update the Chemical Accident Statistical Risk Assessment Model (CASRAM) with outcomes from field and lab experiments.

Where Can the Current ERG Be Found?

A free PDF version of the current Emergency Response Guidebook is available online on the PHMSA website. There’s also a mobile app for the guide available for both Android and iPhone devices.    If you’d like to purchase a hard copy for your use, check out the iSi online store.

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Paint Booth Cleaning: It’s the Law, but Can Save You Money

Paint Booth Cleaning: It’s the Law, but Can Save You Money

Aug 27, 2020

iSi paint booth cleaning example

In this week’s blog, we’ll explore the case for paint booth cleaning.  Not only is it the law, but it can save your company a lot of money.

Cleaning is the Law

There are a number of regulations and standards which include paint booth cleaning and maintenance as part of their directives. Most of these are to protect the workers inside the booth, workers outside of the booth and the environment. Some of these include:

  • OSHA 1910.107 and 1910.94
  • EPA NESHAP, 40 CFR Part 63 Subparts HHHHHH and XXXXXX
  • NFPA 33

Cleaning SAVES Money

iSi has been providing paint booth cleaning personnel for a number of years to industrial facilities. One of the biggest comments we get from our clients in favor of routine cleaning is how much a clean booth will affect the quality of the painted part. A clean booth significantly reduces the amount of dirt and impurities in the air, leading to a dramatic reduction in the number of re-paints. This in turn saves painter time and resources, increases productivity, and improves the quality of the finished product.

Dirty booths can make a big difference on booth effectiveness. Built-up coatings on floors and walls become harder and harder to remove as time goes on. Filters which are dirty, not changed on a regular basis, paint-coated, missing, or not sized for the type of booth they’re in all contribute to poor booth performance. Coated sprinkler heads and fire devices are a fire safety hazard. Not addressed on a routine basis, these issues can end up costing your company in additional labor costs, equipment replacement costs and product painting redos.

What Should be Cleaned?

Booths walls and floors, paint grates, sprinkler heads, filters, gauges, ventilation ductwork and fan blades should all get routine attention. For safety reasons, gauges should shut down if there’s not enough flow through the filters. Paint scraps should never be left in piles on the floor, and drums of rags and wastes should be removed each day.  OSHA says that in some cases, daily cleaning may be needed.

Who Should Clean the Booth?

What are the hazards involved in the paint that you’re using? If the paint is hazardous, this puts you in a totally different level of effort and compliance responsibility than a traditional janitorial or maintenance company may be able to provide. For example, iSi conducts cleaning of booths contaminated by hexavalent chromium paints. This requires our workers to wear special PPE and respirators and follow strict protocols. As a company, iSi is required to have a respirator program, a hexavalent chromium program, and routine medical monitoring.  Other hazardous paints may have similar requirements, so if you’re using your own personnel to clean the booths, make sure you’re compliant with all OSHA and medical requirements for this work.  It may look like it’s just a cleaning job, but the materials your workers will be exposed to make it much more complicated.

Some companies will have their painters do the cleaning either before or after a shift. This takes extra time away from their regular duties, and sometimes lack of time and shifting priorities can create shortcuts. Thus, companies end up paying for maintenance duties at skilled painter labor rates.  It’s fine for you to use your own personnel, but you may want to consider what’s best use of their time and what you’re spending in the long run.

If you have questions or comments about paint booth maintenance, contact us today, and we’d love to help you!

How can iSi help your company with paint booth cleaning and compliance? Check us out!

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DOT Hazardous Materials Registrations Due July 1

DOT Hazardous Materials Registrations Due July 1

Jun 17, 2020

If your company ships or transports hazardous materials, including hazardous waste, you are required to register for a U.S. Department of Transportation (DOT) number. These registrations are due for renewal annually and the payments are due before July 1.

DOT registration fees are based on the nature and size of your company. You will need to know the primary NAICS Code for your company first. There are two tiers of company sizes: “small” and “large” based on number of employees and revenues. Small company fees are $250/year and large company fees are $2,575/year.

You can register by mail or online at https://www.phmsa.dot.gov/registration/online-registration.  Your company cannot transport hazardous materials until registered. If your company has failed to register for any previous years, you will need to register for any missed years and pay for those as well.

DOT has the option for your company to register for up to three years at a time.

If you are transporting hazardous materials, certificates of registration are required to be kept in your vehicle at all times. These will be required during roadside inspections. Failure to have one in the vehicle, or failure to have an updated certificate, could result in a fine of up to $37,500 per day.

In addition, copies of the certificates of registration are to be kept for three years at your place of business and must be available for inspection.

Fees that are collected from DOT registrations are used to pay for grants and state and Indian tribe programs related to hazardous materials emergency response planning and training.

