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Showing posts from March, 2019

Sustainable Solutions: Amendment to Management of Pharmaceuticals

On 2/22/19, EPA has published the final rule: Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine . This rule was initially proposed in 2015 and is scheduled to go into effect August 21, 2019. Goals for this rule include EPA’s efforts to establish cost-savings and streamlined standards for hazardous waste pharmaceutical (HWP) management in order to accommodate healthcare operations and maintain human health and environmental protection.  The rule also eliminates intentional sewer disposal or discharge of hazardous waste pharmaceuticals, reduces overlapping regulations (DEA, FDA, etc.), provides regulatory clarity and consistency on how RCRA applies to reverse distribution and reverse logistics, and allows pharmaceutical distributors, healthcare facilities, and other site that manage these wastes to exclude HWP from RCRA regulation standards.  This also excludes some FDA nicotine therapy products from regulation. Below is a br

Tech Corner: OSHA amends part of the electronic injury & illness reporting rule

On January 25, 2019, OSHA has published the final rule amending the previously finalized Electronic Injury & Illness Reporting rule.  Full text of the final rule was published in the Federal Register, and will take effect on February 24, 2019.  This amendment impacts employees with 250 or more employees. What’s changed? Previously OSHA has required employers with more than 250 employees to electronically report injury and illness data on OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 301 (Injury and Illness Incident Report) and 300A (Summary of Work-Related Injuries and Illnesses).  The new rule no longer requires these employers to electronically report on Forms 300 and 301, only 300A. Why? OSHA has enacted these changes in an effort to protect worker privacy.  Forms 300 and 301 contain employee identifiable information, while Form 300A only requires general injury or illness information. What now? By limiting the electronic reporting requirement to only ge

Tech Corner: Wastewater Practices - General requirements

Sanitary wastewater discharges regulated by the Washington Suburban Sanitary Commission (WSSC) and the Maryland Department of the Environment (MDE) establish specific conditions under which wastewater can be discharged. This fact sheet summarizes general regulatory requirements for wastewater discharge and identifies compliance management practices for facility personnel. Applicable Regulation ·          The Plumbing and Gas Fitting Regulations ·          40 CFR Part 403- General Pretreatment Regulations for Existing and New Sources of Pollution ·          COMAR 26.04- Regulation of Water Supply, Sewage Disposal and Solid Waste General : The WSSC regulations limit the types of materials that may be discharged into the sanitary sewer and may require pretreatment and facility permits on a case-by-case basis. Primary contaminants that must be kept out of the wastewater stream include volatile organic compounds, heavy metals and acidic or caustic discharges. Specific disch

Tech Corner: What is hazardous waste?

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EPA’s hazardous waste management program uses the term solid waste to denote something that is a waste. Hazardous waste regulations define in more detail what materials are solid waste for the purposes of RCRA Subtitle C (hazardous waste) regulation. 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. EPA developed a regulatory definition and process that identifies specific substances known to be hazardous and provides objective criteria for including other materials in the regulated hazardous waste universe. This identification process can be very complex, so EPA encourages generators of wastes to approach the issue using the series of questions described below: