What is a Toxic Release Inventory (aka TRI, SARA 313, Form R)?

What is a Toxic Release Inventory (aka TRI, SARA 313, Form R)?

Mar 26, 2024

What Is It?

TRI first came into existence in 1986 as part of the Superfund Amendments and Reauthorization Act (SARA) and Emergency Planning and Community Right-to-Know Act (EPCRA). TRI’s creation was influenced by an event in Bhopal, India in 1984 where a cloud of toxic gas from the Union Carbide chemical plant killed thousands. Then in 1985 a serious chemical release occurred to a similar chemical plant in West Virginia. EPA wanted a way for the public to learn more information about the chemicals used in their communities so it setup a reporting system for companies using potentially harmful chemicals above certain thresholds.

What’s the Difference Between TRI, Form R and SARA 313?

There are other names that are often used to refer to TRI reporting.

The first is “SARA 313.” TRI reporting is covered under Section 313 of SARA. Thus, TRI reporting is also referred to as “SARA 313” reporting. Other SARA reporting requirements include SARA 311 and 312 which are the Tier II chemical inventory reporting requirements we covered in our EPCRA Tier II blog, SARA 304 which is emergency spill reporting, and SARA 302 and 303 which cover emergency planning and notification requirements.

TRI reporting can also be known as “Form R” reporting. This is because one of the names of the forms used for TRI reporting is called Form R.

Reporting Criteria

In order to qualify for TRI reporting, your company must meet this criteria:

  • Employ 10 or more employees;
  • Fall under an identified NAICS code from the 2017 NAICS list; and,
  • Manufactures, processes, or uses a chemical on the TRI list of approximately 770 chemicals at a threshold above allowed levels. These chemicals have been identified as ones with significant effects to the environment or human health.  Chemicals are continually being added to this list.

2022 Updates

Due July 1, 2022:

  • All natural gas processing facilities that receive and refine natural gas are now subject to reporting.
  • Four PFAS chemicals have also been added:  silver(I) perfluorooctanoate (335-93-3), perfluorooctyl iodide (507-63-1), potassium perfluorooctanoate (2395-00-8), and 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,14-pentacosafluorotetradecyl 2-methyl-2-propenoate and 3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl 2-methyl-2-propenoate (65104-45-2).
  • 29 contract sterilization facilities now must estimate their quantities of ethylene oxide and/or ethylene glycol manufactured, processed or otherwise used to determine if they are subject to TRI reporting.

In the previous reporting year (due July 1, 2021), over 172 PFAS chemicals were added to the list of chemicals and the thresholds for these were significantly less than other chemicals.

Report Format

TRI uses two different forms for reporting, Form R and Form A.  First, you will use Form R to identify chemicals.  For the rest of the reporting, you need to continue with Form R or use Form A.  Form A is a shortened form and only available if your company meets certain criteria in type of chemical, quantity, and waste generated. If you don’t meet the criteria for Form A, then you must use the longer Form R.

A form (R or A) must be completed for each chemical you manufacture, process or use in quantities above the threshold.

How are TRI Reports Submitted?

TRI reports are completed federally through EPA’s TRI-MEweb website. You will need to make copies to submit to your state agency as well.

This information will become public information and be searchable in several online databases.

Supplier Notifications

Companies who process or manufacture chemicals or chemical mixtures are required to send annual supplier chemical notifications per EPCRA Section 313.  For more details on who and what that entails, check out our blog “Annual Supplier Notifications: Does This Affect Your Company“?

Have Questions? Need Help?

Do you need help with this environmental reporting requirement? iSi’s compliance team can help determine if you are required to submit and help you get the forms submitted. Contact us here for more information and pricing.

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Which Environmental Regulations Apply to Emergency Power Generators?

Which Environmental Regulations Apply to Emergency Power Generators?

Mar 17, 2024

Emergency power generators can be critical pieces of equipment for any facility, especially in the stormy seasons of spring or winter or in disasters such as floods and the hurricanes of summer and early fall. If you have one in your facility now, or are thinking about getting one, you need to be aware of the environmental regulations which are triggered by having one onsite.

EPA defines emergency generators as “…stationary combustion devices, such as reciprocating internal combustion engine or turbines that serve solely as a secondary source of mechanical or electrical power whenever the primary energy supply is disrupted or discontinued during power outages or natural disasters that are beyond the control or operator of a facility.” There are no time limits to using emergency generators during an emergency, but there are limits to the number of hours a generator can be used in non-emergency situations such as maintenance, testing, and other occasions such as offsetting electrical demand or to reduce electrical costs.

The bigger the generator, and the older the generator, the more likely environmental regulations will be triggered. The type of fuel used to power the generator also affects compliance. Generators can run on diesel fuel, gasoline, propane or natural gas.

The following environmental regulations may be triggered by your emergency generator:

Air Emissions

Emergency generators can have the potential to emit various air pollutants such as carbon monoxide, volatile organic compounds, xylene, carbon dioxide, sulfur dioxide, and others.

Depending on your state or local environmental regulations and the type of generator you have, you may need to prepare and file for an air permit whether it be a general permit, an operating permit, or a construction permit.

There are specific rules which govern the various types of generator engines. 40 CFR 60, Subpart IIII is for stationary compression ignition generators, 40 CFR 60, Subpart JJJJ is for stationary spark generators, and 40 CFR 63, Subpart ZZZZ applies to reciprocating internal combustion engines (RICE). Each regulation has strict operating guidance and compliance obligations.

Spill Prevention, Control and Countermeasures (SPCC)

If the fuel which you store onsite is in a tank with aboveground storage above 1,320 gallons, you will need to prepare an SPCC plan. SPCC Plans identify discharge prevention potential, discharge prevention measures and tasks, training, and the procedures to be followed if a spill does occur.

Emergency Planning and Community Right to Know Act (EPCRA)

If your fuel storage is above certain amounts, you will be required to conduct EPCRA annual reporting, chemical inventorying, and notifications. (For more information about EPCRA read our EPCRA blog article.)

Tank Certifications and Registrations

Aboveground and underground fuel storage tanks may need to be registered, permitted, inspected, and certified per state and local regulations.

PCBs

A potential for the presence of polychlorinated biphenyls (PCBs) can be found in any transformers, capacitors, electrical equipment, thermal insulation and motor/hydraulic oils. Cleanups, exposures and removals would need to be handled according to EPA’s PCB regulations.

Employee Exposure Issues

Though technically a safety issue, any backup generator which is brought into a facility could cause additional employee exposure issues. Before the use of generators, noise monitoring would need to be conducted to determine the potential noise exposures to employees in the area. Exhausts emitted from indoor generators may cause additional issues with employee exposure to chemicals, causing the need for engineering controls or additional employee personal protective equipment use.

Which Environmental Regulations Apply to Your Emergency Power Generator?

The regulations which apply to emergency power generators can vary greatly depending on style, type, model, your location, facility setup and other factors. What are your specific permitting requirements? Let iSi figure this out for you. Contact us for more information about environmental obligations, or ask us for a pricing quote to take a look at your situation.

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EPA Makes Final Rule to Update RMP Requirements

EPA Makes Final Rule to Update RMP Requirements

Mar 15, 2024

EPA has issued a change to its Risk Management Program, or RMP regulations for those who process, produce, handle or store hazardous substances or chemicals.  The changes are in an amendment to the rule, officially called the Safer Communities by Chemical Accident Prevention, or SCCAP.  These new rules hope to help increase protection for human health and environment from chemical hazards using lessons learned and process safety procedures.

First, What’s RMP?

RMP can be found in EPA’s Clean Air Act.  If you produce, process, handle or store one of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities, then you fall under RMP requirements.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

Water treatment plants, agricultural COOPs and chemical manufacturers are typical types of companies who need to comply with RMP.

RMPs must include:

  • Hazard assessments
  • Potential effects of a chemical accident
  • 5-year accident history
  • Evaluation of worst-case scenarios and alternative accident release potentials
  • Prevention programs that include safety precautions, maintenance, monitoring, and employee training measures
  • Emergency response program that lists emergency health care, employee training measures, procedures for informing the public.

RMPs are similar to OSHA’s Process Safety Management (PSM) standard, but RMP is concerned with protecting the environment and human health while PSM is focused on protecting the worker.  Unlike PSM, RMPs are directly submitted to EPA and information is input into a public database for transparency purposes.

Program Levels

A number of the changes are related to specific program levels of RMP.  There are 3 levels to RMP:

Program 1

Processes which would not affect the public in the case of a worst-case release and with no accidents with specific offsite consequences within the past five years.  These sites have limited hazard assessment and minimal prevention and emergency response requirements.

Program 3: 

This is for processes not eligible for Program 1 and are either subject to OSHA’s PSM standard or have one of 10 specified North American Industrial Classification System (NAICS) codes (NAICS code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532).  This program requires using OSHA’s PSM standard as your prevention program plus there are additional hazard assessment, management, and emergency response requirements.

Program 2:

If you don’t fit into Program 1 or 3, then you are a Program 2.  This program imposes streamlined prevention program requirements, as well as additional hazard assessment, management, and emergency response requirements.

The Rule Changes

Emergency Response

  • RMP facilities must develop procedures for informing the public about accidental releases.
  • Release notification data must be provided to local responders.
  • A community notification system must be in place for RMP-reportable accidents.
  • Field exercises must be conducted every 10 years unless local responders indicate that’s infeasible.
  • Emergency response exercises are to follow mandatory scope and reporting requirements.

Third-Party Compliance Audits

  • A third-party must do the next scheduled compliance audit when an RMP-regulated facility experiences two RMP-reportable accidents within five years or when a Program 3 facility under NAICS 324 or 325 has one reportable accident within one year AND that facility sits within one mile of another NAICS 324 or 325 process facility.

Program Requirements

  • Facility siting must be considered in Program 2 hazard reviews and Program 3 process hazard analyses.
  • When facilities have a reportable accident, a formal root cause analysis incident investigation must be conducted.
  • Program 2 hazard reviews and Program 3 process hazard analyses must now address natural hazards (including those resulting from climate change) and power losses.
  • Whenever a recommendation from a hazard evaluation, facility siting, or a third-party compliance audit is not adopted, a justification needs to be put into the RMP.

Employee Participation

  • Employee participation is required in resolving process hazard analyses, compliance audit and incident investigation recommendations and findings.
  • Employee participation is required for stop work procedures in Program 3.
  • Program 2 and 3 sites must provide opportunities for employees to anonymously report RMP accidents or issues of non-compliance.

Safer Technologies and Alternatives Analysis (STAA)

  • A STAA evaluation is required for all Program 3 NAICS 324 and 325 processes.
  • A Practicability assessment of inherently safer technologies and designs (IST/ISD) should be considered if your process falls within one of these conditions:
    • It’s a Program 3 under NAICS 324 and 325 within one mile of another Program 3 NAICS 324 or 325 process,
    • It’s a process under NAICS 324 using with hydrofluoric acid alkylation,
    • You’ve had one RMP accident since the facility’s most recent process hazard analysis.
  • Implement at least one passive measure at the facility, or IST/ISD, or a combination of active and procedural measures equivalent to or greater than the risk reduction of a passive measure for the same facilities required to conduct the practicability assessment.
  • When STAA recommendations are not adopted, then you must provide justification.

Communication

  • The facility must now provide chemical hazard information, upon request, to residents living within 6 miles of the facility in the language they request.

