Imagine you are installing a new process line at your facility, and a building addition to house that line. During the construction and installation, along with your employees, you may have a general contractor on site to oversee the project, subcontractors to do the wiring and other specialized work, additional subcontractors to assist the construction or demolition of the surrounding area, temporary workers to clear the land, venders on site to tell you how great their equipment is, and maybe even some visitors from corporate. With these companies and workers walking and working on your property at any given time, how do you know who is responsible for preventing injuries and accidents? And, in case there is an injury or illness, who has failed to provide a safe workplace and is not compliant with OSHA requirements? Continue reading “To Record or Not to Record: Responsibilities on a multi-employer worksite”

Over the past several decades, the Occupational Safety and Health Administration (OSHA) as well as the National Fire Protection Association (NFPA) have been expanding and enforcing regulations and standards designed to lessen the potential for disasters in facilities that handle combustible dusts. Any facility that processes or handles combustible solids or dusts, such as food products, wood, plastics, and metals should take preventative measures in identifying and managing the potential fire and explosion hazards present during normal operations at an industrial facility. A catastrophic incident of a facility failing to properly identify and mitigate the hazards associated with handling combustible dust is the explosion at the Imperial Sugar factory in east Georgia back in 2008. This combustible dust explosion killed 13 people and injured 40 more. This accident was entirely avoidable. Continue reading “Combustible Dust Regulation Updates”

In November of 2016, the Environmental Protection Agency (EPA) published its final rule on hazardous waste generator requirements. This rule provides guidance and best management practices (BMPs) for all levels of hazardous waste generators. This article will explore some of the changes in requirements for hazardous waste generators with the passage of the new rule. Continue reading “Changes to Hazardous Waste Generator Regulations”

After two rounds of public comments, the final version of Georgia’s General Multi-Sector Industrial Storm Water Permit (GAR050000) renewal has been issued. The permit will become effective on June 1, 2017. Covered industrial facilities will need to meet the following compliance deadlines:

All NOI’s and Annual Reports must now be submitted via Georgia EPD’s Online System (GEOS). Below are links to the final permit and to the GEOS website. If you have any questions or need assistance with submitting an NOI or updating or developing your SWPPP, please contact us.

New Georgia Multi-Sector Industrial Stormwater Permit – http://epd.georgia.gov/sites/epd.georgia.gov/files/related_files/site_page/FinalSigned2017IGP-20170306.pdf

GEOS Website – http://epd.georgia.gov/geos/

Georgia EPD’s NPDES Industrial Storm Water General Permits website – http://epd.georgia.gov/npdes-industrial-storm-water-general-permits

The first International Standard Organization (ISO) 14001, Environmental Management System (EMS) document was published in 1996 to provide a standard basis for all voluntary EMS’s to be certified as compliant systems by third party auditors. ISO14001 has since been revised twice, in 2004 and 2015, to make it more comprehensive and useful. In the newest revision, organizations and facilities can be certified under the 2004 standard for three years from the publication of the 2015 document. Therefore, organizations that wish to receive certification with ISO14001 have until September 2018 to update their EMS’s to be compliant with the 2015 revision. Continue reading “ISO-14001: Updating Your Environmental Management System”

One environmental reporting requirement that is often overlooked, but enforced regularly by the Environmental Protection Agency (EPA), the Georgia Environmental Protection Division (GA EPD), and other state agencies is Tier II Reporting under the Superfund Amendments and Recovery Act (SARA).

If your facility stores any chemical or product on site that requires a Safety Data Sheet (SDS) (e.g. petroleum products, grains, paints, lead-acid batteries, liquid oxygen, etc.) in amounts over 10,000 pounds, your facility is required to notify the state, your local emergency planning committee, and the local fire department of these materials on an annual basis. Additionally, if you store any extremely hazardous substances (e.g. sulfuric acid) above its reportable quantity, usually 500 or 1,000 pounds, your facility is also required to report under the SARA Tier II requirements. The annual deadline to submit Tier II reports is March 1.

If you would like assistance determining whether or not your facility is required to report under the SARA Tier II requirements, or need assistance completing the reports, please give me a call at (770) 363-6330, x.113 or email me at jhaar@conversiontechnology.com.

The US Environmental Protection Agency (EPA) has proposed to issue an Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP), also known as the “PCWP MACT” or “Kiln MACT”. This is an important update for those in the lumber industry, as lumber drying kilns are one of the sources regulated under the standard. While the PCWP NESHAP covers many types of process units, this discussion will be primarily focused on the standard’s effect on sawmills operating lumber drying kilns.

 What is the history of the rule? Continue reading “EPA Proposes Collection of Information for “Kiln MACT””

The US Environmental Protection Agency (EPA) has issued a final rule to revise the Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program. The update contains over 60 revisions and will be effective May 30, 2017. One of the EPA’s objectives of the revisions is to reorganize the regulations to make them more user-friendly and easier to understand for generators. The revisions also include changes that address gaps in existing regulations, provide more flexibility for generators to mange hazardous waste, and make technical corrections. 

Below is a list of some the program changes: Continue reading “EPA Issues Changes to RCRA Hazardous Waste Generator Rule”

Most industrial facilities are required to maintain a Storm Water Pollution Prevention Plan (SWPPP) in order to minimize the discharge of pollutants from the property. The U.S. Environmental Protection Agency (US EPA) releases a Multi-Sector General Permit every five years that the majority of states model their permits after. These 6 steps are important for maintaining a compliant SWPPP in most states:

Continue reading “7 Routine Steps to Comply with Industrial Storm Water Pollution Prevention Plan Requirements”

swq_sdt1Under the Georgia Industrial Storm Water Permit, all covered facilities are required to conduct a smoke, dye, or equivalent test of all floor drains and sinks in industrial areas. These tests are to ensure that these sinks and floor drains do not discharge to storm water conveyances, and must be conducted by the end of the permit, May 31, 2017.

Continue reading “Have You Conducted Your Smoke and Dye Test?”