Previously, there was an independent software used to prepare these reports. This year (reports to be submitted in March 2018) HW Biennial Reports have to be prepared and submitted using the EPA RCRAInfo Industry Application (RIA) software.
Here’s what’s new:
- The Biennial Reporting software is a part of the EPA RCRAInfo Industry Application (RIA) which is also a part of the EPA CDX system – so everyone who prepares and submits a HW biennial report needs a CDX account and to register in the RIA system.
- MassDEP noted to be sure you understand that there are a number of roles for RIA and whoever signs up as the Site Management Role will have control not only of the HW Biennial Report roles and content but also any roles related to the eManifest (expected this summer), and Generator Notification form (expected in the near future), etc. (Basically anyone with a waste role on CDX related to the client’s facility). So CAPACCIO is advising clients to be careful who they assign to that role. Once roles are assigned, you need to make sure that those people have CDX accounts. If they don’t have accounts, one of the first things you need to do is set a up CDX account and then register on RCRAInfo.
- That’s because EPA has not loaded the SI form template (form with your site information) into the RCRAInfo Biennial Report site and you cannot submit the report without completing an SI form. The form will likely be available in mid-January.
Extra! Extra! Read All About It!
The Assault on Health and Safety Begins!
Deregulation policies a threat to worker safety!
OSHA Delays Electronic Record-Keeping Rule!
Talk of scrapping two regulations for each new one adopted!
Proposed $2.5B Cut to Dept. of Labor’s Budget, Elimination of Chemical Safety Board
During the past six months, there has been lots of talk (and action) in Washington about reducing and eliminating regulations, repealing OSHA rules, and imposing major staff reductions and budget cuts in agencies dedicated to increasing worker health and safety (OSHA, MSHA, NIOSH, and The Chemical Safety Board). Despite all the headlines, businesses throughout the country must continue to operate and, unfortunately, workers continue to be injured or killed on the job on a daily basis.
Although safety regulations and enforcement actions can have a positive effect on reducing worker injuries, they do not prevent them. It still remains everyone’s responsibility within the workplace to promote, create, and maintain a safe and healthy work environment despite whether or not a formal regulation is in place. From top management down through all levels of the business hierarchy to the employees on the shop floor, safety should be everyone’s top priority.
Regulations or the threat of enforcement penalties and fines should not be the sole driving force in providing safe and healthy work environments. Many highly successful businesses foster safe working conditions and decide on their own to implement safety programs that exceed the basic requirements spelled out in safety regulations.
Bottomline –Safety should remain at the top of your priority list every day for yourself, your fellow employees, and your family and friends while you are away from the workplace.
For more information or of you require assistance with your health and safety programs, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or firstname.lastname@example.org.
In our continuing series about auditing and how it can be similar to an annual physical, we will discuss an often overlooked area; a deep dive into air permitting. Just as an annual physical may gloss over some of the more specific parts of the body, air permits can also sometimes be overlooked but doing so can lead to a potential problem in the long run.
Every year, the Doctor asks a list of questions, such as, “Has anything changed in your immediate family’s health (diagnosed with diabetes, heart disease, ADHD)? Who lives at your home? Do you have any pets? Do you have any concerns at the moment? In a similar fashion, prior to an air audit, the auditor will send you a list of questions. Do you have an air plan approval? Do you have air emissions tracking sheets? Do you have a control device? All of these questions help the Doctor/Auditor get an overview of your health/facility and any specific areas that may be of concern.
Your responses become the roadmap for the auditor. If you stated you do not have an air plan approval, the auditor may request a listing of how much solvents are used onsite to determine if the facility needs to further evaluate/justify whether a plan approval is needed or if there is an exemption that excludes a facility from obtaining an air plan approval. The auditor will check if you are maintaining documentation that states how you are complying with the regulation or why your facility meets the listed criteria exemption.
As with your annual checkup, the more symptoms/details you can provide to the Doctor increases their ability to provide you with advice on what you need to do to maintain a healthy lifestyle. Are there warning signs that you may not have noticed with your air permits?
- Your volatile organic compound (VOC) emissions from a small process is approaching permitting level
- The state updated their Regulated Toxic Air Pollutant (RTAP) list and you missed the notice
- EPA has finalized a regulation that applies to you
- An emergency generator was installed at your facility and was not self-certified
- Emission statements were not submitted
These are some of the most common findings found during an air audit. What happens if you don’t see the warning signs or you ignore them for too long? The small warning signs can compound each other to create one larger issue. Just like your health, it is good to go through the annual checkup to help catch the small warnings before it becomes a larger issue and is too late to be fixed.
Just like there are apps to track your health on your phone, computer, or other electronic device, CAPACCIO’s EHS DashboardTM can help you track your facility’s data making an audit by the state or federal inspectors that much easier. Learn more about the dashboard at www.ehsdashboard.com.
For more information on air permits or other air compliance related questions, please contact Lynn Sheridan, EIT, at 508-970-0033 ext. 122 or by cell at 774-249-2565 or email email@example.com.