Other

  • Hot work permits must be kept for 3 years.
  • Program 2 and Program 3 requirements should be consistent for recognized and generally accepted good engineering practices.
  • Program 3 process safety info must be kept up to date.

Compliance Dates

The SCCAP is effective May 10, 2024.  There are two separate compliance dates.  Emergency response field exercise frequencies are due by March 15, 2027, or within 10 years of the date of an emergency response field exercise conducted between March 15, 2017 and August 31, 2022.

The following items are due three years after Final Rule publication (May 10, 2027)

  • Root cause analyses
  • Third-party compliance audits
  • Safer Technologies and Alternatives Analysis (STAA)
  • Employee participation
  • Emergency response public notification
  • Exercise evaluation reports

More Information

If you have questions or need assistance in determining if your facility is required to comply with RMP, or if you need help getting one setup, contact us!

Need Assistance?

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Which Annual Environmental Training Should You Add to Your Calendar?

Which Annual Environmental Training Should You Add to Your Calendar?

Jan 31, 2024

Recently we covered the required annual OSHA safety training requirements your company should be scheduling each year.  What about the most common annual EPA or environmental training requirements?

RCRA Hazardous Waste

Training is required for anyone handling or managing hazardous waste. For large quantity generators this training is required annually by federal regulations. For conditionally exempt small quantity generators and small quantity generators, annual training is not specified in the federal regulations but is considered a best practice.

Many states have their own hazardous waste regulations which can vary from the federal version and even be stricter, so be aware of the regulations for your area. For example, in Kansas, small quantity generators are specifically required to have annual training.

Stormwater Pollution Prevention Plan (SWP3)

Training is required annually for any facility required to have a Stormwater Pollution Prevention Plan, and in some locations, additional training may also be required. iSi did a stormwater training project for a client who had facilities in 48 states, and one of the modules we produced had a clickable state map where the learner could go learn about the rules for their state.   In our research, we found stormwater rules can vary greatly from state to state, and in some cases, from municipality to municipality.  State general permits have expiration dates on them and will be updated when the new one is issued, so check with your state’s environmental agency and find their general permit to see what the rules are.

[Don’t have time to look it up?  Contact us and we can get you pricing to have one of our environmental team members look up the most recent permit for your state(s) and determine what your requirements are, and what your training needs to cover.  (We can do the training too or make the slides for you if you need it.)]

Spill Prevention, Control and Countermeasures (SPCC)

Any company required to have an SPCC Plan must conduct training annually.  SPCC Plans ensure facilities have containment and other countermeasures in place to prevent oil spills from reaching navigable waters. Annual training is required for oil-handling personnel to ensure the prevention measures and procedures are in place, understood and followed.  This training should include the procedures and policies written in your SPCC plan.

Facility Response Plan (FRP)

FRPs are plans regarding oil spill responses after the spills occur. For those who are required to have FRPs in accordance with 40 CFR Part 112, there is training required as well as hands-on exercises. The National Preparedness for Response Exercise Program (PREP) is to be used for the hands-on portion and the U.S. Coast Guard’s Training Elements for Oil Spill Response can be used for the classroom training.

Qualified individual and emergency procedures exercises must be conducted quarterly, equipment deployment exercises must be conducted semiannually, and incident management team tabletop exercises must be conducted annually. There are additional requirements for unannounced and after business hour training.

This is different from HAZWOPER, which is an OSHA requirement, but you could incorporate some of the exercises as part of your annual HAZWOPER training.

Asbestos

Those certified as asbestos workers, contractor/supervisors, inspectors, planners and project designers are required to complete annual refresher training.

On the OSHA side, maintenance personnel who may disturb asbestos within the course of their duties are required to have annual awareness training. Although EPA addresses awareness training for these workers, it’s OSHA that requires the training annually.

Others Worth Mentioning

TSDF facility personnel must have RCRA emergency response training, and that training can be HAZWOPER if it meets the RCRA requirements. HAZWOPER refresher training is due annually.

There are other annual environmental training requirements for industrial processes which are not as widespread including municipal solid waste combustors, medical waste incinerators, and underground hazardous waste injection wells. Much of this training is also conducted by EPA or state-approved training providers.

Others Required, but Not Annually:

  • NESHAP Subpart HHHHH (6H) for Paint Stripping and Surface Coating Operations:  Every 5 years
  • Risk Management Plans: Every 3 years
  • Pesticides: Every 5 years
  • Lead-Based Paint (Lead Renovation, Repair and Painting Rule (RRP)): Every 3-5 years depending on the initial test you took
  • DOT (for hazardous waste manifest signing): Every 3 years
  • IATA (for air shipments of hazardous materials): Every 2 years
  • IMDG (for vessel shipments of hazardous materials): Every 3 years

Annual OSHA Safety Training

If you missed our blog on annual OSHA safety training needed, you can find that 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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2024 EPA and OSHA Compliance Deadlines

2024 EPA and OSHA Compliance Deadlines

Jan 5, 2024

It’s a new reporting year and time to plan for reporting and compliance deadlines from 2023’s activities and for the new year.  Mark your calendars with these environmental and safety reporting deadlines and other to-do tasks for 2024:

EPA/Environmental

 

OSHA/Safety

 

DOT/Transportation

State and Local Reporting Dates

There are other environmental and/or safety reports you must complete, but due dates may vary according to your state and local regulations or when your permits or reports were first completed.  Some examples include:

  • Title V Air Permits (Semi-Annual Compliance Certifications)
  • Hazardous Waste Reports
  • Wastewater Discharge Certifications and Monitoring Reports
  • Aboveground and Underground Storage Tank Registrations
  • Groundwater Monitoring Reports
  • Air MACT Certifications, Deviation Reports and Summary Reports
  • Stormwater Reports, Inspections and Sampling
  • Boiler Reports
  • X-Ray Equipment Registrations

Stay tuned to our blog for any updates or notices of new regulations.

Because environmental and safety regulations vary from state to state, city to city, there may be additional requirements for your company which are not listed above.  If you need assistance in determining which of these apply to you, or assistance with completing these reports and permits, iSi would love to help!  Please contact us 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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EPA Looks to Add Air Emissions Reporting Items

EPA Looks to Add Air Emissions Reporting Items

Aug 18, 2023

EPA has announced a several changes to its Air Emissions Reporting Rule, or AERR that would make reporting of hazardous air pollutants (HAPs) consistent from state to state, add electronic reporting of stack tests, decrease and standardize emissions thresholds, create earlier reporting deadlines, and add new point sources to reporting requirements.

All of the changes EPA is considering making is to help the agency comply with the presidential commitment to enhance environmental justice by gathering more detailed location-specific information.

HAP Reporting

Per the AERR, industry is already required to report emissions of common or criteria pollutants and the pollutants that form them, called precursors.  Right now, the federal rule doesn’t require HAP reporting, but some states require reporting and voluntarily give this information to EPA.  Not all states do, and not all Indian lands do either.  For the ones that do, the rules can vary greatly from state to state.

The new rule would make HAP reporting standard for all facilities in all states who are:

  • Major sources per Clean Air Act operating permits;
  • Non-major sources who were in a certain industry emitting HAPS at or above a certain threshold;
  • Indian lands; and,
  • Offshore deep water ports.

Facilities would also be required to provide other details and data about HAPs from their stack test and performance evaluations.  EPA would like these to be reported electronically through the Consolidated Emissions Data Reporting Interface (CERDI).

To help states find a way to make reporting this data to EPA be more streamlined without the need to create their own separate data collection programs, EPA would like for states to develop procedures to have industry use the online Combined Air Emissions Reporting System, or CAERS system.  CAERS is already in use for reporting National Emissions Inventories and Toxic Release Inventories (TRI).  EPA even hopes to work towards eventually using CAERS to gather Greenhouse Gas Reporting (GHG) data and incorporate the CERDI as well.

The new rule would start in 2027.  This is because states have told EPA it can take two to three years for them to change their air emissions regulations.  EPA also says time it can take states to migrate from their current systems to CAERS could be one to three years as well.

Shorter Deadlines

The proposed rule looks to make states work faster to get this data to EPA.  Right now, states have 12 months after the end of the reporting period to turn in inventory data.  That is, the reporting period ends on December 31, and EPA has until December 31of the following year to turn it in to EPA after receiving it from industry much earlier than that. Starting in 2027, state inventory data would be due to EPA by September 30 and starting in 2030, data would be due by May 31.

Many states already turn in their collected inventory data sooner than that 12-month deadline, but shortening the due dates may force all states to go to electronic systems and may cause some of them to move up due dates for industry.

If EPA’s goals of using CAERS for multiple emissions reports, EPA speculates the possibility arises industry may eventually see one consolidated deadline for all reports rather than the current tiered deadlines of GHG reports due March 31, some air emissions reports due May 31 and TRI reports due July 1.  Another possibility to help alleviate stress in the deadlines in this case would be for industry to potentially report some data directly to EPA rather than go through the state.

EPA is currently seeking comments about the timing of the phase in deadlines and EPA wants feedback on these potential scenarios.

Standardized Emissions Thresholds

Under the current AERR rule, states report data on criteria pollutants and precursors that exceed certain thresholds.  The thresholds are setup to be different each year over a triennial cycle. That is, they are higher in the first two years and then lower in the third year.  On that third year, more facilities end up qualifying for reporting.  The new rule would make the threshold the same each year.  That would be the lower year 3 emissions threshold, causing more facilities to need to report every year.  HAP thresholds would be the same each year as well.

Small Generating Unit Emissions Data Included

Some facilities use small generating units to help meet demand on high electricity demand days or use them to supplement their own electricity.  EPA wants to make these a new source reporting requirement, taking daily data such as fuel use or heat input.  EPA says that when facilities use a number of these at one time, the units can significantly add to ozone formation through emitting of nitrogen oxides and particulate matter.

Currently, emissions for these are reported as an annual, not daily, emissions value and only if they’re located at a point source.  If they’re not located at a point source, they aren’t tracked at all.  The new rule would track all of them at all facilities.

Prescribed Fire Data

The proposed rule would also add the requirement for state, local and tribal forestry agencies to report daily activities associated with prescribed fires on state, tribe, private, or military lands.  This would include fires affecting more than 50 acres where there is forest canopy present (understory fire) or where there is little forest canopy like a grassland or oak woodland fire (broadcast fire), or pile burns of 25 acres or more.

Agricultural fires, land clearance fires and construction fires would not be included.

Comments Period

The public is invited to comment on the proposed rule up until October 18, 2023.  You can find the entire rule HERE.

Need Help Sorting This Out?

If you have questions about air emissions reporting in general, anything discussed in this article or this proposed rule, or need help getting your environmental reporting taken care of, we’re here to help!  Contact iSi today!

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Does this new change pertain to your company? Our team can help you figure it out and can help with other air compliance issues.

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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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The Importance of Water Audits: A Comprehensive Guide

The Importance of Water Audits: A Comprehensive Guide

Mar 29, 2023

What Is a Water Audit?

A water audit is a systematic examination of all aspects related to water use and efficiency in a given facility. It involves measuring, monitoring, and analyzing water use patterns to identify opportunities for improved water efficiency. This term is often used by water auditors, professionals who specialize in conducting these assessments.

The Role of the International Water Association (IWA)

The IWA is a global network of water professionals striving towards a water-wise world. They advocate for effective water management practices, including the need for regular water audits. They emphasize that understanding water usage patterns is key to achieving sustainable water management.

