Q&A: Anhydrous Ammonia Leaks
Recently, we received the following question from a subscriber: What does OSHA say about initial entry into an area with a suspected gas leak of anhydrous ammonia of unknown quantity and the use of an SCBA?
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Ensure Compliance with New Hazardous Waste Generator Requirements
On November 28, 2016, the EPA published the final Hazardous Waste Generator Improvements Rule, providing a much-needed update to the Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulations. By enhancing facility safety and the communication of onsite risks to emergency responders, the revisions are a significant attempt to address the challenges hazardous waste […]
OSHA Cites Illinois Contractor for Continuing Fall Violations
Elmer Miller, an Illinois construction contractor operating as Miller Building Systems LLC, faces $354,912 in Occupational Safety and Health Administration (OSHA) fines after the agency again found workers were exposed to falls from elevation at four jobsites. The agency cited Miller with four willful fall protection violations, OSHA announced July 12. Agency investigators observed violations […]
EPA Has Eased Up on Criminal Enforcement
Using data from the U.S. Department of Justice (DOJ), Public Employees for Environmental Responsibility (PEER), a liberal environmental group, reported that the EPA’s criminal enforcement division under President Donald Trump is reaching new lows in the number of referrals for prosecution it makes to the DOJ.
Back to Basics: Building and Maintaining Psychological Safety
Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine the importance of workplace psychological safety. While workers face many physical hazards on the job, it’s important to consider the non-physical hazards as well. Psychological safety is a crucial part of any […]
EPA Moves to Implement HSM Orders from D.C. Circuit
In a final rule promulgated without a prior proposal, the EPA is revising regulations associated with the definition of solid waste under the Resource Conservation and Recovery Act (RCRA). The revisions apply specifically to rules the Agency issued in 2008 and 2015, which addressed the conditions under which hazardous secondary materials (HSMs) are legitimately recycled.
EPA Outlines PFAS Action Plan
On April 28, 2025, the EPA announced upcoming agency actions to address per- and polyfluoroalkyl substances (PFAS). While the list of actions is lengthy, experts say it lacks substantive measures. In line with EPA Administrator Lee Zeldin’s Powering the Great American Comeback initiative, the Agency’s “work in this space will advance Pillar 1: Clean Air, […]
Four RMP Documentation Violations to Avoid
Four RMP Documentation Violations to Avoid 1) Failure to include all the required documentation for the alternative release scenarios for the chemical pipe leak and natural gasoline vapor cloud fire as required by 40 CFR 68.39(b). 40 CFR 68.39(b) establishes the offsite consequences analysis documentation requirements for alternative release scenarios that include a description of […]
2014 EPCRA Enforcement Roundup
2014 EPCRA Enforcement Roundup What do a wood door manufacturer, an organic food company, a wire manufacturer, a cheese manufacturer, and an oil sands crude refinery have in common? On the surface, it would appear they are pretty different, but when it comes to compliance with EPCRA, all reached settlements with the EPA during […]
Hazardous Waste Compliance in Construction, Demolition, and Renovation
Hazardous Waste FAQs for Construction, Demolition, and Renovation Projects by CESQGs Q: Do CESQGs have to comply with any recordkeeping and reporting requirements related to hazardous waste in C&D debris? A: As long as a generator remains a CESQG and is in compliance with the CESQG hazardous waste requirements of 40 CFR 261.5, it is […]