If you need assistance in determining the DOT registration process applies to your company, or need help in completing the paperwork for this requirement, please contact us. Also, if your company is shipping or transporting certain types of hazardous materials or large bulk quantities (6,614 lbs. of solids or 792 gallons of liquid), you are required to have DOT Security Plans in place. iSi can help determine if this additional requirement applies to you, and help you prepare these plans as well. Please contact us for more information.

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EPA Enforcement During COVID-19 Disruption: What Do You Need to Do?

EPA Enforcement During COVID-19 Disruption: What Do You Need to Do?

Apr 2, 2020

UPDATE:  EPA has announced they will be ending these policies on August 31, 2020.

The COVID-19 outbreak is affecting businesses — from creating labor challenges to shutting them down altogether. As a result, you may not be able to meet your EPA or state environmental obligations. During this time, what is EPA doing about enforcement?

EPA has issued a guidance document on how it will conduct enforcement for noncompliance. Basically, the overall message is to communicate, document-document-document and do your best to make a good faith effort to comply.

EPA is leaving discretion to the states on how they want to handle noncompliance. So although in this article we are going to cover what EPA says (and what iSi’s experience has been with state agencies lately) ALWAYS double check with your state or your permitting agency because what they say will be the overall direction you will need to follow. Better yet, keeping in contact with your permitting agency and alerting them of potential noncompliance is likely the best policy because if their policies differ, they will be able to tell you so. Always document your conversations or communications for your files.

Overall EPA Guidance

EPA wants your company to make every effort to comply, but if you cannot,

  • Act responsibly until you can;
  • Identify the nature of what your noncompliance will be, on what dates, and the reasons why COVID-19 was the cause;
  • Document the steps you are going to take to become compliant,
  • Work to become compliant ASAP; and,
  • Document all actions and reasons and keep those in your files.

EPA understands that staffing may be limited and resources like contractors and laboratories may affect your compliance status. So until further notice from EPA, they will not be penalizing the following actions if they agree with you that COVID-19 was the legitimate cause of your noncompliance:

  • Monitoring
  • Sampling
  • Lab Analysis
  • Integrity Testing
  • Reporting
  • Certification
  • Training

Although training is on that list, EPA says they expect you to maintain your training certifications as there are a number of online alternatives available. An example where they would excuse noncompliance is if you needed to make a choice between having certified and qualified operators running your operations vs. sending them to training. They would prefer you to keep operations running if that was the only choice you had.

Resume bi-annual and annual reporting as soon as possible and submit late reports as soon as possible. If your report requires a handwritten signature, it can be digitally signed. If you miss a sampling or monitoring episode, you will not need to make it up later if it is typically conducted in intervals of 3 months or less.

Hazardous Waste

If possible, continue to conduct your weekly inspections. If you have containers onsite that will exceed the number of days you can store them, such as a 90-day storage limit, continue to properly store and label them until you can get them removed. EPA will not consider you a TSDF (treatment, storage and disposal facility) if you go past the date. If you are a Small Quantity Generator or a Very Small Quantity Generator, you will retain your generator status if you go past the date.

Ensure you document everything and put it in your records.

Air Emissions

Get very familiar with your permits and what they say about notifications during shutdowns. In some permits, there may be a reference to emergency episode plans that typically address equipment failures, but see if they say anything about temporary shutdowns. Some permits may also mention that temporary shutdowns may cause less emissions during shutdown, then exceedances when the equipment is refired. You may have to give a notification in both instances.

If you cannot find anything, double check with your permitting agency and then document any phone calls or emails. Self-reporting shows good faith efforts on your part.

Wastewater

Every permit may be different, so check what yours says about shutdowns. Many permits will mention that you must notify if there will be a “significant change,” and a shutdown would be a significant change. You will likely need to continue doing weekly inspections and sampling. For shutdowns over extended periods, when you return to service, you may need to do weekly sampling for a set term to prove you’re in compliance.

When any part that is covered by your permit is removed from service, you’ll need to notify the permit authority to ensure the water and the environment is protected.

Stormwater 

Stormwater regulations vary from state to state and in some areas, city to city. Most will have quarterly inspections and rain event sampling. Continue to do that whenever possible. If you cannot, contact your local stormwater authority and/or document the reasons why this cannot be accomplished.

Spill Prevention, Control and Countermesure (SPCC)

Most SPCC plans require monthly inspections. Continue to do these, and if for some reason you cannot, document the reasons why.

Public Water Supply

For those who operate public water supplies, it needs to be run business as usual. EPA has specifically called out this operation as critical to public safety and health. If you are having staffing or laboratory issues, you need to work with your state to get these issues solved.

Accidental Releases

If you have an accidental release or an equipment failure that causes an exceedance which can affect the environment, this needs to be handled business as usual as well. You need to stop the release, mitigate the affects of it as quickly as possible, and still make all the necessary notifications.