Why Are Water Audits Important?

Water audits are essential tools for commercial and institutional facilities seeking to conserve water and reduce costs. They provide valuable insights into a facility’s water use, helping to identify inefficiencies and opportunities for improvement.

The Role of a Certified Landscape Irrigation Auditor

A certified landscape irrigation auditor is a professional who evaluates irrigation systems to ensure they are operating efficiently. They play a crucial role in the annual water audit, particularly for facilities with extensive landscapes.

Understanding Regional Water Resources Agencies

Regional water resources agencies are responsible for managing and protecting local water resources. They often provide free water audit software to help businesses and organizations conduct their own audits. These tools can be invaluable for entities attempting to improve their water efficiency.

Achieving Water Efficiency through Water Audits

Water audits are a critical step towards achieving water efficiency. By identifying leaks, inefficient appliances, and wasteful behaviors, audits enable facilities to take targeted action to reduce water use.

Landscape Irrigation Water Use

Landscape irrigation can be a significant contributor to a facility’s water use. A basic irrigation schedule, recommended by the Irrigation Association, can help manage landscape irrigation water use effectively.

The Role of Water Utilities

Water utilities are responsible for supplying clean, safe water to the community. They often offer a water loss control program to help customers reduce their water usage and lower their bills.

Digging into Water Audit Data

Water audit data provides a wealth of information about a facility’s water use. This data can reveal patterns and trends, helping to identify areas where water efficiency can be improved.

Understanding the Water Audit Method

The water audit method involves collecting data on water use, analyzing this data, identifying inefficiencies, and recommending improvements. This method can be carried out by a professional water auditor or using free water audit tools provided by water utilities.

The Benefits of a Free Water Audit

Many water utilities offer free water audits to their customers. These audits can provide valuable insights into a facility’s water use and identify opportunities for cost savings.

Managing an Irrigation Project

An irrigation project, such as upgrading an existing system or installing a new one, can significantly impact a facility’s water use. An audit can ensure that the project is designed and implemented with water efficiency in mind.

The Future of Water Audits

As water scarcity becomes an increasingly pressing issue worldwide, the importance of water audits is set to grow. With the support of organizations like the IWA and regional water resources agencies, water audits will continue to play a key role in promoting sustainable water use.

In conclusion, water audits are a vital tool for managing water use effectively. By identifying areas of inefficiency and recommending targeted improvements, they enable facilities to conserve water, reduce costs, and contribute to a more sustainable future.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilities looking for help navigating the often perplexing regulatory landscape, contact us today!

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What is a Phase II Environmental Site Assessment?

What is a Phase II Environmental Site Assessment?

Feb 17, 2023

What is a Phase II?

A Phase II Environmental Site Assessment (ESA) is an in-depth procedure conducted by a environmental professional to confirm the presence or absence of suspected contaminants.

This assessment typically follows a Phase I ESA and involves more intensive methods such as soil, groundwater, or building materials sampling and laboratory analysis.

Phase II ESAs are essential when dealing with properties that may have been affected by hazardous substances. The environmental site assessment process provide a detailed understanding of the environmental conditions at a site and act as a critical tool in managing potential liabilities associated with contamination. Conducting an environmental site assessment is a staple of a companies environmental due diligence.

What’s the Difference Between a Phase I Environmental Site Assessment and Phase II Environmental Site Assessment?

While both assessments aim to evaluate potential environmental risks associated with a property, their methodologies differ significantly.

Phase I environmental site assessments are essentially a preliminary study. It involves a detailed review of historical records and a visual inspection of the property to identify potential environmental risks. This phase does not involve any physical testing or sampling.

Instead, it focuses on identifying ‘Recognized Environmental Conditions’ (RECs) that indicate the possible presence of contamination on the site.

On the other hand, a Phase II assessment is a more detailed and hands-on investigation. It is triggered when RECs are identified during the Phase I assessment. Phase II involves actual sampling and testing of soil, groundwater, or building materials to confirm if suspected contaminants exist at concentrations above regulatory limits.

When Do I Need a Limited Phase II ESA?

A Limited Phase II ESA is often required when the Phase I ESA identifies potential environmental risks, but the suspected contamination is localized to specific areas of the site.

This more focused assessment is less extensive — and thus less costly — than a full Phase II ESA but still provides valuable insight into potential environmental liabilities. It involves targeted sampling and analysis based on the findings from the Phase I ESA.

Who Pays For A Phase 2 ESA?

Typically, the party who stands to benefit from the information generated by a Phase II ESA is responsible for its cost.

This could be a prospective buyer who wants to ensure they are not acquiring contaminated property, a current property owner seeking to understand their liability, or a lender requiring assurance on the environmental status of a property before approving a loan.

In some cases, the cost may also be negotiated between the buyer and seller as part of the property transaction process.

How Long Does a Phase 2 ESA Take?

The duration of a Phase 2 ESA can vary depending on several factors. These include the size and complexity of the site, the number of samples taken, and laboratory turnaround times for sample analysis. On average, a Phase II ESA can take anywhere from a few weeks to a couple of months to complete.

How Much Does a Phase 2 Environmental Study Cost?

The cost of a Phase 2 ESA varies widely based on the scope of work required. Factors influencing the cost include the size and complexity of the site, the type and number of samples, and the analytical methods used. It can range from a few thousand dollars for a Limited Phase II ESA to tens of thousands for a more complex site.

What Is The Final Goal of a Phase 2 Assessment?

The ultimate goal of a Phase 2 Assessment is to provide a clear understanding of the environmental conditions at a site. The findings from a Phase II ESA can significantly impact property transactions, lending decisions, and redevelopment plans.

If contamination is confirmed, it may necessitate remediation under local, state, or federal regulations. By identifying these issues early, businesses can proactively manage potential liabilities and avoid unexpected costs and delays.

Conclusion:

In conclusion, a Phase II Environmental Site Assessment is a critical tool in managing environmental risks. This environmental assessment provides a detailed understanding of the recognized environmental condition at a site, helping stakeholders make informed decisions and potentially avoid significant future liabilities.

Although the process may seem daunting, it is a crucial step towards ensuring the safe and responsible use of land.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance.

We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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EPCRA Tier II: Does the March 1 Deadline Apply to Your Facility?

EPCRA Tier II: Does the March 1 Deadline Apply to Your Facility?

Feb 15, 2023

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. This is a federal requirement, but each state has its own nuances in method of submittal, what’s required with the submission and who to send it to. For reporting, EPCRA has a Tier I form and a Tier II form. The Tier II has all of the information Tier I does, but with more detail, so many states just require the more complete Tier II form.

Does This Apply to My Facility?

First, all chemicals you’re required to keep a Safety Data Sheet (SDS) for per OSHA requirements are subject to reporting. Next, determine if the quantities on-site at any one time last year met the threshholds for reporting.

Extremely Hazardous Substances listed in 40 CFR part 355 Appendix A and Appendix B, the reporting quantity is 500 pounds or the amount of the Threshold Planning Quantity (TPQ), (whichever is lower). Gasoline and diesel fuel at retail gas stations have their own individual requirements. For all other hazardous chemicals, the threshold is 10,000 pounds.

There are a few exclusions per EPCRA for food, food additives, drugs, cosmetics, substances for general/household purposes for use by the general public, fertilizer sold to farmers, and substances used by research labs and hospitals.

Information Collected

Each state has its own requirements, but the information reported is very similar. Some examples of information you’ll need to gather include:

  • SDS for Each Chemical
  • Facility Information
  • Emergency Contacts and Contacts Knowledgeable of Tier II Information
  • Physical and Health Hazards
  • Chemical Descriptions
  • Maximum Amount Present on any Single Day During Reporting Period
  • Average Daily Amounts (Weights)
  • Number of Days Onsite
  • Storage Types, Conditions and Locations

Reporting

Each state varies on how the information is reported then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1.

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iSi can help you determine your applicability, what your state requires and then help you complete the Tier II reporting elements. Contact us today for a pricing quote!

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Mar. 1 will be here soon — Let iSi take care of this requirement for you!

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Need Help?

Mar. 1 will be here soon — Let iSi take care of this requirement for you!

Get Help Here

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report emergency and hazardous chemical information each year to their state and local emergency response officials and local fire departments. This is a federal requirement, but each state has its own nuances in method of submittal, what’s required with the submission and who to send it to. For reporting, EPCRA has a Tier I form and a Tier II form. The Tier II has all of the information Tier I does, but with more detail, so many states just require the more complete Tier II form.

Does This Apply to My Facility?

First, all chemicals you’re required to keep a Safety Data Sheet (SDS) for per OSHA requirements are subject to reporting. Next, determine if the quantities on-site at any one time last year met the threshholds for reporting.

Extremely Hazardous Substances listed in 40 CFR part 355 Appendix A and Appendix B, the reporting quantity is 500 pounds or the amount of the Threshold Planning Quantity (TPQ), (whichever is lower). Gasoline and diesel fuel at retail gas stations have their own individual requirements. For all other hazardous chemicals, the threshold is 10,000 pounds.

There are a few exclusions per EPCRA for food, food additives, drugs, cosmetics, substances for general/household purposes for use by the general public, fertilizer sold to farmers, and substances used by research labs and hospitals.

Information Collected

Each state has its own requirements, but the information reported is very similar. Some examples of information you’ll need to gather include:

  • SDS for Each Chemical
  • Facility Information
  • Emergency Contacts and Contacts Knowledgeable of Tier II Information
  • Physical and Health Hazards
  • Chemical Descriptions
  • Maximum Amount Present on any Single Day During Reporting Period
  • Average Daily Amounts (Weights)
  • Number of Days Onsite
  • Storage Types, Conditions and Locations

Reporting

Each state varies on how the information is reported then given to emergency officials. Some states require electronic reporting, others may require you to send it directly to your state emergency response commission, your local emergency response commission and the fire department with jurisdiction over your facility. Check out your state requirements here. Reporting is due March 1.

Need Help?

iSi can help you determine your applicability, what your state requires and then help you complete the Tier II reporting elements. Contact us today for a pricing quote!

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EPA Proposes Changes to Air Permitting Regulations for New Sources

EPA Proposes Changes to Air Permitting Regulations for New Sources

Dec 15, 2022

Companies with operations subject to the Clean Air Act are required to submit their plans for any operational or physical changes before they occur to see if they’ll have a significant affect on air quality.  This program is called the New Source Review preconstruction permitting program, or NSR program.  EPA is making some changes in the way fugitive emissions are figured into the equation to determine if the changes to existing sources will be considered a major modification to the company’s air permit.

 

The NSR Program

EPA’s NSR program wants to make sure that a company’s changes will not significantly affect air quality of the area.  In the U.S., there are cities and regions that have air quality levels that are above EPA’s National Ambient Air Quality Standards. These areas are called “non attainment” areas and industries in those areas have additional rules, regulations and restrictions they need to follow as a result.  In other cities and regions that are still below the national standards, EPA wants to make sure a company’s changes don’t significantly deteriorate the area’s compliance so that they can stay below non attainment.  This program is called the Prevention of Significant Deterioration, or PSD program.

The NSR program looks to see if your new operations will become a new major source of air pollution, or if any changes to your current major source permit would be considered a major modification, depending on certain thresholds.

 

Fugitive Emissions

When making this determination, EPA counts fugitive and stack (non-fugitive) emissions.  A fugitive emission is one that could not reasonably pass through a stack, chimney, vent, or similar opening.

