Compared with the air quality monitoring methods of even a few years ago, today’s air monitor system offers its users a quicker, more effective, and comprehensive way to assess potential environmental hazards.

2nd Ave Subway Construction Muck House – What emissions from here are impacting the Local Air Quality?

The recently published article, “MTA: 2nd Avenue Subway Construction Not a Danger to Your Health,” responds to a rise in complaints about possible environmental health hazards from the construction. In the article, MTA Capital Construction President Michael Horodniceanu suggested the public faced no danger from the construction based on results from a fall 2011 Parsons Brinkerhoff (PB) air monitoring study.

The PB study highlights important facts and issues about the project and makes useful points about air quality monitoring in general; however, PB used the same traditional dust and vapor monitors and methods that were used at the World Trade Center recovery site in 2001.

In the last decade and especially over the last few years, superior air monitoring technologies have been developed and used to help ensure that emission rates from major hazardous waste remediation operations in the New York metropolitan area are kept as low as possible. The use of innovative, more effective, and more cost-saving air monitoring equipment and methods would have provided data for the PB study that would better support MTA’s assertions.

Greenlight Map View of Integrated Air Monitoring Data

• Differentiate the sources of air contaminants so that those associated with the construction can be distinguished from those of other background sources

• Determine when emission levels from the construction/remediation activity begin rising

• Deliver immediate information to construction management so that they can make timely decisions to protect workers and the public

• Measure the efficacy of engineering controls and work practices in reducing emission rates, even when concentrations are below project or regulatory safe levels

Given the options, PB and the MTA would have found these and other meaningful enhancements in air monitoring equipment and techniques valuable to the 2nd Avenue Subway construction project.

I encourage you to learn more about state-of-the-art air monitoring equipment, including integrated systems that allow users to make evidence-based decisions to protect workers and the public.

Second Avenue Subway (SAS) Project – Air Quality Monitoring Study of Construction Activities between 69th and 87th Street on Second Avenue

You can view the rule at HERE

One of the changes is the inclusion of an “Unclassified Hazards” category; a definition is provided below.  The U.S. Chemical Safety Board recently released a statement supporting the Unclassified Hazard category to allow for inclusion of combustible dust hazards on safety data sheets and labeling.

“Unclassified hazard” means a chemical for which there is scientific evidence identified during the classification process that it may pose an adverse physical or health effect when present in a workplace under normal conditions of use or in a foreseeable emergency, but the evidence does not currently meet the specified criteria for physical or health hazard classification in this section. This does not include adverse physical and health effects for which there is a hazard class addressed in this section.

It should also be noted that EPA began to make amendments in November of last year to regulations for the “Protection in the Workplace” (40 CFR 721.63) and “Hazard Communication Program” (40 CFR 721.72) components of the Significant New Uses of Chemical Substances regulations at 40 CFR 721 to align them with the GHS changes in the OSHA Hazard Communications Standard.

Want to stay informed? Emilcott publishes a timely email reminder, “EHS Regulatory Submissions”, 3x/year to keep our clients informed about upcoming deadlines. If you’d like to subscribe to that newsletter, just go to http://www.emilcott.com/subscribe.asp. If you need help with your Regulatory Submissions, contact Emilcott and ask for either an EHS or Hazardous Materials/Waste consultant.

What polymeric substances are exempt from reporting?

• Chemical substances described with the word fragments “*polym*”, “*alkyd”, or “oxylated” in the Chemical Abstracts (CA) Index Name
• Chemical substance which is identified in the TSCA Master Inventory File as-    Siloxane(s) and silicone(s)

-       Silsesquioxane(s)

-       Proteins (albumin, casein, gelatin, gluten, hemoglobin)

-       Enzymes

-       Polysaccharides (starch, cellulose, or gum)

-       Rubbers

-       Lignins

What polymeric substance are NOT exempt from reporting?

Those substances that result from hydrolysis, depolymerization, or chemical modification of polymers, regardless of the extent of these processes, if the final products are no longer polymeric (e.g., a mixture of amino acids that is the result of hydrolysis of a polypeptide), the chemical substances are not considered to be polymers and must be reported if not otherwise excluded.