Questions?

If you have questions about what you need to do, or need us to help while your own staffs are short, please contact us!

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EPA Finalizes Aerosol Can Universal Waste Regulation

EPA Finalizes Aerosol Can Universal Waste Regulation

Dec 19, 2019

As we first reported here in April 2018, and is now final, EPA is allowing generators to handle aerosol cans as a universal waste rather than a hazardous waste.   The rule becomes effective February 7, 2020.

The final rule looks a bit different than the proposed ruling, and has clarified some issues, especially in the puncturing and draining of cans.

The goal of classifying aerosol cans as universal waste is to reduce regulatory costs, ease regulatory burdens on retail stores and other businesses that discard aerosol cans, promote the collection and recycling of the cans, reduce the amount of cans going to landfills, and save over $5.3 million per year.

Who’s Affected?

The new aerosol can universal waste rule applies to all persons that generate, transport, treat, recycle or dispose of aerosol cans.  It does NOT apply to very small quantity generators or households.

Aerosol Can Definition

In terms of what can be included as an aerosol can, EPA decided to broaden its definition to be more in line with DOT regulations.  Their definition:

“…aerosol can is defined as a non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.…Because compressed gas cylinders, unlike aerosol cans, require special procedures to safely depressurize, it would not be appropriate to include them in the final rule.”

Labeling

Each aerosol can, or a container in which contains aerosol cans, must be labeled or marked with any of the following phrases: “Universal Waste—Aerosol Can(s),” “Waste Aerosol Can(s),” or “Used Aerosol Can(s).”

Storage

Handlers must ensure their management of universal waste aerosol cans do not create releases to the environment.

  • Cans must be accumulated in containers that are structurally sound and compatible with the contents of the can, and show no evidence of leaks, spills, or damage that could cause leaks.
  • Universal waste can be stored for up to one year.
  • Handlers may sort aerosol cans by type and consolidate intact aerosol cans in larger containers.
  • Handlers can remove actuators to reduce the risk of accidental release.
  • Cans may be punctured and drained when the emptied cans are to be recycled.
  • Leaking and damaged cans must be packaged in a separate closed container, overpacked with absorbents, or punctured and drained.

Puncturing/Draining Written Procedures

Puncturing and draining must be conducted by a device specifically designed for that purpose, and must effectively contain the residual contents and any resulting emissions. Commercially-manufactured and custom designed or retrofitted machines are acceptable, as long as they meet acceptable engineering and design standards are met and that specific procedures are followed.

To ensure the process and devices safely puncture cans, effectively contain residual contents, and control emissions, EPA is requiring handlers to develop and follow written procedures that take the necessary precautions to protect human health and environment.  The procedures require:

  • Operation and maintenance of the unit (e.g., including manufacturer’s and state guidances);
  • Segregation of incompatible wastes;
  • Proper waste management practices (e.g., ensuring that ignitable wastes are stored away from heat or open flames, wearing proper PPE, keeping containers closed, not overfilling containers, etc.);
  • Maintain a copy of manufacturer’s instructions onsite; and,
  • Ensure employees operating the machines are trained in proper procedures.

Handling

  • It will be the handler’s responsibility to ensure wastes are compatible with each other for worker safety, environmental safety, and fire prevention purposes.
  • Puncturing equipment must be placed on solid, flat surfaces in well-ventilated areas.
  • The hander must immediately transfer contents from the can to a container or tank.
  • The handler becomes the generator of the waste and should manage it in accordance with RCRA guidelines. As such, after transfer of contents to the container/tank, a hazardous waste determination should be made.

Spill and Leak Prevention Written Procedures

The aerosol can universal waste rule requires written procedure be in place in the event of a spill or leak.  In addition, a spill clean-up kit should be provided. All aerosol can spills or leaks should be cleaned up promptly.

Land Disposal Restriction

Aerosol cans, as other universal wastes, will be exempt from land disposal restriction requirements.  Aerosol can universal waste will be added to the LDR requirements.

Wait – Be Aware of Your State Requirements

EPA considers this rule less stringent than current federal programs, and thus, states will not be required to adopt this rule.  However, EPA says that many states already recognize aerosol cans as universal waste, and they are encouraging states to adopt this recognition.  Check the regulations in your state and their stance on incorporating this final rule before adopting these policies.  Depending on your state regulations, you will still need to treat them as hazardous waste until your state incorporates these changes into their own regulations if they differ.

Questions?

If you have questions about the new aerosol can universal waste regulation or about your company’s compliance with it, contact us today!  If you need to learn more about hazardous waste regulations in general, check out our hazardous waste management and RCRA Refresher class schedule or arrange for one at your facility!