Historically, for new sources to become new major sources, only certain type of sources belonging to a specific list would have to count fugitive emissions toward the threshold.

Existing sources would have to count both fugitive and non-fugitive (stack) emissions.  However, in 2008, EPA finalized a rule for existing sources that would also allow them to only count fugitive emissions only for certain types of major sources belonging to specific categories.

 

The Proposed Changes

The specific categories of sources that had to count fugitive emissions were petroleum refineries, large fossil fuel-fired steam electric plants, and Portland cement manufacturers.  Everyone else was not required to include fugitive emissions.

However, EPA wants to repeal that 2008 rule for major modifications.  Now, all existing major sources would need to count fugitive emissions toward the major modification thresholds.

Anytime a company’s changes are considered a major modification, they need to obtain a major NSR permit before moving forward with construction. The permit will require emission control measure to ensure that changes won’t degrade air quality.

Another change that EPA is proposing is to remove a provision established in 1980 that exempts certain stationary sources from substantive major NSR requirements if the only reason the change is considered a “major modification’ is because fugitive emissions are included.

 

Upcoming Changes at Your Facility? What’s Your Air Compliance Status?

Are you considering a major change to your operations or equipment that will affect your air compliance status?  Do you need help with construction air permitting or making determinations on what your air quality compliance requirements are?  Let our team of air permitting experts assist you!  Contact us today!

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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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Mining Testing

Mining Testing

Oct 27, 2022

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What is it?

Mining testing is a process that helps evaluate the safety, productivity, and environmental impact of mining operations, mining services, and the mine site. It involves collecting data from various sources such as geological surveys, graphical analysis, borehole drilling tests, hydrogeological studies, geophysical surveys and laboratory testing to ensure the quality and sustainability of mining projects.

This type of testing helps identify potential risks before proceeding with large-scale mining operations, helping to ensure that the safety of miners and environment is protected in the mining industry. Additionally, it also helps identify resources that are economically viable for extraction.

Mining testing is an essential part of any successful mining venture and is carried out by experienced professionals with specialized knowledge in order to maximize success. This testing should be used in any mine planning as any good mining engineering professional would advise.

What are the different types of mining tests?

Mining tests are used to assess potential mining sites and the quality of ore they contain. These tests can identify if a particular rock or mineral is economically viable for extraction, as well as provide information about the environmental impact of a particular mining operation.

There are several types of tests commonly used in the industry including geophysical surveys, chemical analyses, drill core sampling, and exploratory mining. Geophysical surveys use various techniques such as magnetometers, gravimeters, and seismic reflection to identify subsurface structures that may contain economically valuable ore. Chemical analyses involve taking samples from the site for laboratory analysis to determine the mineral content of an ore body.

Drill core sampling involves taking cylindrical samples of rock from different depths in order to determine the grade of ore as well as to determine overall mineral composition and structure. Exploratory mining or underground mining proposed by exploration companies involves digging trial pits or tunnels in order to gain a better understanding of the deposits present at a particular site. Each of these tests can provide important information for successful mining operations, allowing companies to make decisions that will maximize their profits while minimizing environmental impacts.

How do you test for mineral content?

Mineral content in water is tested using a variety of methods. A common method is to use colorimetry, which involves measuring the amount of light absorbed by different chemical compounds in the sample being tested. Another way to test mineral content is through ion-selective electrodes, which measure the electrical potential between two points and can be used to identify certain ions or minerals present in the sample.

X-ray fluorescence spectroscopy is also used to detect and quantify minerals in water samples, as it looks for the presence of specific chemical elements. Finally, Inductively Coupled Plasma Mass Spectrometry (ICP-MS) can be used to measure trace levels of minerals in a sample by analyzing the frequencies emitted by different particles.

What do MSHA (Mine Safety & Health Administration) inspectors look for?

MSHA inspectors are responsible for ensuring the safety and health of miners in the workplace. They look for a variety of conditions to ensure miners are following safety regulations, such as checking ventilation systems, guarding against hazardous machinery, inspecting electrical equipment, and monitoring fire risks. They also take into account worker practices like wearing personal protective equipment, using approved methods for lifting heavy objects, and following all regulations and guidance. This work practices should be spearheaded by company management which provides extensive training for employees.

Furthermore, MSHA inspectors review records of workplace illnesses and injuries to identify underlying safety issues that need to be addressed. Finally, they observe work areas to make sure miners are aware of hazards and have the necessary tools and equipment to do their jobs safely. MSHA inspectors play an important role in safeguarding the health and safety of miners.

What does a mining consultant do?

A mining consultant, also known as a mineral engineer or natural resources specialist, is responsible for helping companies and organizations extract the maximum value from their mining operations. They work closely with clients to assess and analyze geological data in order to develop cost-effective production plans that take into account environmental protection decisions. Mining consultants may also be tasked with developing mine reclamation plans, assisting with feasibility studies, monitoring safety and compliance issues, and providing expert testimony in legal proceedings.

In addition, they may be called upon to provide environmental consulting services for mining projects, advise on policy development related to the industry, and conduct research on new technologies and processes that could improve extraction practices. As such, mining consultants play an important role in helping organizations maximize their returns while promoting sustainable mining practices.

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Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

Oct 16, 2022

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When it comes to environmental health and safety (EHS) audits, having a comprehensive checklist is essential. Audits are designed to show the effectiveness of an organization’s existing EHS management system as well as identify any areas that need improvement. A good audit will be comprehensive in scope and include elements such as environmental compliance, risk assessment, occupational safety, air quality monitoring, and emergency preparedness.

The challenge for many organizations is creating or finding an EHS audit checklist that covers all the necessary elements. To help get you started, we’ve put together a comprehensive guide to mastering the essential EHS audit checklist. This guide will provide you with everything you need to know about best practices and key components of successful EHS audits.

First, you’ll want to make sure that your EHS audit checklist is aligned with the organization’s goals and objectives. A comprehensive checklist should include all of the basic elements that are required by law or identified within the scope of an organization’s operations. This includes ensuring compliance with national and local environmental regulations, assessing workplace safety risks, monitoring air quality on site, and preparing for emergency situations.

Next, you’ll need to consider how often audits will be conducted. Depending on the size and complexity of the organization’s operations, this could range from once a year to multiple times per year. It may also be necessary to conduct periodic follow-up audits in order to ensure that any changes or improvements made since the last audit are still in place.

Finally, when conducting an audit it’s important to document everything that is found. This includes any potential hazards and exposures, compliance issues, and recommendations for improvement. Having a comprehensive audit report is essential for making sure that all corrective actions are properly implemented and tracked over time.

By following the above steps and having a detailed EHS Audit checklist in place, you can ensure that your organization is meeting all of the necessary standards for environmental health and safety. With the proper preparation and planning, you can have confidence that your audits will yield accurate results and provide you with the actionable insights needed to make improvements where necessary.

EHS Audit Checklist Templates

EHS audit checklists are an invaluable tool for organizations to ensure their health and safety processes are in line with industry standards. They help organizations identify potential risks, areas of improvement, and areas that need additional attention. EHS audit checklist templates provide a consistent structure for conducting audits and allow the organization to easily evaluate compliance across multiple departments and locations.

With the use of these templates, organizations can quickly identify which areas require further action or review. In addition, using an EHS audit checklist template ensures that all essential elements required for a successful safety program are included in the assessment process. This helps to ensure that any issues identified during the audit can be addressed in a timely fashion and prevents any unnecessary delays that could put workers at risk.

Who needs to use a health and safety audit?

A health and safety audit is necessary for any workplace, no matter the size or industry. It is important to make all employees aware of what measures need to be taken to reduce risks in the workplace.

Employers and business owners should use audit findings to ensure that their employees are safe from potential hazards. Additionally, supervisors and managers should also regularly monitor the implementation of safety protocols as part of a comprehensive risk management plan. The ultimate goal is to create an environment where everyone can work productively with minimal risks and hazard exposure. This includes providing appropriate protective gear for all employees as well as have all employees trained on safety policies.

By conducting regular audits, employers not only make sure their workers are well protected but also demonstrate good corporate citizenship towards regulatory authorities. Furthermore, these reviews may help identify areas of improvement so that effective preventive measures can be put in place. In sum, anyone with a stake in the safety and well-being of employees should incorporate health and safety audits into their overall risk management strategy.

EHS Audit Software:

EHS Audit Software is an essential tool for Environmental Health and Safety (EHS) professionals to monitor and ensure compliance with regulations. It automates the auditing process, providing insight into risk areas and helping organizations improve their processes.

EHS Management Software provides a comprehensive interface to facilitate efficient data collection, tracking and reporting of regulatory compliance-related activities. This makes it easier to identify deficiencies in safety protocols, quickly address potential hazards, and take proactive steps to mitigate future risks.

With the help of this software, organizations can ensure that they provide a safe workplace environment for all employees while minimizing both environmental impacts and financial costs associated with non-compliance.

EHS Audit Management Software Benefits

EHS Audit Management Software Benefits provides organizations with powerful tools to streamline their environmental, health and safety auditing processes. It helps them save time and resources while ensuring compliance with local regulations, industry standards, and best practices.

The software allows for automatic scheduling of audits and tracking of results, which can help identify gaps in safety protocols more quickly. This ultimately helps to reduce the risk of accidents, environmental damage, and costly fines. With centralized data storage and reporting capabilities, it also enables organizations to track their compliance progress over time, enabling them to continually strive for excellence in safety.

EHS Audit Management Software Benefits is a powerful tool that can help organizations protect their employees, customers, and environment while ensuring compliance with all relevant regulations.

Pre-Audit Phase

The Pre-EHS Audit Phase or audit planning is an important part of the overall Environmental, Health & Safety (EHS) audit process. During this phase, a company will assess its current EHS operations and compliance in order to identify any areas that may present possible risks or noncompliance issues.

This helps ensure the organization meets all applicable regulations and safety requirements, and helps reduce potential liability risks when an EHS auditor arrives. During the Pre-EHS Audit Phase, organizations often review their compliance records and processes, evaluate current systems, develop new procedures and protocols as needed, and produce a detailed report of findings.

This helps ensure the organization is properly prepared for the actual EHS audit itself. The Pre-EHS Audit Phase is essential to ensuring organizational safety and compliance with all applicable laws and regulations.

An effective Pre-EHS Audit Phase also helps an organization identify potential risks and areas of improvement before the actual audit begins. Through this assessment, organizations can develop specific strategies to improve their safety and compliance operations going forward, as well as develop plans for problems that may arise during the EHS audit itself.

What should be included in a health and safety audit checklist?

A health and safety audit checklist should include items that are relevant to the particular work environment being audited. This can vary depending on whether the workplace is an office, factory, warehouse, or other premises.

Generally, items that should be included in a health and safety audit checklist would be physical hazards such as trip/slip risks, poor lighting conditions, inadequate ventilation, and hazardous substances. Additionally, potential health risks such as noise levels, temperature/humidity levels, ergonomics, and the availability of safety wear should be considered.

All employees should also have access to first-aid kits and emergency procedures in case of accidents or incidents. Finally, employers should consider if necessary protective measures are in place to protect employees from violence or harassment. By including these items in a health and safety audit checklist, employers can ensure that their workplace is safe and compliant with relevant regulations.

What is a health and safety audit?

A health and safety audit is an independent assessment of a workplace to assess how well it complies with relevant laws, regulations, and industry standards. It evaluates existing practices and procedures in the workplace to make sure they are working properly and efficiently.