If you need guidance for the EPA TSCA 2012 CDR Submission, Emilcott offers these helpful options

1. Contact Emilcott  directly with your questions about TSCA or other regulatory issues.
2. Subscribe to our free TSCA newsletter which delivers TSCA-related information just like this right to your mailbox.
3. Look for additional information at the Emilcott TSCA Center Page

At Emilcott, 2011 was a successful year where we were able to tackle new projects, serve our clients and continue to respond to current industry issues in the environmental, health and safety field. Though we have had many great memories from 2011, we would like to mention some of the things that stood out most in our business for 2011.

Hurricane Irene – the immense and powerful Atlantic hurricane that left a path of destruction and devastation was something that definitely stands out in 2011. We remember this event not only because of the wreckage caused by the storm, but also because of the after effects. The staff at Emilcott recognized the importance of addressing the legacy of water intrusion and the promise of mold after the storm and stressed to clients the importance of “timing” to address how to respond to this problem, as well as the importance of selecting the proper remediation technique along with an EHS mold expert and Emilcott’s mold remediation strategy. (Read more: Hurricane Irene Leaves a Legacy of Water Intrusion and the Promise of Mold)

Energy Sector – Emilcott has been thrilled to be able to participate in many different initiatives within the energy sector.  Regionally important to the growth of our economy, the ongoing infrastructure improvements have given us substantial health and safety support work. In EHSWire during 2011 we addressed many occupational hazards as Occupational Heat-related Illnesses where we went over the symptoms that workers may experience, as well as what should be done if someone does experience these symptoms. Besides dealing with working conditions such as heat, Emilcott also provided information on the truths about occupational slips, trips and falls which ended up costing American businesses $13.67 billion in workers compensation costs in 2008. Adhering to proper safety protocols and preventing injuries is something that benefits businesses and their workers. OSHA provides a Walking/Working Surfaces – Safety and Health Topic page which provides links to all the applicable standards.

With issues such as heat affecting the health of workers to preventing injuries on job sites, Emilcott has seen our fair share of mishaps. Being able to share our experiences and knowledge with others never gets old. From teaching someone the hazards about working near a crane, or things you should do when working in certain environments, Emilcott has always tried keeping people in the loop. We even have a 10-Hour Construction Industry Outreach Training Course based on the requirements established by OSHA which is a very hands-on and interactive class that we recommend to avoid a future work related issue. (Read more: Work Near a CRANE? Learn the Hazards!)

9/11 Tenth Anniversary – focused the changes that have occurred since 9/11/2001 such as the new precautions that have taken place on the American Chemical Security issue.   The DHS (the Department of Homeland Security) has been increasing their focus on utilities and chemical facilities which may become targets for terrorist activities and the DHS Chemical Facility Anti-Terrorism Standard (CFATS) now requires completing and submitting a Top Screen analysis to the DHS.

The James Zadroga Act, which was authorized to broaden, renew funding and extend benefits to Ground Zero workers whose death was a result of exposure, is of great significance and has put new emphasis on the importance of proper real-time environmental site monitoring. New technologies are available to protect site workers and the public from exposure to hazardous substances such as those from the collapse of the WTC towers. (Read more: 9/11 Tenth Anniversary Focuses on American Chemical Security)

Toxic Substance Control Act (TSCA) – was of major importance not only to Emilcott, but also to facilities who are manufacturers or importers of chemicals in amounts of 25,000 pounds or greater. With so many questions regarding TSCA and the changes, Emilcott decided to put on a free webinar along with posting a number of blogs that answered many of the concerns our clients had. Emilcott was able to use its expertise and help many clients with TSCA compliance questions and concerns regarding the developments of IUR reporting and reporting obligations in 2011 for the calendar year 2010. (Read more: August 2011 Update on the TSCA IUR-now-CDR Rule)

Though Emilcott has had many remarkable memories of 2011, we felt these 4 really left an impression on our business. Emilcott is privileged to know that we were able to assist our clients in many different businesses not only in 2011, but throughout our history. Emilcott looks forward to a productive 2012 and we are excited to see what this year has in store for us.

Do you have any environmental, health or safety concerns for 2012? If so, please share them with us below!

