Environmental, Health & Safety Blog

Whether you're a large healthcare facility, a small research and development venture, or an industrial manufacturing powerhouse, using a partner to deliver environmental, health, and safety operations may have valuable benefits. Third party delivery of EH&S allows an organization to focus on its core goals, all while leaving the demanding safety, compliance, and health programs to the experts.

Section 312 of the Emergency Planning Community Right-to-Know Act (EPCRA) of 1986 states that Emergency and Hazardous Chemical Inventory Reports, also known as Tier II reports, must be submitted annually by March 1^st to your State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department(s). Failure to comply with Tier II reporting requirements can cost your organization. Each violation of EPCRA Section 312 may result in civil penalties of up to $25,000. Each day a violation continues constitutes a separate violation.

The Resource Conservation and Recovery Act (RCRA) requires large quantity waste generators to submit a report every two years detailing their hazardous waste activities generated in the year prior. This is referred to as a Biennial Report or the National Biennial RCRA Hazardous Waste Report.

Is your university ready in terms of safety and compliance for students to come back from summer break? Your EH&S program should be ready to help you minimize liability, keep people safe, reduce your cost of managing waste, stay compliant, and protect your school's reputation and brand. That's a lot to think about with school right around the corner.

Section 312 of the Emergency Planning Community Right-to-Know Act (EPCRA) of 1986 states that Emergency and Hazardous Chemical Inventory Reports, also known as Tier II Reports, must be submitted annually by March 1^st to your State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department(s). Failure to comply with Tier II reporting requirements can cost your organization. Each violation of EPCRA Section 312 may result in civil penalties of up to $25,000. Each day a violation continues constitutes a separate violation.

Triumvirate will detail findings and implications of the 2016 State of EH&S Survey in a webinar on January 28, 2 p.m. ET. Registration is open at: bit.ly/EHSwebinar

Environmental Health and Safety (EH&S) compliance can be overwhelming. Fire safety, hazard communication, and many other standards change often – and your facility must adapt to them all. Let’s take a look at some of the many tricky compliance issues and real-life solutions established by Triumvirate’s Onsite Support Services (OSS) teams that you can implement at your facility.

Satellite Accumulation Areas (Near The Point of Generation):

One common aspect of the EH&S world that is frequently inspected by regulatory bodies is the Satellite Accumulation Area (SAA). SAA’s allow a facility to accumulate waste in an established area with fewer requirements than a Central Accumulation Area (CAA) otherwise known as Main Accumulation Area (MAA). However, there are still important rules to consider when managing SAA’s.

Some wording in the regulations regarding SAA’s can be left to interpretation, such as the requirement that waste in an SAA must be collected "at or near the point of generation."  Since this is interpreted on a case by case basis, different inspection agencies may have varying opinions on how your facility complies with this rule.  Having a team member onsite who is familiar with all of your facility’s SAA’s, as well as each location’s waste-generating processes, can ensure that the accuracy of the SAA location will never be up to interpretation.

“We put this SAA here because putting it any closer to the point of generation could pose an unnecessary safety hazard”. Similar to the last statement, a good recommendation would be to develop an understanding of the equipment, mechanisms, and actions leading to waste generation at a particular place. It will then be easier to determine the best location for an SAA with confidence.

SAA’s must also have the appropriate labeling and signage for installation and inspection.

Satellite Accumulation Areas are not always subjected to a regulated and documented weekly or monthly inspection; depending on your state, there are some specific requirements that may require these assessments to be done. For this reason, it can be easy for them to be overlooked in favor of more pressing compliance needs at your facility. However, facilities may still be penalized for any number of SAA compliance issues upon discovery during a State Agency, Federal EPA, Joint Commission, or other regulatory-body’s inspection.  These agencies will be checking on Resource Conservation and Recovery Act (RCRA)-required provisions such as container closures, container conditions, proper signage and container labeling.