EPA Haz Waste Generator Rule Updates Reply

The Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program was originally promulgated in 1980. Since that time, the EPA has become aware of the need for more clarity, consistency, and flexibility within the program. EPA’s final rule, which was promulgated on May 30, 2017, revises the hazardous waste generator regulations making them easier to understand, and providing greater flexibility in how hazardous waste is managed.

Some key provisions where EPA is finalizing flexibility are:

  1. Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed, and
  2. Allowing a very small quantity generator (VSQG) (previously called conditionally exempt small quantity generators) to send its hazardous waste to a large quantity generator under control of the same person.

This program update is also implementing some Improvements to environmental protection and, therefore, several of the revisions to the hazardous waste generator regulations are more stringent than those in the previous version. One such revision requires Small Quantity Generators (SQGs) to periodically re-notify the EPA regarding their generator status every four years (SQGs needed to only notify once under the previous system).

You may Click Here for additional information on the RCRA Program Updates.  Please note that though the Federal regulations are currently in effect, the Massachusetts Department of Environmental Protection (MassDEP) has indicated they will not be adopting these updates until 2018.

We can help! Capaccio has RCRA experts that can assist you with the reporting and planning challenges associated with Federal and state hazardous waste programs.  If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 ext. 142 or adallaportas@capaccio.com.

 

 

New OHS Standard ISO 45001: Progress Towards Finalization Reply

Each year, nearly 2.2 million workers die as a result of an occupational injury or illness. This statistic is burdensome to organizations and society as a whole. To encourage a strong occupational health and safety program, the International Organization for Standardization (ISO) has been working on the development of a new Occupational Health and Safety (OHS) Standard; ISO 45001. This standard aims to provide organizations with the framework to manage the prevention of work related injuries, illnesses, and deaths.

ISO 45001 has been drafted to include many of the same concepts set forth in OHSAS 18001. The main differences between the two standards is that ISO 45001 has a much stronger focus on the context of an organization and requires top management to provide leadership in the development, management, and tracking of their company’s OHS Management System. It is expected that OHSAS 18001 will be withdrawn once the new ISO 45001 standard is published. Organizations certified to OHSAS 18001 will need to transition to ISO 45001 within three years of its publication.

Currently the new OHS Standard is in its second draft. A preview of this version is currently available for review.  For the next four months, the OHS Standard will be undergoing the translation and ballot phase of the review process. If a Final Draft International Standard (FDIS) is not required, the new ISO 45001 standard could be published as early as November 2017. If a FDIS is required, publication could be pushed back to the second quarter of 2018.

For more information please contact Bob King at 508-970-0033 ext. 113 or bking@capaccio.com or Katie Grasso at 508-970-0033 ext. 134 or kgrasso@capaccio.com.

Source Registration and Greenhouse Gas Reporting Update Reply

Recently, many facilities received an email from the Massachusetts Department of Environmental Protection (MassDEP) regarding the upcoming Source Registration (SR) and Greenhouse Gas (GHG) reporting deadlines and requirements. This e-mail states that the MassDEP is suspending the April 15, 2017 deadline for both SR and GHG reporting while they continue to work on combining these two reports into one web based platform.  During this process, the current reporting platforms will not be available.  It is currently not known when the system will be up and reports will be due.  When the reporting platform is ready, the MassDEP will be sending out letters with reporting deadlines to facilities. In the meantime, CAPACCIO recommends that facilities continue to compile their 2016 data and complete required calculations.
Let us know if you need assistance.

If you have any questions, please contact Lynn Sheridan at (508) 970-0033 ext. 122 or lsheridan@capaccio.com.

Stormwater Multi-Sector General Permit Annual Report Due January 30 Reply

The first annual report required by the new 2015 stormwater multi-sector general permit is due on January 30, 2017. The new annual report is different than the previous version as it now must be submitted electronically via EPA’s Central Data Exchange. The new annual report format now requires operators to upload a summary of the routine inspection findings, quarterly visual assessments, any benchmark monitoring exceedances, and any corrective actions that were taken over the course of the previous calendar year. While no documentation needs to be uploaded it will be important to have all the relevant documents available to facilitate a quick and complete submittal.

 If you need assistance with your report or have any questions, please contact Dave Averill, EIT, at 508-970-0033 ext. 146 or daverill@capaccio.com or Chris Walton, PE, BCEE, at 508-970-0033 ext. 139 or cwalton@capaccio.com.