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Citation Case Study: Fluorescent Lamps Hazardous Waste Violation

Citation Case Study: Fluorescent Lamps Hazardous Waste Violation

Sep 26, 2019

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Haz Waste Audits

iSi conducts audits and inspections to find potential environmental violations, including hazardous waste.  Let us give you that second set of eyes to make sure your company is on track.

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The following is an example of a fluorescent lamp hazardous waste citation given to a manufacturing facility by a state’s environmental regulatory agency.  The company appealed to the state’s Office of Administrative Hearings.  Although this particular citation was from a state regulatory agency, the citation referenced a federal hazardous waste regulation and thus this issue may be cited in any location.

Can this scenario be found at your facility?

Scenario:

A company was found with one spent 8’ fluorescent lamp on a shelf. 

The Citation:

40 CFR 273.13(d)(1), 273.14(e), and 273.15(c)

The company was cited with hazardous waste violations for

1)  Failure to containerize lamp;
2)  Failure to label lamp as Universal Waste; and,
3)  Failure to mark lamp with accumulation start date

The company tried to prove that the lamps used are non-hazardous (do not contain mercury above the TCLP limit) and were purchased from Lowe’s by providing receipts.  However, receipts found were from 4’ lamps and not 8’ lamps.

The company also stated that a marked container was indeed present for lamps (and the state environmental agency acknowledged a container marked “Universal Waste – Lamps” was present in their notes from the inspection).  The company argued that therefore, they should not be cited for the container violations of failure to label and failure to date, only the failure to containerize.

The Ruling in Appeal:

It was found that while the fluorescent lamp was ultimately placed in the container as required, that it did not detract from the fact that, upon inspection, the spent lamp had not been placed in a container. Moreover, since the lamp was not in a labeled container, the regulation requires that the lamp itself be labeled. If the lamp was not in that container then it must be labeled, according to the regulation.

Likewise, the fluorescent lamp needed to be dated to indicate when it became waste.  While the there was a labeled and dated container in the facility, the lamp in question was not in that container.  Because the lamp was not in the container maintained by the facility, the company was in technical violation of all three regulations.

###

Are you maintaining your fluorescent lamps properly?  What about the other wastes at your facility?  iSi can help you determine what you’re currently doing correctly and which areas need changes.  Let us come take a look at your facility today!

How does your hazardous waste program look?  Let our experts do a walkthrough to see what could be potential violations!

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Citation Case Study: Paint Drippings on the Ground a Hazardous Waste Violation

Citation Case Study: Paint Drippings on the Ground a Hazardous Waste Violation

Aug 22, 2019

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Haz Waste Audits

iSi conducts audits and inspections to find potential environmental violations, including hazardous waste.  Let us give you that second set of eyes to make sure your company is on track.

Schedule Inspection

The following is an example of a hazardous waste citation given to a manufacturing facility by a state’s environmental regulatory agency.  The company appealed to the state’s Office of Administrative Hearings.  Although this particular citation was from a state regulatory agency, the citation referenced a federal hazardous waste regulation and thus this issue may be cited in any location.

Can this scenario be found at your facility?

Scenario:

A company had paint drips on the ground outside by their dumpster.  The paint drips had accumulated over time since the company had been in the same location for over 10 years.

The Citation:

40 CFR 265.31

The company was cited for violation of hazardous waste rules for “Failure to prevent the possibility of fires, explosions or sudden releases of hazardous waste.” 

The company tried to prove the paint drips came from exempt containers that were RCRA empty at the time of disposal into the dumpster, and the paint drips had accumulated over time.

The Ruling in Appeal:

In this appeals process, a judge reviewed the work of the state inspector and heard testimony by the cited company. 

The first consideration was whether all wastes were removed from the can that could be removed, as required by regulation in order for the remaining contents to be exempt. KDHE and the Administrative Judge found that if the contents were able to drip from the cans upon transport to the dumpster, and in the quantity dripped, not all of the wastes were removed from the paint cans that could have been removed. As a handler of hazardous wastes, the company had a responsibility to take precautions to ensure that hazardous materials were not subject to a release “to air, soil, or surface water which could threaten human health or the environment.”  

The judge noted that spills were understandable; however, the failure to clean up the spills and mitigate the release is crucial. 

With the premise that the hazardous waste contents of the paint cans were no longer exempt once they exited the paint can(s), the question is then whether the spills identified during the inspection violated 40 CFR 265.31.  The regulation states: “Facilities must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.”  The judge found that the company did not minimize the possibility of a fire or release of hazardous waste, and took the least restrictive means’ of handling a hazardous waste, resulting in spills.

Possible Solution:

During the hearing a question was posed to the inspector as to what could have been done to prevent the spills. The inspector mentioned the possibility of using better bags for disposal or even double bagging the paint containers, and landfills are constructed to avoid release of hazardous wastes into the environment.

The company was told it must take precautions to mitigate release, at the very least until the waste reaches the landfill and the citation was upheld.

