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 cti@conversiontechnology.com.

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”

On September 6, 2019, the EPA published a proposed amendment to what is commonly referred to as the Plywood or Kiln MACT. This proposed amendment does not address lumber kiln emission standards. EPA has stated that the lumber kiln emission and work practice standards will be addressed in a later proposed amendment.

This proposed amendment to 40 CFR 63, Subpart DDDD: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plywood and Composite Wood Products (PCWP) is based on the completion of the residual risk and technology review. The review has found that no revisions are necessary to the current controls in the original rule. The rule does propose removal of the startup, shutdown, and malfunctions plans as EPA has deemed this to be sufficiently addressed in the work practice standards of the regulation, as well as by the Clean Air Act (CAA).

The proposed rule is open to comments until October 21, 2019. All submissions must include Docket ID No. EPA-HQ-OAR-2016-0243-0034. The EPA encourages that comments be submitted through the Federal eRulemaking Portal located at https://www.regulations.gov/.

If you need help identifying how this proposed rule change will affect your facility or need assistance with providing comments to the EPA, please contact us at (770) 263-6330 or cti@conversiontechnology.com.

 

The National Fire Protection Association (NFPA) is an organization tasked with developing and maintaining fire protection and life safety standards in the United States and worldwide. In addition to subjects such as sprinkler design, flammable liquid storage, and emergency exit requirements, NFPA has standards that deal specifically with combustible dust; a topic that CTI has been focused on for over a decade.  There are several NFPA Standards that address combustible dust: NFPA 652 – Standard on the Fundamentals of Combustible Dust, is the overarching standard that applies to all facilities, and there are also several commodity-specific dust standards (e.g. 61 for agricultural and food, 664 for wood products, 484 for metals). CTI is a principal member of the NFPA 61 Technical Committee for Agricultural Dust and has worked with several of the other committees. All of these standards are changing, and CTI is here to help our clients understand what that will mean for them. Continue reading “Changes to Combustible Dust Standards”

Come say hello to Adam Haroz, one of CTI’s Engineering Managers, as he will be speaking at this year’s Region IV VPPPA Conference in Chattanooga, TN on June 19th.

Adam Haroz will be discussing how the regulations governing industrial machinery have shifted the need for conducting risk assessments on robotic systems from a good practice to now a mandatory requirement. The discussion will emphasize the benefits of conducting an on-site risk assessment. It will also highlight the need to identify the hazards and assess the potential risks associated with robot operations when selecting and designing safeguarding measures. He will review the methodology for conducting a risk assessment for different robotic systems, as well as other industrial equipment, how to assess the adequacy of current safeguards, and methods for determining the risk reduction measures required.

The Voluntary Protection Program (VPP) is designed to encourage cooperative efforts between employees, management and OSHA for the purpose of improving workplace safety and health. The VPP concept recognizes that workplace safety and health can be enforced in a compliance atmosphere and can be enhanced in a cooperative atmosphere. OSHA recognizes and partners with worksites that demonstrate excellence in Safety and Health.

Region IV VPPPA is the region that serves the eight Southeast states. (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee)

For more information on the VPPA or to register for the Region IV VPPA Conference click the following link: http://www.regionivvppconference.com/


On November 25, 2018, the National Fire Protection Agency (NFPA) issued an updated version of NFPA 45 – Standard on Fire Protection for Laboratories Using Chemicals. NFPA 45 includes information regarding fire protection requirements for laboratories, laboratory design, vent hood use, and safe quantities of flammable materials allowed to be stored and used in the laboratories. The 2019 edition of the standard includes minor changes from the previous 2015 version. Inspection, testing, and maintenance of fire-extinguishing systems in ductwork and chemical fume hoods has been revised from a specific time interval to a schedule that is deemed suitable for the type of system. Also, a minimum inspection frequency of 1 year has been added for chemical storage. The revision of the standard includes references to NFPA 30 – Flammable and Combustible Liquids Code for quantities of flammable and combustible liquids within liquid storage areas that are indoors.

Continue reading “Is Your Laboratory Compliant with OSHA and NFPA Requirements?”

On December 12, 2018, the Occupational Safety and Health Administration (OSHA) began to enforce compliance with the updated Beryllium Rule that went into effect on May 20, 2017. The purpose of this updated Rule is to limit employee exposure to beryllium, which is known to cause lung cancer and other chronic beryllium disease. Continue reading “Updates to the OSHA Beryllium Standard”

On January 17, 2017, The Occupational Safety and Health Administration (OSHA) updated their Walking-Working Surfaces and Fall Protection standards. While most of the changes to the rule have already been put into effect, several provisions have delayed effective dates, many of which are coming up soon. Is your facility ready to comply with these new rule changes? Continue reading “Is Your Facility Ready For The Updated OSHA Ladder Rules?”

Changes to EPA “Once In Always In” Policy for MACT Rules

On January 25th 2018, the EPA released a guidance memo reversing the “Once in Always in” (OIAI) policy regarding the classification of major source facilities subject to MACT (Maximum Achievable Control Technology) standards. A major source is defined as any facility which emits at least 10 tons of any Hazardous Air Pollutant (HAP), or 25 tons of any combination of HAPs. This policy, which has been in place since 1995, stated that any major source that becomes subject to a MACT rule must stay in compliance with that rule permanently, even if the facility finds a way to drop emissions below major source thresholds. Continue reading “Federal, State, and Local Changes to Air Permitting Requirements”