We just had our first cold weather snap in the northeast reminding me that 2012 is just around the corner.  A change in the seasons is our cue to ask Emilcott clients that manufacture or import chemicals:  Have you gathered the 2010 chemical volume data AND are you collecting the 2011 data needed for the 2012 TSCA Chemical Data Report?

In a previous blog we summarized the basic requirements of the inventory, production volume and use information that needs to be collected for the EPA’s TSCA 2012 Chemical Data Report (CDR). You can find this “bare bones chart” by clicking here.  The EPA recently presented the following key requirements  in this document  “Instructions for the 2012 TSCA Chemical Data Reporting.”

HIGHLIGHTS OF 2012 TSCA CHEMICAL DATA REPORTING (CDR)

• The determination of the need to report is based on production volume during calendar year 2011.
• Information on the reportable chemical substance must be reported during the 2012 CDR submission period, February 1, 2012 to June 30, 2012 (40 CFR 711.20).
• All reporting companies must report CDR data electronically, using e-CDRweb, the CDR web-based reporting tool, and EPA’s Central Data Exchange (CDX) system. Prior to submitting data, submitters must register with CDX.
• Reporting is required for all chemical substances listed on the TSCA Inventory, both organic and inorganic, other than polymers, microorganisms, naturally occurring chemical substances, certain forms of natural gas, and water (40 CFR 711.5 and 711.6) when manufacture (including import) of those chemical substances meets the other reporting requirements. Chemical substances that are the subject of any of certain listed TSCA actions may not be eligible for partial or full exemptions (40 CFR 711.6).
• Manufacturers (including importers) are required to report full manufacturing data, for calendar year 2011, and production volume only, for calendar year 2010, for all reportable chemical substances, when 2011 site-specific production volume equals or exceeds 25,000 lb (40 CFR 711.15(b)).
• Manufacturers (including importers) are required to report processing and use data, for calendar year 2011, for all reportable chemical substances, when 2011 site-specific production volume equals or exceeds 100,000 lb (40 CFR 711.15(b)). Inorganic chemical substances are no longer exempt from the reporting of processing and use information.
• Small manufacturers are exempt from CDR requirements unless they manufacture (including import) 25,000 lb or more of a chemical substance that is the subject of a rule proposed or promulgated under sections 4, 5(b)(4), or 6 of TSCA, or is the subject of an order in effect under section 5(e) of TSCA, or is the subject of relief that has been granted under a civil action under sections 5 or 7 of TSCA (40 CFR 711.9) and (TSCA §8(a)(3)(A)(ii)). See Appendix B for further information.
• Information submitted under CDR may be claimed as confidential; however, such claims must be made at the time of submission and substantiated in accordance with the CDR rule. Submitters must provide upfront substantiation of confidentiality claims for processing and use information as well as for confidentiality claims for site or chemical identity. A blank response or a response that is designated as “not known or reasonably ascertainable” may not be claimed as confidential (40 CFR 711.30).

The EPA is frequently adding information to their Inventory Update Reporting and Chemical Data Reporting Resource page.  And Emilcott will continue to update our TSCA Resource Center with helpful information — check in often!

If you need guidance with the information that you should be gathering (starting now!) for the EPA TSCA 2012 CDR Submission, please contact Emilcott!.You can also subscribe to our TSCA newsletter to be kept up to date and enroll for our free webinar (date to be announced soon) by sending an email to pkaufmann@emilcott.com.  Feel free to post any questions below in the comments section and we will respond quickly.

Upcoming TSCA Reporting Period:  February 1 – June 30, 2012.

As of August 6, the EPA has finalized the TSCA IUR — now named the Chemical Data Reporting (CDR) – Rule. There are many changes with the TSCA IUR to CDR  … some of these will be in place for the 2012 reporting submission and many more for the 2016 submission.

The final rule adopted many of the requirements included in the proposed rule (see What are the Changes?) — and, thankfully, the majority are not retroactive. At Emilcott, we are asking our clients to define what needs to be collected for the 2012 submission period with 2011 as the Principal Reporting Year. If your facility uses chemicals or is an importer who falls under TSCA’s CDR guidelines (remember, they’ve changed!), your company will need to collect more data and information than that originally planned for the 2011 IUR submission. The chart below is a bare bones list of the inventory, production volume and use information that needs to be collected for the 2012 Chemical Data Report (CDR). And, as stated earlier, your 2016 submission will have even more requirements.

