The EnviroBlog

Neither The Environmental Protection Agency (EPA) nor most states specifically define trace chemotherapy (often shortened to “chemo”). EPA has recently recognized trace chemo waste as empty IV bags, tubings, vials, gowns, gloves and other items that are contaminated with residual chemo pharmaceuticals.  To add to the overall confusion, EPA lists only nine chemo agents, but we must consider that the regulations were written years ago and have not been updated since the approval of numerous new drugs now on the market. What is Trace Chemotherapy Waste? All chemo paraphernalia should be managed as trace chemo waste if there is any risk exposure to chemo contamination. Trace chemo waste includes: RCRA empty vials, syringes, IV bags, tubing, gowns, gloves, wipes other paraphernalia associated with routine handling, preparation, and administration of chemo wipes and other materials used during routine cleaning and decontamination of a biological safety cabinet or glove box ...

For those of us who ship lithium batteries, you are probably well aware of the recent regulatory changes regarding them.   These changes were enacted in 2017 and called for a two-year transition period during which “old” labels could still be used while phasing in the “new” labels.   January 1, 2019 marked the end of that phase-in period and you can no longer use the “old” labels. We strongly recommend if you haven’t already started using these new updated labels yet, now is the time to do it! To ensure you are using the correctly marked labels, below are some examples of “approved” and “no longer approved” labels.   Consult with your local Enviroexpert today to ensure correct shipping of your lithium batteries! YES NO

Effectively developing, implementing and managing an integrated waste solution requires a very specific set of expertise, resources and planning.   We’re here to ensure your organization has the solutions and services you need to implement a scalable program that handles all you waste streams at all your locations. As your single source partner with our Enviroexpert Integrated Waste Solutions, we offer: ·          Assess and evaluate your companywide waste management and disposal programs for all waste including but not limited to hazardous waste, non-hazardous waste, pharmaceutical waste, regulated medical waste, universal waste, recycling materials, and secure and confidential documents for shredding.  We also assess points of generation and equipment efficiency with focus on evaluating collective effectiveness and identifying needs and conditions for success. ·          Design, Deve...

While the EPA normally prohibits hazardous waste treatment without a permit, in Maryland one rare exception can be found.   Using an ENU under certain conditions and meeting certain requirements in Maryland help some generators of hazardous waste lower disposal cost and sometimes even generator status designation. An Elementary neutralization unit is defined as a device which is used for neutralizing wastes which are hazardous only because they exhibit the corrosivity characteristic and is a tank, tank system, container, transport vehicle, or vessel.   In order to reap the extended benefits of using this equipment you must meet the following requirements: 1.        The waste must only be corrosive characteristic (D002).   If the waste is hazardous for any other reason (ie. Toxic in addition to corrosive), the benefits cannot be applied. 2.        The waste must be treated in an ENU immediately upon gene...

Are you on track to complete your TRI report on time? What are TRI toxic chemicals? Every year on July 1, Toxic Release Inventory (TRI) Reports are due as required by EPCRA Section 313.   Section 313 contains a list of specific chemicals and chemical categories and requires facilities to file a TRI report annually for each “Section 313” chemical exceeding an activity threshold. Who needs to report?   If you meet all three of these criteria you are required to report: 1.        10 or more full-time employees or the equivalent 2.        Are in a TRI-covered industry sector (ie. NAICS codes are listed) 3.        At least one TRI-listed chemical meets minimum threshold during the calendar year Is this the same as Tier II? Although both are mandated regulatory reports and deal with chemical inventory, there are basic differences that make them distinct from one another...

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. Belo...

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 req...