The EnviroBlog

  Since the passing and adoption of the Globally Harmonized System (GHS) Rule in 2012 there have been multiple changes implemented to protect employees from hazardous chemicals they may come in contact with in the workplace. In February OSHA proposed some updates to it’s Hazardous Communication Standard (HCS), or HazCom for short, in another edition of the GHS for classifying and labeling chemicals. OSHA will accept public comments on the proposed HazCom update rule until May 19, 2021. The proposed modifications to the standards include:   ·        Revised criteria for classification of certain health and physical hazards to better capture and communicate the hazardous to downstream users; ·        Revised provisions for labels (including proposed provisions addressing the labeling of small containers and the relabeling of chemicals that have been released for shipment); ·      ...

The Hazardous Waste Generator Improvements (HWGI) rule is currently adapted in 23 states in addition to the territories and tribes who automatically implement Federal RCRA regulations.  Other states that have yet to adapt the rule are still in discussions.  Below are updates from the mid-atlantic area: Maryland is in the final stages of drafting its proposal to integrate the major changes made by HWGI into COMAR 26.13.03 by January 2020.  The MDE is currently developing 14 regulatory changes affected by HWGI listed below: Program Regulation Title Purpose Oil Control Program UST Regulations Chapters revised to comply with current federal UST regulations, to remove obsolete language, and update current practices. Solid Waste Program Solid Waste Management A review of the regulations pursuant to State Government Article, §§10-130-10-139 revealed the need to update these regulations due ...

The Environmental Protection Agency’s (EPA) Hazardous Waste Generator Improvement (HWGI) rule has been in effect since May 30, 2017.  Regardless of generator status designation, there are some important tasks generators must complete.  Here is a summary of the most important of those requirements. ·         Episodic events – Generators can exceed their designated generator status threshold once per year.  Additionally, they can petition for an additional “unplanned” event within the same year.  Generators must have an EPA ID and advise the EPA at least 30 days prior to the event.  In the case of an “unplanned” emergency, the generator must advise the EPA with 72 hours. (§262 subpart L ) ·         Re-notification – SQGs are required to re-notify of waste activities using Form 8700-12 every four years starting in 2021.  LQGs continue current system of re-notification as part of its bie...

Among the many changes implemented in EPAs Hazardous Waste Generator Improvement (HWGI) rule we’d like to focus on Contingency Plan & Labeling Requirements. Contingency Plan One very notable aspect in which the HWGI rule has become more stringent is in the contingency plan requirements for Large Quantity Generators (LQGs).  Prior to the HWGI rule the issue became apparent that LQGs submitted lengthy contingency plans to local emergency responders and at the moment of an emergency response event, the responders would have to search entire plans to find the most important information.  Although LQGs are already required to submit contingency plans, New LQGs now have to include a Quick Reference Guide (described as an Executive Summary in the proposed rule) that contains information most critical for immediate response to an event.  Already existing LQGs are required to include a Quick Reference Guide when they otherwise update their contingency plan.  The go...