The aim of a health and safety audit is to identify any potential hazards or risks that could lead to injury or illness, as well as any areas where improvement is needed. A health and safety audit can help organizations meet their legal obligations and ensure the workplace remains safe and healthy for everyone.

It can also provide important data that can be used to develop effective strategies to reduce accidents, incidents, and other risks in the workplace.

Deficiencies and Corrective Actions

EHS corrective actions are an important part of creating a safe and healthy working environment. These corrective steps involve identifying workplace health and safety hazards, addressing the risks associated with those hazards, and taking steps to eliminate or mitigate any potential harm to workers and the environment caused by these hazards.

Corrective actions can include changing procedures, providing additional training, implementing new rules or regulations, or carrying out engineering modifications to equipment and machinery.

It’s important for employers to take corrective steps in order to protect their workforce, comply with regulations, and ensure a safe working environment. By taking corrective actions, employers can reduce the risk of injury and illness caused by workplace hazards.

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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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Environmental Protection Agency (EPA) Audit Policy

Environmental Protection Agency (EPA) Audit Policy

Sep 4, 2022

United States Environmental Protection Agency Audit Policy: 101

The Environmental Protection Agency (EPA) is committed to protecting and preserving the environment for all of us, which means ensuring that businesses across the country are following EPA policies. To do this, the agency performs audits on companies in order to ensure compliance with EPA standards.

This includes checking documents and records, sampling chemicals and other materials, evaluating waste management practices, testing equipment, observing production processes, interviewing employees, etc. The goal of each audit is to identify any potential violations or areas of non-compliance with the law.

After completing an audit, the EPA will issue a report outlining its findings and recommendations. Typically, the report will include areas of non-compliance, along with suggestions for corrective action to ensure compliance in those areas. Companies are then required to submit a written response to the audit and provide evidence that steps have been taken to address any issues identified by the EPA.

It is important for companies to be aware of their responsibility and obligation when it comes to environmental protection. The Environmental Protection Agency Audit Policy provides businesses with an opportunity for self-evaluation and proactive strides towards ensuring compliance with all relevant regulations and laws. As such, it is essential that companies remain up-to-date regarding changes in policy or procedure, regularly review their operations and practices, and work diligently to resolve any violations or problems discovered during audits. By doing so, companies can help to ensure a safe and healthy environment for everyone.

An important part of the Environmental Protection Agency Audit Policy includes being able to respond effectively to any audit report issued by the agency. Companies should contact an environmental attorney who is knowledgeable about the requirements outlined in the EPA’s Audit Policy, as well as any applicable state or local laws that may be relevant. In addition, they should develop a detailed plan of action outlining how they intend to resolve any issues identified during an audit and provide evidence of their compliance with all applicable standards. By doing so, businesses can help demonstrate their commitment to protecting the environment and set a positive example for others in their industry.

At the end of the day, businesses have a responsibility to protect the environment and ensure compliance with all applicable laws. Companies who take advantage of this policy are helping to set a positive example for others in their industry and create a healthier future for everyone.

EPA’s Interim Approach to Applying the Audit Policy to New Owners | US EPA

The Environmental Protection Agency (EPA) has developed an Interim Approach to Applying the Audit Policy to New Owners, which provides tailored incentives for new owners of facilities that have been found to be non-compliant with environmental laws prior to acquisition. This approach allows new owners to make a “clean start” by addressing any noncompliance that began before they obtained ownership of the facility.

This Audit Policy incentives include compliance assistance and technical advice, potential reduction in penalties and civil enforcement actions, reimbursement for environmentally beneficial projects, and protection from certain criminal prosecution related to pre-acquisition violations. These incentives are designed to encourage responsible parties at newly acquired facilities to address existing noncompliance issues quickly and effectively through voluntary disclosure or corrective action. By taking advantage of EPA’s Audit Policy incentives, new owners can ensure compliance with environmental statutes and make a fresh start.

What are the benefits of an EPS audit?

The EPA believes that having audits conducted allows organizations to make better-informed actions, optimize performance levels, and ensure sustainable success over the long term..

An EPS audit is a valuable tool for assessing the financial health of an organization. It provides an objective overview of a company’s performance and can help identify areas where improvements or corrective actions may be needed. An EPS audit can also serve as an key preventative measure, providing insight into potential problems before they become catastrophes.

At the same time, it can help to enhance processes and procedures that are already in place by giving management a comprehensive look at their current operations and financial position.

What types of companies are required to perform and environmental audit?

Environmental audit reports are useful to a variety of businesses and industries, local, state and federal government facilities, as well as financial lenders and insurance companies that need to assess environmental performance. Audit reports can be extremely useful for businesses, governments, and financial lenders in understanding the environmental performance of a given facility. They provide detailed information on air emissions, water usage, waste management systems, hazardous materials management practices and storage procedures.

This data is key to ensuring that facilities are meeting regulatory requirements and following industry best practices. Additionally, environmental audit reports may be necessary to meet contractual requirements with customers or other third parties. Finally, financial lenders may use these reports to assess risk associated with a particular project or investment opportunity in order to make informed decisions on whether to lend money or not. Ultimately, environmental audit reports are an essential part of ensuring continual compliance as well as business sustainability.

Who conducts EPA audits?

EPA audits can be conducted by internal auditors, external auditors, and third-party verification organizations.

Internal auditors usually have knowledge and expertise in the specific area being audited, such as environmental protection, energy efficiency or sustainability. External auditors are independent third-party experts who assess and evaluate compliance with EPA ordinances Finally, third party verification organizations provide impartial assessments to verify the effectiveness of an organization’s systems for meeting specific standards. Each type of audit provides its own unique benefits, ensuring that thorough and comprehensive evaluations of facility operations take place.

Through careful review and assessment of procedures, policies and practices, these audits ensure that organizations remain compliant with EPA statutes.

How often are EPA audits required?

Once every three years.

According to the regulations at 40 CFR §§68.58(a) and 68.79(a), owners or operators must certify that they have completed a compliance evaluation of their prevention program every three years in order to ensure that established procedures and practices are adequately maintained and followed.

This process requires the tangible review of all applicable documents, including but not limited to safety protocols, emergency response plans, operating manuals, training records, inspection reports and other relevant documentation.

By completing this certification process on a regular basis, owners or operators can maintain regulatory compliance while helping to protect their employees and fix environmental issues.

What is an environmental audit protocol?

Audit protocols can help facilities evaluate their compliance with environmental laws. They provide guidance on how to develop a plan of action to address any issues and may include information on testing, monitoring, or other practices that are necessary for the facility’s success in meeting environmental requirements.

The protocols should be seen as a supplement to existing permits, statutes and laws; however, these guidelines must still be followed in order to ensure legal compliance. Audit protocols also provide a framework for more efficient evaluation of compliance status, helping facilities save time and resources when assessing their operations.

Why is it necessary for businesses to be sustainable?

Sustainability is becoming increasingly necessary in the business world, as businesses look to adopt greener technologies and practices that benefit both their bottom line and the environment. Sustainable businesses are able to make better use of resources while reducing costs, resulting in greater profits and job security for employees. Smaller businesses can also benefit from sustainable practices, as they often find it difficult to compete with larger organizations due to lower capital investments. An example of such is the The Clean Air Act (CAA) (42 U.S.C. 7401 et seq.) is a comprehensive Federal law that regulates all sources of air emissions.

By adopting more efficient methods and technologies, smaller businesses have the potential to become competitive players in the market. Furthermore, sustainability has a positive impact on employment by ensuring better working conditions for employees; this helps create a more stable economy and helps protect human health. Ultimately, sustainability is essential for creating an economically viable future for businesses, employees, and the environment. By taking strides towards a more sustainable business model, companies can create long-term value for their stakeholders and ensure a brighter future for everyone.

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Incident Reporting Software

Incident Reporting Software

Aug 20, 2022

What is safety incident tracking software?

Safety incident tracking software is an important tool for organizations to maintain safety and security in the workplace. It records and monitors all reports related to safety incidents, providing real-time visibility into potential risks.

This helps organizations identify trends, assess root causes of accidents, and take preventive measures. This tracking software also keeps a record of corrective actions taken by management that can used as a reference for future incidents. This allows for more informed decision making, increased accountability and ultimately an improved safety culture within the organization.

Additionally, it helps organizations comply with applicable safety regulations and standards. Incident tracking software can help organizations create a safer environment, reduce their liabilities, and provide peace of mind to employees.

What are the types of incident reporting software?

Incident reporting software provides organizations with the ability to document and track a workplace incident, helping them investigate issues and prevent future occurrences. It is a valuable tool for businesses of all sizes as it enables them to efficiently manage incidents and reduces the risk of costly liabilities. There are several types of incident reporting software available, each designed to meet specific needs.

These include web-based systems that allow reporting to be done online, desktop versions that can be installed on computers in the workplace, and mobile applications that are accessible on smartphones and tablets. Regardless of the type, all incident reporting software offers features such as customizable forms for recording incidents, tracking information, notifications of new incidents, and reports to analyze data.

What is safety incident reporting tool used for?

A safety incident reporting tool is used to track incidents, collect information about them, and report on the data that has been gathered. This kind of tool enables organizations to quickly identify potential hazards and take corrective action before accidents occur or escalate.

The data gathered by the reporting tool also helps with compliance and provides an audit trail for insurance purposes. Additionally, it can be used to measure the effectiveness of safety measures and provide data for developing better workplace safety initiatives. In short, a safety incident reporting tool is an invaluable tool that helps organizations to monitor and improve safety in their workplaces.

By having access to detailed data about an EHS incident, organizations can also identify trends and common issues that arise, allowing them to take proactive steps to prevent such incidents from occurring in the future.

Additionally, having access to such data can be used by management and safety teams to develop better safety initiatives and ensure that employees are aware of their own responsibilities for maintaining a safe working environment. In short, using a safety incident reporting tool is an invaluable way of helping organizations protect their employees and ensure compliance with relevant regulations.

What is the incident recording system?

The incident recording system is a critical component of workplace safety management. It is used to document incidents, near misses, hazardous conditions or any other type of event that may contribute to an unsafe working environment.

The system allows employers and employees to report details about the workplace incident, such as time and date, location, witnesses involved, type of injury, as well as develop a root cause analysis. This information is then stored in a centralised database, making it easy to quickly review the incident and analyse patterns in order to identify potential hazards.

With such an effective system in place it is easier for employers to prevent future incidents from occurring. Additionally, the system helps ensure that any legal or insurance regulations are followed correctly.

What are the 4 types of incident reports?

  1. Accident Report
  2. Property Damage Report
  3. Security Incident Report
  4. Behavioral Incident Report

Incident reports are written summaries of events that have occurred in a workplace, business, or organization and can be divided into four categories. The first type of incident report is an accident report, which documents any accidents or injuries that occur onsite.

This information can then be used to identify potential risks and take measures to reduce them in the future. The second type is a property damage report, which records any damage to the premises or equipment that has occurred due to dangerous working conditions or negligence. Thirdly, security incident reports document any threats to personnel, data, or assets.

Finally, behavioral incident reports are used to record incidents of verbal abuse, harassment, and other forms of disruptive behavior in the workplace. All four types of incident reports help to create a safe working environment and keep track of any issues that may arise.

