If your facility is a Large Quantity Generator (LQG), meaning it generated more than 2,200 lbs of hazardous waste and/or 2.2 lbs of acute hazardous waste per month during 2019, the upcoming deadline applies to you.
LQG are required to complete a Hazardous Waste Report (also called the Biennial Report) and a Hazardous Waste Reduction Plan for waste generated in 2019 by March 2, 2020.
Conversion Technology Inc. (CTI) is an environmental, health, and safety consulting firm with over 30 years experience covering the above reports and other aspects of permitting, and environmental, health, and safety regulatory compliance. If you need help preparing the waste reports, please contacts us at 770-263-6330 or firstname.lastname@example.org.
OSHA is working with the Robotics Industries Association and the National Institute for Occupational Safety and Health (NIOSH) on developing a training program for inspection officers to better understand how robots in general industry operate, what the requirements are for employers, and how to better identify the potential hazard. By 2020, it is expected that OSHA will have the knowledge necessary to better respond to an incident caused by an issue with robotic safety.
If your facility utilizes industrial robots, including Automated Guided Vehicles (AGV) or collaborative robots, contact CTI to determine if your robotic equipment meets safety standards and if you are compliant with OSHA regulations.
In April 2017, the International Agency for Research on Cancer (IARC) determined that welding fume is considered to be a known carcinogen that can lead to lung cancer in humans. This decision may affect all facilities who employ welders or other personnel conducting hot work, as these personnel may be exposed to welding fumes. Employers of welders should ensure engineering and administrative controls are implemented to reduce employee exposure to welding fumes in the workplace. Continue reading “Welding Fumes Have Been Classified as a Group 1 Carcinogen”
On September 9, 2019, the US Environmental Protection Agency (EPA) released an Air Plan Approval that will grant approval of proposed changes to Georgia’s Nonattainment New Source Review (NNSR) permitting rules, proposed in Georgia’s July 2, 2018 SIP revision. The proposed changes have already been implemented by the Georgia Environmental Protection Division (GA EPD), and this Air Plan Approval is the EPA saying that it is okay for the GA EPD to continue implementation and begin enforcement. Continue reading “EPA Nonattainment New Source Review Updates – Georgia”
Several National Fire Protection Association (NFPA) standards for combustible dust were updated in 2019, including standards applicable to food, agricultural, wood product, plastic, pharmaceutical, and many other industries. The 2020 Editions of NFPA 61, 654, and 664 were all issued in the past few months. (Much like a new car model, the new NFPA editions are typically released in the year before the date of the edition.) Below are some of the major changes to these standards. If you have specific questions about how these changes may affect your facility, CTI’s combustible dust experts are available to talk. Continue reading “Updates to the Combustible Dust Standards”
The prevention of stormwater contamination is a major concern that does not discriminate between, and is applicable to, all types of industry. Stormwater can be defined as storm water runoff (e.g. rain flow), snow melt runoff, and drainage. All industrial facilities have some form of stormwater discharge which has the potential to be impacted by pollutants from different types of industrial activities, such as pallets stored outside, forklift traffic between buildings, outdoor parts storage, etc. Due to this potential, all industrial facilities in the United States are required to comply with National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Regulations. Noncompliance with any of the Industrial Stormwater Regulations, such as the discharge of stormwater mixed with pollutants from processes or other industrial activity, is a violation of the Clean Water Act, which regulates the discharge of pollutants to waters of the United States.
Facilities are required to ensure that any stormwater discharging from their property is free from contaminants by conducting analytical sampling. Continue reading “Management and Prevention of Stormwater Benchmark Exceedances”
Over the past decade, there has been a push by lumber manufacturers to install continuous dry kilns, or CDKs, to supplement or replace batch kilns. There are numerous benefits with CDKs, including higher quality lumber, more efficient combustion of fuel, pre-heating of green, undried lumber with heat that would be lost with a batch kiln, and elimination of charge turnover resulting in a significant increase in production efficiency. With all these benefits, comes a substantial problem: a dramatic increase in the generation of kiln condensate.
The regulations that apply to kiln condensate are complex and typically require stringent permits or alternative management techniques. CTI’s white paper provides an overview of the regulations that are applicable to kiln condensate, and it details the legal options lumber manufacturers have in managing it.
Click here for access to the white paper
Title: Combustible Dust Hazards and NFPA Compliance for Storage Equipment
Date: Thursday, October 17, 2019
Time: 12:00 PM EDT
Duration: 1.5 hours
CTI has teamed up with the Fike Corporation and CST to co-host an educational webinar on the ever-growing topic of dust hazards, NFPA Compliance, design approaches and retrofit issues. The webinar will cover:
- Dust Hazard Analyses
- Combustible Dust Deflagration Mitigation Practices
- Dust Hazards for Storage System Design Criteria
The Georgia Environmental Protection Division (EPD) continues to roll out features that require the use of the Georgia EPD Online System (GEOS), their online reporting portal. As more features and updates are added to this website, the EPD is taking a more active approach to reviewing the forms and reports that are being submitted. Lately, the biggest item under review seems to be Stormwater Annual Reports from 2017 and 2018. Special attention is being made to review the annual reports for completion of required tests (e.g. Smoke & Dye, stormwater benchmarks, etc.) and other actions. Continue reading “Georgia EPD to Increase Focus on Facility Online Submittals”
On July 26, 2019, the U.S. Federal Register published the Environmental Protection Agency’s (EPA) proposed amendments to the provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAP). The primary purpose of the proposed amendments is to withdraw the “Once In, Always In” (OIAI) policy regarding the classification of facilities as major sources of hazardous air pollutants (HAPs) subject to Maximum Achievable Control Technology (MACT) standards. A major source is defined as any facility which emits at least 10 tons per year of any HAP or at least 25 tons per year of any combination of HAPs. A facility that is not classified as a major source is considered an area source. The OIAI policy, issued in 1995, required major source facilities that are subject to a MACT standard to permanently comply with that standard even if a facility reduces its HAP emissions below major source thresholds. The withdrawal of the OIAI policy was also previously discussed in EPA’s guidance memorandum issued on January 25, 2018. Continue reading “EPA Proposes NESHAP Amendments to Withdraw “Once In, Always In” Policy for MACT Standards”