How does your hazardous waste program look?  Let our experts do a walkthrough to see what could be potential violations!

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EPA’s National Compliance Initiatives Show Enforcement Priorities

EPA’s National Compliance Initiatives Show Enforcement Priorities

Aug 1, 2019

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Just like OSHA has national emphasis programs for areas they want to target in their enforcement, EPA has its own national emphasis targets.  Called the National Compliance Initiatives (NCI), EPA has listed 7 priority areas to target for enforcement for Fiscal Years 2020-2023. 

So what’s on the EPA NCI Target List?

Air – Reducing Air Emissions at Hazardous Waste LQGs and TSDFs

EPA has found that facilities that generate a greater amount of hazardous waste have air emissions issues.  Their focus will be on air emissions at Large Quantity Generators (LQGs) and Treatment, Storage and Disposal Facilities (TSDFs).  This emphasis item was in the agency’s last list of NCIs, and inspectors have found there is still significant noncompliance at these facilities.  EPA wants improved compliance in controlling organic air emissions from certain management activities.  They will especially be looking at the following areas in which they are continuously finding problems:

  • Leaking or open pressure relief valves;
  • Tank closure devices;
  • Monitoring; and,
  • Recordkeeping.

Water – Reducing NPDES Permits Noncompliance

EPA will be looking at your facility’s NPDES (National Pollutant Discharge Elimination System) permits to see if you’re in compliance.  NPDES permits are for water discharges, whether they be wastewater, stormwater or otherwise.  In 2018, 11,000 permits had violations totaling 4 billion pounds of pollutants above permitted limits, and EPA wants to crack down on that.  Out of 40,000 facilities with NPDES permits, EPA estimates 29% are in significant noncompliance.  EPA’s goal is to cut that in half by fall 2022.  EPA specifically mentions failure to submit required reports and significant exceedances of limits as two of the most violated areas.

Air – Reducing Excess Emissions of HAPs and VOCs from Stationary Sources

EPA wants a focus on reducing emissions of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs).   They will be focusing on sources of VOCs that may have substantial impact on an area’s attainment or non-attainment of National Ambient Air Quality Standards.  EPA will also be focusing on areas with a greater concentration of HAP sources.  EPA has listed over 180 chemicals that are HAPs, including mercury, asbestos, toluene, cadmium, chromium, benzene, perchloroethylene, and lead.

Hazardous Chemicals – Reducing Risks of Accidental Releases at Industrial and Chemical Facilities

This was on EPA’s list last time, and is continuing.   This NCI not only applies to facilities subject to Risk Management Program requirements (for accidental chemical releases at facilities that store certain chemicals above a certain threshold).   EPA cites a General Duty Clause in their Clean Air Act to cover all facilities with regulated substances and extremely hazardous substances, regardless of quantity.  They’ll be using that General Duty Clause (Clean Air Act Section 112(r)) which requires companies:

  • Identify hazards that may result from accidental releases by using appropriate hazard assessment techniques;
  • Design and maintain a safe facility;
  • Take steps to prevent releases; and,
  • Minimize the consequences of the accidental releases that occur.

It will be important that your facility not only has conducted the proper hazard assessments and has plans and controls in place, but has documentation that has occurred.  This exercise and documentation will help you with both EPA and OSHA compliance.

Air – Stopping Aftermarket Defeat Devices for Engines

This is a new item on EPA’s list.  They will be looking to stop the manufacture, sale and installation of defeat devices on engines.  Often called tuners, these devices bypass the engines’ emissions control systems in order to improve engine performance or fuel efficiency.  The systems modify the exhaust system or electronic chips within the vehicle.   EPA has been levying fines on car manufacturers for a number of years in this area.  One of the most famous cases is the recent Volkswagen emissions scandal where vehicles were rigged to recognize regulatory emissions testing, but operated differently in real world driving conditions.  Now EPA is going after the aftermarket manufacturers and have already started.  However, the emphasis isn’t just limited to vehicles on the road, it’s for any engine, including non-road vehicles and engines.

Water – Noncompliance with Drinking Water Standards at Community Systems

This is a new NCI area for EPA.  EPA says that out of 50,000 Community Water Systems that serve water to the same people year-round, 40% violated at least one drinking water standard in 2018.  Also at these facilities, 30% had monitoring and reporting violations and 7% had health violations.  EPA’s goal is to reduce this noncompliance by 25% by having EPA’s Office of Water work to increase capacity within the states and tribes to address these violations.

Lead – Child Exposure to Lead

This one is an unofficial NCI emphasis because it will be treated as a directive but not be a part of the official NCI enforcement list as a separate program.  EPA has an overall initiative for lead, and the NCI guidance documents affirm enforcement commitment to participating in that initiative.   Plans for EPA’s overall lead initiative include:

  • Increasing compliance with and awareness of lead-safe renovations with the Renovation, Repair and Painting rule;
  • Developing a mapping tool to identify communities with higher lead exposures;
  • Targeted geographical initiatives; and,
  • Public awareness campaigns on lead issues.