Types of workplace incidents:

Workplace incidents are events that occur in the workplace and can have a variety of effects on employees, customers, visitors, and the organization as a whole. Incidents range from minor grievances to serious violations of safety regulations or corporate policies. Common types of workplace incidents include physical assaults, bullying or harassment, property damage, threats or intimidation, fraud and theft, violence or intimidation, and sabotage. It is important for organizations to have policies in place to address each of these incidents appropriately. This ensures that all employees are treated fairly and with respect, while helping to maintain a safe and productive working environment.

Organizations should also have protocols in place for reporting workplace incidents, such as making sure reports are documented accurately and filed promptly with the appropriate authorities. This helps to ensure that incidents are avoidable and can be properly managed if they do occur. By following these protocols, organizations can help to protect both the safety and morale of their employees.

In summary, workplace incidents vary greatly in severity and type, but all are important for organizations to take seriously. Having clear policies and procedures in place is essential to ensure a safe and productive work environment, while also protecting the rights of all employees. It is important for organizations to be vigilant in identifying potential incidents and taking appropriate steps to address them in order to maintain a secure work environment.

What is an incident management software?

A safety incident management software is an application specifically designed to help organizations and businesses respond quickly and efficiently to any type of incidents, such as natural disasters, technical issues, or other emergency situations.

This software simplifies the process of gathering information related to an incident from different sources and aggregating it in a single platform for easier decision-making. Incident management software also provides the necessary tools such as an incident management module, to report incidents, create plans, assign tasks, and track progress towards resolving the incident in a timely manner. Ultimately, this type of software helps businesses investigate incidents and reduce the impact and duration of workplace safety incidents as well as improve overall business continuity.

What is safety incident management?

Safety Incident Management is a process used to identify, assess, and mitigate safety incidents. This process helps organizations protect their personnel by responding quickly and effectively to safety incidents that could potentially cause harm or injury.

It enables organizations to create a comprehensive system for managing injuries, accidents, and other safety-related issues in the workplace through documenting safety incident data. Safety incident management also allows organizations to develop corrective actions and strategies for preventing similar incidents in the future. Overall, it is a critical process that ensures safety and health in the workplace.

What is the ITIL incident management system?

The ITIL incident management system is an effective way to proactively manage service interruptions and minimize their impact. It helps organizations predict, detect, identify, diagnose, and resolve incidents as quickly as possible.

With the help of the ITIL incident management tool, organizations can develop standardized processes for resolving software and hardware incidents in a timely manner. The process includes notifying team members, escalating issues to appropriate personnel, and logging incidents for analysis.

By using the ITIL incident management tool, organizations can ensure that their services are running smoothly and customers receive prompt support when needed.

It also helps organizations develop proactive measures such as training employees on how to use the system and implementing preventive maintenance procedures to reduce service interruptions.

Need help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance.

We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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iSi’s Top 8 Gaps Found in Environmental Audits

iSi’s Top 8 Gaps Found in Environmental Audits

Jul 16, 2022

​Environmental regulations are enforced by federal, state and local governments. How do you make sure you have your bases covered? An environmental audit can determine your current status and what your vulnerabilities are.

iSi’s environmental audits cover air, wastewater, stormwater, waste, spill prevention, tanks, DOT and emergency planning (EPCRA) requirements. They are a mock regulatory audit, looking at all aspects of your program through data gathering, walkthroughs and records reviews.

The following are our top 8 areas of compliance we see issues with when we do our audits.

Inaccurate Permits, Registrations & Notifications

What your facility does will determine which of these you need.  For example, have you notified the proper agencies regarding your spraying, blasting, emitting, generating, collecting, storing, disposing, dumping and discharging operations?

When do your permits expire?  Do your permits reflect the operations you’re conducting now?

Notifications may need to be made to EPA, your state authority, and in some cases, municipal authorities.  Many times there will need to be notifications made BEFORE you do these operations in addition to during and after.

Have you made determinations on what category of air emissions source you are or what classification of hazardous waste generator you are?  Who do your storage tanks need to be registered with?

Inaccurate/Incomplete Facility Plans

Specific written plans are required depending on what you do or have onsite. Which apply to you? Are they updated on the frequency required?  Some examples include:

  • Operations and Maintenance (O&M) Plans
  • Work Practice Implementation Plans (WPIP)
  • Storm Water Pollutions Prevention Plans (SWP3)
  • Spill Prevention, Control and Countermeasure (SPCC) Plans
  • Facility Response Plans (FRP)
  • Emergency Response Action Plans (ERAP)
  • DOT Security Plans
  • Hazardous Waste Contingency Plans
Missing/Incomplete Facility Inspections

Are you conducting the inspections which apply to you, on the frequency required?  What documentation is required?  Some typical issues we see missing inspections include:

  • Air
  • SWP3
  • SPCC
  • FRP
  • DOT
  • Hazardous Waste
Missing/Incomplete Facility Tracking

Are you tracking your air emissions correctly? What about waste generation? Tier II or Form R chemicals?  In many cases what you purchase and how much you use need to be tracked.  What do your permits require?  Are you past the usage allowed?  Have you changed a process which was not accounted for in the permit?

These are the areas many companies do not track their usage:

  • Air Emissions
    • Volatile Organic Compounds
    • Hazardous Air Pollutants
    • Particulate Matter
  • Waste Generation
  • Tier II
  • Form R
Inaccurate/Incomplete Reporting

We see a lot of issues with inaccurate and incomplete reporting.  This affects all areas of environmental issues. Reports can be required to monthly, quarterly, semi-annually, and annually?  What does your state/city/county require vs. what’s required federally?

When you have a spill, who are you reporting that to?  There are federal and state regulations which require you to make phone calls to certain authorities based upon the quantity and location.  Besides 9-1-1 or your spill contractor, you may need to report a spill to local emergency planning, the National Response Center, your state authorities.  Do you have a plan for this?  Have you done this and is it documented?

Inaccurate/Undocumented Training

Have you conducted the training you are required to?  Are the right people trained?  In addition to environmental training, please keep in mind that some regulatory agencies cross over in their requirements.  Don’t assume that because you’ve had hazardous waste training, that will suffice for shipping hazardous materials, or if you’ve had OSHA HAZWOPER training that will work for hazardous waste.  There are differences between EPA, OSHA and Department of Transportation (DOT) regulations and the training required for each.

Annual training is required for hazardous waste and per many environmental plans.  Do you have a mechanism to track this?  Are you doing this and has your training been documented?

Do you have job descriptions on file for your people?

Incomplete/Inaccurate Records

Are you keeping required records? Where are they kept and for how long?  Documentation is critical and will save you from many hassles in an inspection.  Are you keeping records for onsite inspections, training, and notifications?  Are they easily accessible?

Poor Day-to-Day Facility Management

Is there a disconnect in the proper way to do something vs. how it’s actually being done?  Spot checks and walkthroughs are just as important for environmental issues as they are for safety.  Many times we see worksites where the same issues keep cropping up on a regular basis.  Are issues you’ve been cited for in the past still popping up at your facility?

For example, are your hazardous materials going into the proper containers?  Are the containers closed and sealed?  Are they properly labeled?  Have your hazardous waste containers been sitting onsite for past the allotted time frame?  What are you doing with your spent fluorescent bulbs?

Do you have proper containment around your tanks?  Are containments cracked or able to leak?

Where is your stormwater being directed?  Do you have vehicles or equipment which leak oils that could come into contact with rainwater where the oils could be transported offsite?

Some of the most common areas we see issues include:

  • Air Emissions
  • Stormwater
  • SPCC
  • Waste
  • DOT
Where Do You Go From Here?

iSi can help you get a baseline on your environmental compliance responsibilities and help you prioritize the ones which are most critical to be taken care of.  Request a quote for an environmental audit today!  Need more information about these issues?  Contact us at (888) 264-7050 or email us!

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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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Personal Protective Equipment (PPE): The Basics

Personal Protective Equipment (PPE): The Basics

Jun 21, 2022

What is Personal Protective Equipment (PPE)?

PPE is essential in protecting workers from potential harm and is mandatory in many industries. Employers must provide PPE to all their employees free of charge if they are likely to be exposed to hazards during work. The different types of PPE used depend on the risk assessment carried out by the employer, which will determine the level of protection needed for each individual employee.

Common examples of PPE include safety helmets, gloves, safety goggles, ear defenders and respirators. In some cases, employers may also need to provide fire retardant clothing or specialist footwear such as steel toe capped boots.

It is important that employers follow guidelines set out by regulatory bodies when providing PPE, as failure to do so could result in serious injury or even death. It is also important that employees use the PPE provided correctly and understand the associated risks of not doing so.

What different industries require PPE?

Transportation

The most common type of PPE used by truck drivers are:

  • Safety glasses or goggles
  • Steel toe boots
  • High visibility clothing

It is important to be aware of any hazardous materials that you may come into contact with while making a delivery and to make sure that you are wearing the appropriate PPE. In some cases, full-body suits may be necessary to protect against hazardous materials.

Chemical

  • Face shields/Face mask
  • Respiratory protective equipment
  • Chemical splash goggles
  • Gloves
  • Aprons/Overalls

PPE should always be used where there is a risk of exposure or contamination of corrosive liquids. It is important to ensure that PPE is appropriate for the task, fits properly, and is maintained in good condition. To determine appropriate types of PPE, it may be necessary to have a qualified person assess the nature and extent of potential hazards.

Food

  • Gloves
  • Safety glasses
  • Face shields
  • Hairnets

PPE is an essential part of any restaurant, cafe, or bar staff’s uniform and should be worn at all times while on the job. Employees who don’t wear the right PPE can easily get injured from sharp knives or hot dishes, increasing both their risk of harm and the potential liability of their employer.

Healthcare

  • Gloves
  • Gowns
  • Eye protection
  • Disposable N95 respirators, surgical masks, face shield

PPE for healthcare workers is essential for occupational safety. The CDC (Center for Disease Control) recommends gloves, gowns, eye protection, and face shields/masks as the basic requirements for any and all healthcare workers.

Wearing PPE such as basic respiratory protection, protective clothing, a surgical mask, protective eyewear, and lab coats, when worn correctly, can significantly help prevent workplace hazards and biological hazards, thus helping protect workers and health workers.

Oil and Gas

  • Eye protection
  • Hearing protection
  • Hand/Foot protection
  • Flame-resistant clothing
  • Gas detection monitors

Essential PPE for oil and gas workers significally reduce employee exposure to physical hazards present as well as notify them on things they cannot see.

Automotive

  • Peripheral safety goggles
  • Cut-resistant gloves

Peripheral eye protection is especially important in the Automotive Industry, as liquids like fuel and oil can drip down the face, and working in dusty environments with fiberglass, or metal fragments can work their way around non-sealed safety glasses.

Sealed glasses and goggles provide the best protection against such hazards while allowing unrestricted vision to perform service tasks. Motor vehicle technicians and mechanics should always wear proper eye protection whenever doing repairs, as the risks of serious injury or permanent vision damage are simply too great to ignore.

It is also important for anyone working in an automotive environment to get regular vision exams to ensure that any issues can be caught and treated early. Cut-resistant gloves will help prevent skin damage and skin hazards.

Construction

  • Protective gloves
  • Hearing protection to prevent occupational hearing loss
  • Full face shields when cutting, grinding, or chipping
  • Goggles for chemical splashes
  • Proper respiratory equipment and protection
  • Fall protection equipment when working above 6 feet

In addition to these PPE requirements, all construction site employees must be aware of the site-specific health hazards associated with working on a construction or renovation site. Employees should know what types of hazardous substances are present and how they can protect themselves.

