Category: EHS Management

EPA’s eDisclosure Portal has Launched!

Effective December 9, 2015, the EPA launched a new tool that allows regulated entities to electronically report self-discovered violations. The tool, called eDisclosure, will function under the Agency’s two self-policing incentive policies—the 2000 Incentives for Self-Policing Discovery, Disclosure, Correction and Prevention of Violations and the 2000 Small Business Compliance Policy.

Wastewater Exemption

We treat our compressor condensate prior to discharge using this a crude oil water separator in a 55 gallon drum that has a 24 gallon oil storage compartment. Does the wastewater exemption apply? We are assuming that you are regulated under the federal Spill Prevention, Control and Countermeasure (SPCC) regulations, and that your facility meets […]

Next on the GHG Hit List: Refrigerants

Back in June 2013, President Obama announced his Climate Action Plan, a major component of which is to cut carbon pollution in the United States. The outline to accomplish this focuses on renewable energy, clean energy innovation, energy efficiency, and a cleaner transportation sector, but it also specifically addresses cutting carbon emissions from power plants, […]

OSHA 300 Log—Is It Recordable? 4 scenarios

The end of the year is a good time to review workplace injuries and illnesses. Yesterday we looked at the requirements for Occupational Safety and Health Administration (OSHA) Form 300A, The Summary of Work-Related Injuries and Illnesses. Today we will address various scenarios for recording injuries and illnesses under OSHA’s regulations. Background. Under OSHA’s injury […]

OSHA Form 300A—What, Who, When, and Where

As the year winds down, it is time to start preparing your Occupational Safety and Health Administration (OSHA) Form 300A for posting. Today we will review the requirements for Form 300A, and tomorrow we will address various scenarios for recording injuries and illnesses under OSHA’s regulations. General Background Information Under OSHA’s recordkeeping regulation at 29 […]

Two Court Cases Find in Favor of the EPA

EPA’s nonattainment designations of two counties—one in Montana and one in Michigan—under the Agency’s 2010 National Ambient Air Quality Standards (NAAQS) for sulfur dioxide (SO2) were challenged in the U.S. Court of Appeals for the D.C. Circuit in two separate petitions that the court consolidated. According to the court, the two claims had “virtually nothing […]

Changes Issued to Simplify Exceptional Events Rule

EPA’s 2007 Exceptional Events Rule (EER) was intended to give state and local agencies an avenue to remove data about certain types of monitored air pollution from area attainment/nonattainment designations under the national ambient air quality standards (NAAQS). However, the EER required states to support their applications for data exclusion with analyses that were so […]

House Passes Joint Resolution to Block CPP

The U.S. House welcomed President Obama’s return from the Paris climate change conference by passing a joint resolution to block the EPA from implementing its Clean Power Plan (CPP) to regulate carbon emissions from existing power plants.