What’s Next:  Regional Plans

Each region is to develop a strategic plan on how they will be accomplishing these EPA NCI goals.  Within these plans the regions are to determine how they’re going to allocate resources to these NCIs and how much investment will be put into each one.  The plans are due August 1.   

These NCIs are the goals for Fiscal Year 2020-2023, thus they will go into effect October 1, 2019.

Does your facility fall under these targets?  We can help you determine that, and get you ready — Contact us today!

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What are Lab Packs and How Could Your Facility Use Them?

What are Lab Packs and How Could Your Facility Use Them?

Jun 20, 2019

Casey Moore, iSi Environmental

About the Author: iSi’s Casey Moore has more than 25 years of experience in the hazardous waste industry including working for hazardous waste carriers and operating hazardous waste facilities in California and Arizona.

I’ve never been a fan of “spring” cleaning, but it’s a necessary part of good housekeeping around the home or at your facility. When was the last time your facility did a “spring cleaning” walkthrough to see if there are any materials around your workplace that are expired, or you don’t need?  Flammable cabinets, chemical storage, research/QC labs and maintenance shops are likely places these items accumulate.

What is a Lab Pack?

Since most of the items in these locations are likely to be in smaller containers, they aren’t treated like regular waste streams. Lab packs are a practical solution. Lab packs are consolidation packaging of “like” materials from the smaller containers into larger containers to satisfy proper DOT shipping and EPA RCRA hazardous waste management.

The lab pack was designed for managing expired materials in labs, however, it’s something that can be used for any facility that needs to do a cleanout of smaller containers usually less than 10 gallons each.

What Items Are Candidates for a Lab Pack?

Look for jars, jugs, vials and cans of hazardous materials, including chemicals, solvents, paints, thinners, acids, cleaners, strippers, inks and more. These are typically out of date, off-specification, partially used, and no longer needed.

Who Does Lab Packing?

There are strict regulations about who is qualified to do lab packing. These persons need to determine which containers can be put together and which ones may cause harmful reactions when mixed. Typically, hazardous waste carriers provide this service.

How is Lab Packing Accomplished?

First, items are segregated, that is, sorted, for combining into one larger container.  Items are segregated by:

  • Hazard class — most common are flammables, corrosives, and toxics
  • Type of material — liquids, solids, etc.
  • Compatibility

“Paper pack” is the term used to show the segregation by container. An initial inventory list is converted into lab pack inventory sheets (what goes into each container). This is what waste companies use to create approval numbers for compliance under RCRA. It is also how they establish price. Pricing is based on disposal, transportation and labor associated with packaging.

Packaging is accomplished by:

  • Putting the segregated materials into their respective larger containers;
  • Filling with a packing material (vermiculite is most common) to create stability and containment while shipping;
  • Vermiculite will be in the base and surrounding each of the internal containers; and,
  • The smaller containers are placed into the larger container vertically, so the label with the double arrows pointing up is on the outer packaging.

RCRA Regulation Implications

A lab pack counts towards your waste generation status if you’re a Very Small Quantity Generator (VSQG) or a Small Quantity Generator (SQG), so be mindful of the amount of hazardous waste generated in the process.

For states that have already adopted the Generator Improvements Rule, this is a good use of the episodic event and would not count against your generator status.

If you have any questions regarding lab packs or hazardous waste regulations, contact us!

iSi can help with hazardous waste compliance and facility walkthroughs to find environmental and safety issues.  Contact us today!

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Who Regulates Hazmat Shipments?

Who Regulates Hazmat Shipments?

Sep 21, 2018

In the environmental and safety world, it’s pretty simple to determine who’s the regulatory authority. For safety, in most cases it’s OSHA, and if you’re in a “state plan” state or if you’re a public entity, your state has an additional safety regulatory agency. For environmental issues, it’s EPA and for many states there is an additional state agency which covers environmental regulations plus you have municipal environmental rules. However, when it comes to shipping hazardous materials, it gets a little more complicated.

In the U.S., the shipment of hazardous materials is covered by federal regulation 49 CFR. 49 CFR addresses the shipment of hazardous materials by ground, air and vessel. The Department of Transportation (DOT) is responsible for enforcing 49 CFR.

DOT contains a variety of agencies which are responsible for ensuring specific parts of 49 CFR are being followed:

  • Pipeline and Hazardous Materials Security Administration (PHMSA);
  • Federal Aviation Administration (FAA);
  • Federal Motor Carrier Safety Administration (FMCSA); and,
  • Federal Railroad Administration (FRA).