Appropriate PPE such as respirators, gloves, boots, and chemical protective clothing may need to be worn depending on the particular job site. Make sure that you understand all safety procedures before beginning work and follow them at all times.

It is the responsibility of each employee to take appropriate steps to protect themselves from any potential harm.

Finally, make sure that you report any unsafe conditions or practices immediately to your supervisor or the project manager in charge of the site. Safety first – always!

Manufacturing

  • Gloves
  • Hard hat
  • Goggles
  • Full-body suits
  • Face shields

When working in a manufacturing facility, it is important to wear the proper personal protective equipment (PPE) to protect yourself and protect employees around you.

This includes gloves, protective hearing gear, hard hats, goggles, respirators, and full-body suits. Wearing PPE can help protect you from various hazards in the workplace. Some facilities may require using a self contained breathing apparatus or powered air purifying respirators as well as other equipment designed for a specific purpose.

What are some examples of PPE?

Masks and Respiratory Protective Equipment

When choosing a respirator, it’s important to understand the differences between APRs and ASRs. Air-purifying respirators (APRs) filter out contaminants from the air that is breathed through them. These types of respirators are most effective when used in environments with low levels of contamination, since they are unable to protect against high concentrations of airborne contaminants. Some examples are:

Protection for the Face and Eyes

Eye and face protection is important in any workplace setting to not only protect against eye injuries, but also for ensuring optimal employee productivity. Depending on the work environment and tasks that need to be completed, there are four primary types of eyewear available to help minimize risk.

General safety goggles are designed with side shields that provide a greater area of coverage, and some models may even include a wraparound frame. They are suitable for most workplace conditions, including those with light debris or dust particles in the air. Another example of safety goggles is laser safety goggles.

Head and Shoe Protection

Wearing a hard hat with a chin strap is the best way to ensure that an employee’s head remains protected when working in hazardous situations. The chin strap will keep the hat secured and prevent it from falling off in case of a fall or other accident. Hard hats must also be inspected regularly for any cracks, dents, scratches, punctures or other signs of damage.

Damaged hard hats must be replaced immediately to ensure an employee’s safety. Employees should also check the fit of their helmet before beginning work. A well-fitting hard hat will provide maximum protection and comfort for employees working in hazardous conditions. Safety equipment can only help you if you use it properly.

Gloves

Different types of gloves include: Leather, Canvas or Metal Mesh Gloves, Fabric and Coated Fabric Gloves, Chemical- and Liquid-Resistant Gloves, and Insulating Rubber Gloves. Gloves are used in many different scenarios and provide protection against anything from infectious materials, contaminated body fluids, bloodborne pathogens, and bacterial contaminants, to physical hazards such as cuts and abrasions.

What is required for OSHA standards for PPE?

Employers should assess the workplace to determine if PPE is necessary. If it is, employers should provide employees with appropriate protective equipment and ensure its use. Employers must also make sure that the protective equipment is well-maintained and kept clean.

Additionally, employers must train employees on how to properly wear and care for their eye and face protection in order to ensure its effectiveness. Employees should also be informed about potential hazards in their work environment, as well as any limitations of the protective equipment they are using.

If an employee needs prescription lenses while wearing safety glasses, employers may have additional requirements to meet OSHA standards. It is important to note that non-prescription safety glasses do not provide adequate protection against hazardous materials.

Employers should ensure that employees who require prescription lenses have access to appropriate protective equipment and can safely perform their job duties without endangering themselves or others.

If an employer has determined that protection is necessary, they must also provide employees with a copy of OSHA’s standard 1910.133 which outlines the requirements for protection in the workplace.

This document contains detailed information on types of hazards, selection criteria, performance requirements, instructions for use and care, as well as other helpful information employers need to know when providing appropriate face protection to their employees. The World Health Organization and OSHA reiterate that employees must wear PPE and proper equipment in order to protect them properly.

Why do you and your employees need PPE?

  1. Liability

  2. Long-term issues

  3. Keep what you got!

  4. Increase quality work environments

Conclusion:

When it comes to workplace safety, personal protective equipment (PPE) is an essential piece of the puzzle. PPE protects workers against hazards in the environment that could cause physical harm or injury. Industries such as manufacturing and mining are particularly hazardous, and effective use of PPE can help prevent accidents and injuries from occurring.

To ensure maximum protection, it is important that workers always wear the correct type of PPE for the job they are doing. This could include safety glasses, gloves, hearing protection, hard hats and other items that are designed to protect against specific hazards.

How Can We Help? Ask a Question or Request Info or Pricing

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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What is EPA’s General Duty Clause? Where is It?

What is EPA’s General Duty Clause? Where is It?

May 26, 2022

Does This Apply To You?

iSi can help determine which of these options apply to your facility, and help you make sure you’re on the right track in getting the necessary documentation and processes in place.

Help/More Info

In our blog, we’ve looked at OSHA’s General Duty Clause, including issues that are commonly cited under the General Duty Clause.  Did you know that EPA has a General Duty Clause too?

Who Does It Apply To?

The EPA General Duty Clause can be found in the Clean Air Act, Section 112(r)(1).  It states companies that produce, process, handle or store hazardous substances/chemicals have a primary duty to identify release hazards and prevent chemical accidents.

If your company doesn’t fall under EPA’s Risk Management Plan (RMP) requirements, you will fall under EPA’s General Duty Clause.

General Duty Clause vs. RMP

If you produce, process, handle or store hazardous substances/chemicals, you will need to comply with either the EPA General Duty Clause or RMP, based on your operations.

The requirements for RMP can also be found in this same Clean Air Act Section 112(r) as the General Duty Clause, and it also applies to the same types of facilities who use hazardous chemicals.  However, RMP is focused on one or more of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

RMPs are directly submitted to EPA.  Water treatment plants, agricultural COOPs and chemical manufacturers are typical types of companies who need to comply with RMP.

RMPs must include:

  • Potential effects of a chemical accident
  • Hazard assessments
  • 5-year accident history
  • Evaluation of worst-case scenarios and alternative accident release potentials
  • Prevention programs that include safety precautions, maintenance, monitoring, and employee training measures
  • Emergency response program that lists emergency health care, employee training measures, procedures for informing the public.

 What is Required by EPA’s General Duty Clause?

In an EPA inspection, the inspector can ask your company to produce information to show you are complying with the General Duty Clause.  To be compliant, companies are required to address the following 3 topics, with examples for each.

1.  Identify hazards which could occur if an accidental release happens.

  • Identification of related environmental, health and safety hazards
  • Identification of potential release scenarios through experience/industry research, analysis and logic trees, or “What If” brainstorming
  • Determine the consequences in each scenario

2.  Design and maintain a safe facility. (By putting features such as these in place:)

  • Design safety codes
  • Use of less hazardous chemicals when possible
  • Equipment quality control procedures,
  • Using alternate processes
  • Process siting
  • Using safety technology where possible
  • Standard Operating Procedures
  • Employee training
  • Change management
  • Incident investigation programs
  • Self audits
  • Preventative maintenance programs

3.  Determine potential consequences of accidental releases and minimize them.

  • Development of an Emergency Response Plan that contains, at a minimum: anticipated releases, mitigation, notification process to local responders and local responder involvement
  • Coordination with local emergency response officials including the local emergency planning committee
  • Training for “out of the norm” circumstances
  • Periodic exercises using your plan, training, and equipment practicing response, evacuation, sheltering-in-place, and worker’s ability to perform in the event of an emergency

Inspectors will also be looking into the thoroughness of your process hazard analyses, your evaluations, and the elements you’ve put into place, and whether or not they apply to your current operations.

Which One Applies to Your Facility?

Because the RMP is specific to certain chemicals and thresholds, all companies with the potential for accidental chemical releases may not fall under its requirements.  However, if RMP does not apply to your company, then the EPA General Duty Clause will.  

Which one applies to your facility?  Have you completed all the necessary analyses required? Do you have all the programs, processes and training in place?  If the answer to any of these questions is no, then iSi can help.  Contact us today for more information.

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

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EPA Proposes Ban on Chrysotile Asbestos Still in Use Today

EPA Proposes Ban on Chrysotile Asbestos Still in Use Today

May 12, 2022

Asbestos is contained in thousands of products, from building materials and adhesives, fireproofing materials to consumer products.  The use of asbestos has dramatically declined since the 1980s, and more than 50 countries have banned its use.  However, one type of asbestos is still being used to make certain products in the U.S., and EPA is working to ban it.  It’s called chrysotile, or white asbestos.

Chrysotile is the most common type of asbestos.  Its soft, flexible fibers form a serpentine material that’s strong, heat resistant to 3000 degrees and non-conductive. 

Some chlor-alkali manufacturing plants that make chlorine and sodium hydroxide and some vehicle brake and sheet gasket manufacturers still import and use chrysotile asbestos in their products.

The EPA Ban on Chrysotile

EPA has issued a proposed rule to ban chrysotile asbestos in the following products:

  • Chrysotile asbestos used in bulk or in asbestos diaphragms in the chlor-alkali industry beginning two years after the effective date of the final rule;
  • Chrysotile asbestos-containing sheet gaskets in chemical production beginning two years after the effective date of the final rule;
  • Chrysotile asbestos-containing brake blocks used in the oil industry;
  • Chrysotile asbestos-containing aftermarket automotive brakes/linings and other friction products, including for consumer use; and
  • Chrysotile asbestos-containing gaskets, including for consumer use.

Asbestos diaphragms are used by chlor-alkali plants for the water treatment industry, but that use has been declining.  EPA estimates only 9 chlor-alkali plants in the U.S. still use asbestos diaphragms as there are other alternatives, accounting for only 33% of all chlor-alkali plants. 

EPA was not able to quantify the scope of asbestos use in the brake and gasket industries.

EPA’s rule would also include targeted disposal and recordkeeping requirements that would take effect 180 days after the effective date.

Other Upcoming Asbestos Studies by EPA

As part of the Toxic Substances Control Act (TSCA), asbestos was one of 10 chemical substances on a list to be studied and put through a risk evaluation.  EPA decided to do the evaluation in two parts. 

The first part was the risk evaluation for chrysotile, leading to this ruling on banning it. 

In Part 2, EPA will be looking at a number of other issues related to asbestos, including:

  • Different types of asbestos (amphibole-type asbestos such as crocidolite, amosite, tremolite)
  • Legacy uses of asbestos in commercial, industrial and consumer products
  • Disposal phases
  • Occupational exposure
  • Consumer and bystander exposure
  • General population exposure
  • Potential exposed or susceptible subpopulations (children, workers, smokers, others)

In addition, EPA will be evaluating asbestos-containing talc and vermiculite.  This does not apply to talc used in makeup, but talc that’s imported and used in industrial, commercial and consumer products such as filler/putty, crayons with talc-containing asbestos and toy crime scene kits with talc-containing asbestos. 

EPA will be looking at the import of this talc, distribution of it in commerce and its disposal.  Vermiculite was used in building materials, and 70% of all vermiculite sold in the U.S. was extracted from an open pit mine in Libby, Montana until it closed in 1990.

EPA is accepting public comments on the proposed rule for chrysotile asbestos  at https://www.regulations.gov/.

