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Spill Prevention, Control, and Countermeasure (SPCC) Regulation was originally published in 1973 and went through major revisions since then. It is currently undergoing rulemaking to include hazardous substances. Review the following eight points and evaluate if your facility is EPA inspection ready for the existing SPCC regulations: Applicability determination (capacity vs. quantity) If the facility […]

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A comprehensive Environmental, Health & Safety (EHS) program is very important at most organizations to keep the workers safe and meet environmental permitting and compliance requirements. All facilities whether its pharmaceuticals, chemical, energy, or commercial institutions, need to maintain an untarnished track record for its stakeholders. Nonetheless, achieving and maintaining success of the EHS department […]

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Only trained, capable, and ready members of pollution prevention team (PPT) should undertake the stormwater sampling.  Below is general overview of the most important features of the stormwater sampling requirements. Qualifying Storm Event Criteria The depth of the storm must be greater than 0.1-inch accumulation. The storm must be preceded by at least 72 hours […]

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An Overview of Most Frequently Cited Lockout/Tagout Standards by OSHA
– Establish a LOTO Program
– Develop Machine Specific Procedures
– Conduct Periodic Inspections
– Provide Lockout/Tagout Training
– Proper use of Lockout/Tagout procedures

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Stormwater permitting is mandated in EPA regulations for “industrial activities.” EPA’s definition of “industrial activity” is complex and detailed in 40 CFR 122.26(b)(14). The applicability is based upon the Standard Industrial Classification (SIC) code assigned to the facility and most manufacturing operations can make the determination in-house. It is important to note that stormwater discharge […]

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Following are the most cited hazardous waste violations by EPA and state agencies; and recommendations to minimize these violations. Failure to mark containers with the “Hazardous Waste” label. Have a steady supply of labels on hand. Having more than 55 gallons of hazardous waste at the Satellite Accumulation location. Provide periodic training to all operators. […]

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EPCRA requires industry to report on the storage, use and releases of hazardous substances to federal, state, and local agencies. About 500,000 products are covered to report under hazardous chemical storage requirements (Section 311/312). About 650 toxic chemicals and categories are covered to report under toxic chemical release inventory (Section 313). About 1000 chemicals are […]

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