In addition to the federal agencies, there are additional state agencies with the authority to enforce DOT regulations. For example, this could be your state’s department of transportation and additional agencies which govern the highway patrol, rail lines or pipelines. Thus, you could receive inspections from a variety of state officials and highway patrol in additional to the federal agencies.

If there was one arm of DOT which takes the lead in hazardous materials, it’s PHMSA. PHMSA’s focus is safe shipments and it creates and publicizes regulations. Thus, if you wanted to learn new information about shipping hazardous materials, start with PHMSA.

When it comes to air and vessel shipments, you’ll find that although 49 CFR has rules regarding these types of shipments, in parts, 49 CFR defers to two other agencies, the International Air Transport Association (IATA) and the International Maritime Organization who publishes the International Dangerous Goods Code (IMDG). These are international organizations, as the shipment of hazardous materials will often cross country boundaries via ocean or air. Thus, when you’re required to have training, you need the training of both 49 CFR and IATA or IMDG. IMDG can also be applicable to shipments within in the U.S. when shipping to Hawaii, Alaska or Puerto Rico.

Radioactive materials shipments are regulated under the U.S. Nuclear Regulatory Commission (NRC).

Both OSHA and EPA mention and defer to DOT within its regulations. Thus, you need to be aware AND trained in both the regulations of OSHA/EPA and DOT when dealing with environmental or safety issues.

49 CFR regulations can become very confusing. If you need help determining which regulations apply to you and how you need to ship your hazardous materials, contact us and we’d be happy to help!

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EPA Proposing Changes to Aerosol Can Hazardous Waste Regulations

EPA Proposing Changes to Aerosol Can Hazardous Waste Regulations

Apr 2, 2018

EPA is proposing to allow generators to handle aerosol cans as a universal waste rather than a hazardous waste. As a result, EPA hopes to encourage more recycling, ease regulatory burdens on generators, reduce the amount of cans going to landfills, and save over $3 million per year.

The Current Aerosol Can Hazardous Waste Regulation

Aerosol cans, when discarded, are handled as hazardous waste. Entities with these are required to follow all hazardous waste rules regarding them. The number of days you can store these cans ranges from 90 to 270 depending on generator status and transportation. Retail stores who discard aerosol cans must also follow all hazardous waste rules. In some states, generators can recycle the cans for scrap metal by puncturing them and draining the contents into other containers. The can becomes non-hazardous, but the container of leftovers may be considered hazardous waste. Some states don’t allow the puncturing and recycling of cans at all, even under carbon filtration.

The Proposed Aerosol Can Hazardous Waste Regulation

The proposed regulation would make discarded aerosol cans a universal waste. Other EPA universal wastes include batteries, mercury-containing equipment, and hazardous waste mercury lamps. Universal wastes can be stored and collected for up to one year and don’t need a hazardous waste manifest as long as they’re properly packaged and labeled.

As for aerosol can recycling, the proposed rule would encourage generators to collect and send their cans to a centralized hazardous waste handler for recycling. Any company recycling aerosol cans would be subject to special requirements. Only approved commercial devices for safely puncturing cans could be used. These facilities would also be required to have written procedures for operations and maintenance of the machines, how incompatible wastes would be segregated, proper hazardous waste management practices to be followed, and what emergency spill procedures would be followed.

EPA’s intent is to ease the retailer’s burden of managing aerosol can as hazardous waste, ease the generators’ burden of managing aerosol cans as hazardous waste, and to encourage more states and more entities to recycle aerosol cans.

Gaps

There are still some gaps and unknowns within the regulations such as: What is the exact definition of an aerosol can, that is, would cans that do not aerate (such as shaving gel cans), be included? At what point between full, empty, “RCRA empty”, and used would the cans be eligible for universal waste consideration? Should there be a size limit on the cans; would cylinders be included? Would the equipment that some generators have already invested in to puncture and recycle their own cans be suitable under the new regulation?

EPA is accepting comments until May 15, 2018. To read more about the proposed regulation and where to send your comments, read here.

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Hazardous Waste e-Manifest System Coming in June

Hazardous Waste e-Manifest System Coming in June

Feb 8, 2018

EPA is establishing a nationwide electronic hazardous waste tracking system, and it hopes to have it up and running by June. The system will be known as e-Manifest, and will allow shippers to complete electronic manifests and destination/receiving facilities the opportunity to electronically upload manifests.

All states will be required to implement e-Manifest and incorporate it into their hazardous waste programs as an option. The system will be linked to RCRAInfo, a separate site which collects information on hazardous waste sites.

Right now, the using e-Manifest will be optional. Paper manifests will still be accepted from generators for the foreseeable future, and from destination/receiving facilities for up to three years. EPA hopes that by using electronic means, significant gains in cost, time, accuracy, notification, and monitoring effectiveness can be realized by all who use the system. Electronic manifests will be just as legal as paper ones, except they’ll be completed and signed electronically.