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EPA Proposes Rule Expanding Facility Response Plan Requirements

EPA Proposes Rule Expanding Facility Response Plan Requirements

Apr 28, 2022

EPA has issued a proposed rule that would require many non-transportation-related facilities to develop a Facility Response Plan under the Clean Water Act, based on planning for worst-case scenario discharges.  This proposed rule significantly increases the number of facilities who may need a Facility Response Plan and increases the number of hazardous substances to be considered when making a compliance determination.

EPA’s goal is to make onshore non-transportation facilities determine if they could reasonably be expected to cause substantial harm to the environment by discharging one of the 296 Clean Water Act hazardous substances into or on navigable waters, the shoreline or exclusive economic zones.  If the facility meets the criteria, then they’ll be required to prepare a Facility Response Plan that plans for worst case scenarios.

This rule is a result of a settlement EPA made in a 2019 lawsuit from the Natural Resources Defense Council and others.  The suit claimed EPA was required, but failed, to make non-transportation-related facilities that could cause substantial harm to plan, prevent, mitigate and respond to worst case spills of hazardous substances.  The consent decree requires EPA to take final action on a rule addressing worst case discharge plans for hazardous substances before September 2022 and this is the result of that.

What Industries are Affected?

The new rule would apply to the following NAICS code groups:

111 Crop Production
115 Support Activities for Agriculture and Forestry
211 Oil and Gas Extraction
212 Mining (except Oil and Gas)
213 Support Activities for Mining
221 Utilities
311 Food Manufacturing
314 Textile Product Mills
321 Wood Product Manufacturing
322 Paper Manufacturing
324 Petroleum and Coal Products Manufacturing
325 Chemical Manufacturing
326 Plastics and Rubber Products Manufacturing
327 Nonmetallic Mineral Product Manufacturing
331 Primary Metal Manufacturing
332 Fabricated Metal Product Manufacturing
333 Machinery Manufacturing
335 Electrical Equipment, Appliance, and Component Manufacturing
336 Transportation Equipment Manufacturing
423 Merchant Wholesalers, Durable Goods
424 Merchant Wholesalers, Nondurable Goods
441 Motor Vehicle and Parts Dealers
444 Building Material and Garden Equipment and Supplies Dealers
447 Gasoline Stations
453 Miscellaneous Store Retailers
488 Support Activities for Transportation
493 Warehousing and Storage
511 Publishing Industries (except internet)
522 Credit Intermediation and Related Activities
562 Waste Management and Remediation Services
611 Educational Services
622 Hospitals
811 Repair and Maintenance
812 Personal and Laundry Services
928 National Security and International Affairs

How Do You Know if It Affects Your Company?

To determine if this applies to your company, there are three criteria to consider.

  1. Maximum Capacities Stored Onsite

Determine if your maximum capacity for any of the 296 Clean Water Act-identified hazardous substances meets or exceeds 10,000 times the reportable quantity in pounds.  The reportable quantities for each hazardous substance are different.  Some may be 5000 lbs. (hydrochloric acid, acetic acid), others may be 1000 lbs. (nitric acid, phenol), some may be 100 lbs. (hydrogen sulfide, formaldehyde), others may be 10 lbs. (benzene, nitrogen dioxide, sodium) and some may be 1 lb. (PCBs, arsenic, diazinon).

  1. Location

Next, determine if your facility is one half mile of a navigable water or conveyance to a navigable water.  The definition of a navigable water has been under debate for a number of years and has changed between the different Presidential administrations.

  1. Substantial Harm Criteria

Last, do you meet any of the substantial harm criteria.  That is, will you:

  • Do you have the ability to adversely impact a public water system?
  • Could you cause injury to fish, wildlife and sensitive environments?
  • Do you have the ability to cause injury to public receptors?
  • Have you had a reportable discharge of a Clean Water Act hazardous substance within the past 5 years?

If you meet the substantial harm criteria, you would need to submit your Facility Response Plan to the EPA.  Existing facilities that meet the criteria on the effective date of the rule would have to submit a Facility Response Plan within 12 months.

What is a Facility Response Plan (aka, an FRP)?

FRPs are required per 40 CFR 112.  Current criteria says if you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet other certain criteria, you are required to have one. Facility Response Plans requirements are from the Federal Water Pollution Control Act.

Public Comment

EPA is taking public comments on the proposed rule until May 27, 2022.  More information, including links to the public comment site can be found HERE.

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Sustainability Consulting for the 21st Century

Sustainability Consulting for the 21st Century

Mar 1, 2022

The modern world is a sustainable one. It’s time for your business to join the ranks of those who are making a difference.

Sustainability has become one of the most important topics of our time. As the world becomes more and more aware of the environmental, social, and economic challenges we face, more and more businesses are looking for ways to operate in a more sustainable way.

That’s where sustainability consulting comes in. A sustainability consultant helps businesses identify opportunities to operate in a more sustainable way. This can mean anything from reducing energy consumption to increasing employee engagement in sustainability goals.

Sustainability consultants come from a variety of backgrounds, but all share a common goal: to help businesses move towards a more sustainable future with sustainability services.

The good news is that sustainability consulting is one of the fastest growing industries in North America and the world. The bad news is that it can be hard to know where to start when it comes to finding a sustainability consultant that’s right for your business.

Here are four tips to help you find the right sustainability consultant for your business:

1. Define your sustainability goals and ESG strategy.

What does your business want to achieve by working with a sustainability consultant? Do you want to reduce your carbon footprint in your global business? Develop more robust sustainability strategies? Achieve sustainable development goals? Incorporate sustainability solutions and a sustainable infrastructure into your business strategy? Improve employee engagement? Need risk management? Find ways to save money.

Once you know what you want to achieve, you can start looking for consulting firms that specialize in those areas.

2. Identify a budget.

Do your sustainability ambitions match resources available for the project? Does the ESG (Environmental Social and Governance) strategy align with your corporate growth strategy?

It is recommended to present a sustainability strategy internally, that outlines tiers of investment and the types of sustainability performance to be expected per expenditure.

3. Do your research.

Do a deep dive in the sustainability consulting services universe. Once you’ve identified some consulting firms that might be a good fit, take some time to learn about their backgrounds and experience and nail it down to your favorite consulting firm.

How long have they been working in a sustainable business? What are some of the clients they’ve worked with? What do other people say about them? Top consulting firms offer diverse corporate responsibility solutions and professional services across a wide swathe of industry sectors.

4. Ask for recommendations.

Talk to other businesses in your industry and see if they’ve worked with any sustainability consulting firms that they would recommend. If you know someone who works in sustainable business, ask them for their thoughts on different consultants.

The best way to find a good consultant in the large world of the consulting industry is through word-of-mouth from people who have worked with them before.

A global management consultancy will have the general pulse on corporate social responsibility. Top sustainability consulting firms will be a global leader in change management and integrated business planning.

The best ones possess deep expertise in the management of business risk and climate risk, while working with you to embed sustainability into your culture.

These days, there’s no excuse for not being sustainable, not manage risk, and not create sustainable business models.

Future leaders and businesses that don’t take steps to operate sustainably will not only be missing out on opportunities and losing business value, but will also be left behind as society progresses towards a more sustainable future.

These can be complex problems. Sustainability consulting is one of the best ways for businesses to make sure they’re operating sustainably and making a positive impact measurement on the world around them.

iSi Environmental is a leading provider of environmental consulting and management consulting services in the United States and we are committed to protecting the planet and its inhabitants with the skills and knowledge of our people. With us you get long term value.

Senior Executives and Sustainability Teams turn to us when:

  • Their team is short on time and resources to achieve organizational sustainability strategy
  • They need hands-on implementation of new compliance processes
  • They need to integrate sustainability at multiple locations
  • Also turn to us when looking to roll local best practices into a global corporate system

Need Assistance?

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The Top 4 Facility Response Plan Issues Found by EPA

The Top 4 Facility Response Plan Issues Found by EPA

Dec 9, 2021

EPA has reviewed inspection data from its regional offices to get an idea of the most common Facility Response Plan and SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies.  The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations.  [Check out the SPCC Plan deficiencies here.]

What is a Facility Response Plan (aka, an FRP)?

Facility response plans are required per 40 CFR 112. If you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet certain criteria, you are required to have a Facility Response Plan. Both the SPCC Plan and Facility Response Plan are from the Federal Water Pollution Control Act.

EPA’s Review

The data was reviewed for companies who also had both Facility Response Plans and SPCC Plans, with a preference for companies with higher oil storage capacity.  The Facility Response Plans facilities had an average aggregate oil storage capacity of 69,000 to 857 million gallons of oil, with a worse case scenario discharge planning volume of 94,000 to 20 million gallons.  EPA found an average of 4 issues per plan.

Top 4 Facility Response Plan Deficiencies (in Order)

  1. Diagrams (1.9) – 31 of the 55 had this deficiency
    • This includes site plans, evacuation plans and drainage diagrams.
  2. Discharge Scenarios (1.5)
    • This includes discussion and plans for worse-case discharge.
  3. Vulnerability Analysis; Hazard Evaluation (1.4. 2 and 1.4)
    • This would be spill history and analysis of discharge potential.
  4. Plan Implementation  (1.7)
    • This would be a description of containment and drainage planning, disposal plans and response resources.

Other Issues Found

  • Lack of details about response equipment. (1.3, 1.3.2)
  • Companies didn’t include key information from their Emergency Response Action Plans (ERAPs) (1.1)
  • Not conducting required preparedness drills and exercises (1.8)
  • Not training personnel on appropriate oil spill response measures.

Do you have any of these issues with your own Facility Response Plan? Are you required to have an FRP? We can help! We can review your plan for compliance to these issues, prepare updates, or provide the required training or scenarios you need to conduct to your employees. Contact us today!

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EPA Names Most Common SPCC Plan Deficiencies – Do You Have Any of These?

EPA Names Most Common SPCC Plan Deficiencies – Do You Have Any of These?

Oct 11, 2021

EPA recently reviewed inspection data from its regional offices to get an idea of the most common SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies.  The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations.

The data was reviewed for companies who had SPCC Plan issues, with a preference for companies with higher oil storage capacity and who also had to have Facility Response Plans (FRPs) onsite as well.  Inspection data was reviewed for 120 companies with oil storage capacity between 4,000 gallons and 857,000,000 gallons.

Of those, 10 companies didn’t have an SPCC Plan.  Of the remaining, they found that the companies averaged 4 issues with their plans.

Top 9 SPCC Plan Deficiencies (in Order)

  • Plan Content, Certifications & Reviews (112.3, 112.5, 112.7) – 119 of the 120 had this deficiency
  • General Secondary Containment (112.7)
  • Testing and Inspection: Integrity Testing (112.8, 112.12)
  • Sized Secondary Containment (112.8, 112.9, 112.12)
  • Drainage (112.8)
  • Piping: General (112.8)
  • Piping: Inspections (112.8, 112.9)
  • Discharge Prediction (112.7)
  • PE Certification (112.3)

Some examples of these include:

  • Inadequate or no documentation of the required 5-year review of the plan;
  • Failure to address required containment for piping;
  • Failure to address integrity testing of bulk storage containers;
  • Failure to demonstrate that secondary containment met the requisite size of design requirements; and,
  • Failure to provide procedures for controlling stormwater discharges from diked areas.

Do you have these issues with your own SPCC plan?   Are you required to have an SPCC Plan?  Check out our blog about SPCC plans, or contact us today to help.  We can review your plan for compliance to these issues, conduct the required 5-year update, or provide the required training you need to conduct to your employees.  Contact us 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
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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