OSHA Update – Hazard Communication

In 2019 OSHA will update how companies must communicate the hazards of chemicals they sell and export. The update will align OSHA requirements with the most recent version of GHS, released in July 2017.

In July we noted that Scott Pruitt released a memo on March 13 to change how industries calculate whether increases in air pollutants from source modifications will trigger an EPA permitting program called new source review (NSR).

Most states are required to adopt the provisions of the Hazardous Waste Generator Improvements Rule (HWGIR) by July 1, 2018. Indiana, Michigan, Ohio, and Kentucky (among other states), will adopt the rules this July. Indiana will adopt the rule by reference.

Operational changes often affect a facility’s air permit and each permit modification requires specific information and are accompanies by various degrees of timelines (30 to 270 days).

If you are having issues with finding a reusable wipe that fits your needs or are sending wipes off as hazardous waste, we suggest looking at the exclusion found in 40 CFR 261.4(b)(18).

This article provides an overview of key differences between ISO 14001:2004 and 14001:2015. Some new requirements include terminology such as evaluating RISKS and OPPORTUNITIES, while others expand on existing terminology (i.e. INTERESTED PARTIES).

OSHA will walk back some of its requirements for employers to provide injury and illness information to the agency, according to the Trump administration’s new regulatory road map released Dec. 14.

August 11 U.S. EPA published new TSCA rule to the Federal Register, often referred to as “TSCA Reset”. Companies have 180 days to comply, Feb 7, 2018.

Another component of the RCRA updates that has been of interest to some of our clients are the Episodic Event clauses.

An Annual Compliance Certification (ACC) is a reporting mechanism used to let IDEM know if your facility is in continuous compliance or intermittent compliance with your operating air permit.