Using e-Manifest will satisfy EPA, RCRA and DOT 3-year recordkeeping requirements. EPA is also working with DOT to ensure e-Manifest will produce a proper shipping paper. DOT will still be requiring hard copies to be sent with the shipment, so those using e-Manifest will be able to print out a copy of their manifest for DOT purposes.

In the future, the e-Manifest system may link to the Biennial Hazardous Waste Report, and potentially replace it.

The fees for the system will be paid by the destination or receiving facility, which more than likely will be passed down to the generator. Fees will be per manifest, and fees for electronic manifests will be lower than the paper ones.

The target date for e-Manifest roll-out is June 30, 2018.

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Need Help?

Need guidance or support with hazardous waste? Do you have your required training and reporting complete?

Get Help Here

EPA is establishing a nationwide electronic hazardous waste tracking system, and it hopes to have it up and running by June. The system will be known as e-Manifest, and will allow shippers to complete electronic manifests and destination/receiving facilities the opportunity to electronically upload manifests.

All states will be required to implement e-Manifest and incorporate it into their hazardous waste programs as an option. The system will be linked to RCRAInfo, a separate site which collects information on hazardous waste sites.

Right now, the using e-Manifest will be optional. Paper manifests will still be accepted from generators for the foreseeable future, and from destination/receiving facilities for up to three years. EPA hopes that by using electronic means, significant gains in cost, time, accuracy, notification, and monitoring effectiveness can be realized by all who use the system. Electronic manifests will be just as legal as paper ones, except they’ll be completed and signed electronically.

Using e-Manifest will satisfy EPA, RCRA and DOT 3-year recordkeeping requirements. EPA is also working with DOT to ensure e-Manifest will produce a proper shipping paper. DOT will still be requiring hard copies to be sent with the shipment, so those using e-Manifest will be able to print out a copy of their manifest for DOT purposes.

In the future, the e-Manifest system may link to the Biennial Hazardous Waste Report, and potentially replace it.

The fees for the system will be paid by the destination or receiving facility, which more than likely will be passed down to the generator. Fees will be per manifest, and fees for electronic manifests will be lower than the paper ones.

The target date for e-Manifest roll-out is June 30, 2018.

iSi can help you with hazardous waste compliance — Contact us today!

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The New Hazardous Waste Generator Improvements Rule

The New Hazardous Waste Generator Improvements Rule

Apr 1, 2017

Called the “Hazardous Waste Improvements Rule,” EPA has issued updates and changes to its Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.

When: EPA has made over 60 changes which are geared to make technical corrections, clarify, increase flexibility and improve environmental protection. The changes will not go into effect until May 30, 2017, then every state but Iowa and Alaska will have until mid-2018 to implement and adopt (or not adopt) the less stringent requirements.

Consolidation of VSQG Waste at LQGs

EPA now allows very small quantity generators (VSQG, now the term for the former “conditionally exempt small quantity generator”) to consolidate waste at a large quantity generator (LQG) under the control of the same person. In some cases, organizations have satellite locations that qualify as a VSQG and could take advantage by consolidating together. VSQGs would need to mark and label their waste as “Hazardous Waste,” and indicate the hazards associated with the contents. LQGs would notify on the Site ID Form 30 days prior to receiving the waste that they are participating in this activity, who the VSQG is, maintain records for each shipment for 3 years, mark the accumulation units with the date the HW was received, manage consolidated waste as LQG waste and report in annual and biennial reports.

HW Determinations

  • Generator’s waste must be classified at its point of generation and at any time during the course of its management. Container markings and labels apply at the point of generation as well.
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Hazardous Waste Manifest Signers Need DOT Training

Hazardous Waste Manifest Signers Need DOT Training

Jan 15, 2013

Did you know anyone who signs a haz waste manifest on behalf of your company is required to have DOT training?

We come across many companies who have overlooked this important requirement, especially if their haz waste transporter is filling out all the paperwork for them.  Your hazardous waste is covered under EPA regulations, but once it’s sent for transportation, it becomes a hazardous material and is subject to DOT regulations.

Under DOT, your company is the shipper, not the hazardous waste transporter.  Even if the person signing the manifest doesn’t complete any of the shipping paperwork, (that is, if the transporter prepares it), as soon as he or she signs it, they become legally responsible for that shipment.  With their signature, they’re certifying everything has been packaged correctly, labeled correctly and that the forms have been filled out correctly.  Per DOT, this cannot occur without proper training.

Thus, in addition to hazardous waste training, the person signing your manifest needs DOT training.  This requirement can be satisfied through our Ground Hazardous Materials (DOT) Transportation course.  Visit our training page for dates, times and pricing.

iSi can help your company with haz waste and DOT compliance! Check us out!

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