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 1st 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.
Environmental, Health & Safety Blog
According to OSHA, falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and death. To better protect workers from slips, trips, and falls, OSHA has issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems (29 CFR part 1910, subparts D and I) that updates and clarifies standards and adds training and inspection requirements. By making these changes, OSHA estimates that 29 fatalities and 5,842 lost-workday injuries will be prevented every year. Keep reading to learn some quick facts about the final rule from OSHA.Read More
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 1st 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.
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.Read More
It’s time to start thinking about Biennial Reports again. Hazardous waste large quantity generators (LQGs) and Treatment Storage Disposal Facilities (TSDFs) are required to report their hazardous waste activities that occur during the 2015 calendar year. The report should compile information on the type, source, form, quantities, and management of hazardous wastes generated and is due on March 1st. The EPA requires that this information be submitted at least every two years; however some states require that this information be submitted annually. The EPA uses Biennial Report data for planning and developing regulations, compliance monitoring, and enforcement.
Here’s what you need to know:
Who Needs to Report:Read More
Stormwater management should be a serious concern for your organization. According to Sarah Crean's article in the Gotham Gazette:
In industrialized areas, stormwater not only poses a risk for flooding, but also contamination and pollution. When stormwater reaches the earth, it can mix with chemicals and other pollutants that can prove deadly when the water runs into ponds and streams.
From the Loading Dock to the Lab
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