Submit Your Form U Electronically

For the 2012 CDF, all submissions will be required to use the EPA’s free, web-based reporting tool, e-CDRweb, for completion of Form U. In preparation, the EPA will schedule another informational webinar on the electronic submission tool in late September with beta trials completed by early October. Please ask Emilcott if you will need help with the Form U filing.

Additional TSCA Information

Emilcott has set up an online “TSCA Resource Center” and over the next few weeks will be creating a dedicated TSCA landing page to contain all the information related to both the CDR Final Rule and other TSCA New and Existing Chemicals topics. Links to all EHSWire TSCA blogs will also be located there for quick reference. If you have any questions or would like to consider Emilcott as a TSCA consultant, please give us a call at 973-538-1110 or send an email to pkaufmann@emilcott.com

Did you miss the TSCA 2006 Form U submission?

You must notify the EPA that you missed reporting for the 2006 IUR within 21 days of your discovery.  The EPA has an Audit Policy for Self-Disclosure in which drastic fine reduction is possible if the requirements outlined by the Agency are met.  This policy is presented on the EPA Compliance Incentive and Auditing web site (http://www.epa.gov/compliance/incentives/auditing/auditdisclose.html). If you would like help, Emilcott has been brought in to work with multiple US and International clients with US facilities that inadvertently missed the Form U deadline due to either misunderstanding or ignorance of the regulations. Our advice is to not wait!

Paula Kaufmann, CIH

We have some news on this year’s TSCA IUR Form U submission.  Well, it really isn’t information about the requirements – but we do know that this year’s Form U submission period will not be June 1 to September 30.  It will most likely be later this year.  So, we all can move that task to another segment of the calendar year!

More Information

On May 11, 2011, the EPA issued a Federal Register Notice amending the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) regulations by delaying  the June 1 to September 30 submission period for the 2011 Form U reports.  The notice indicated that this delay will not alter the timing of subsequent submission periods (e.g., the submission period from June 1, 2016 to September 30, 2016).  This is an interesting statement as one of the changes included in the proposed IUR Rule is a change of the reporting period cycle to every four (4) years from the current five (5) year cycle.

The EPA is delaying the submission period because the proposed IUR modifications rule has not yet been finalized. EPA expects to have the final version of the changes to the IUR reporting requirements in the near future. The revised 2011 submission period will be announced with the publication of the final IUR modification rule. 

How does this delay what the EPA rule refers to as a “suspension” affect what needs to be done for the 2010 reporting period?  It seems that the EPA will mandate a new submission period but it is not clear when this will be during 2011.

• We are assuming that the reporting period will remain as the 2010 calendar year. 
• Our next assumption, or guess, is that the Form U submission period will shift to September 1 to December 31, but that will require that the final rule on the IUR modifications be published very soon.

“Food” for Thought…

As recently as March 4, 2011, representatives from the American Petroleum Institute (API) met with the EPA presenting concerns about several aspects of the proposed IUR modifications rule.  One topic the API presented was that when the last set of revisions of the IUR was finalized in 2003 with the next reporting period was extended by one year shifting from 2004 to 2005 with Form U submission in 2006.  During 2004 and 2005, the EPA held many workshops and issued clarification and guidance documents.

And, for now, we wait for the Final Rule and hope that the data we have all collected for the 2010 reporting period will be adequate.  Emilcott’s recommendations for what to do while we wait are in my January blog:  “TSCA IUR Update – What Are the Changes?”. Essentially, we are advising our clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Here are a couple of items to keep on your radar:

• Be sure your list of manufactured chemicals is complete.  Your list should be based on all chemical processes and imported materials received at the site and not just on the products.
• When calculating individual substance volumes – include imported mixtures with those manufactured at the site aggregating all mixtures containing that substance. 

…And, Emilcott will continue to keep you posted!

What to do if you need help or have questions?

If you need assistance related to the TSCA New Chemicals regulatory requirements or the potential changes due to the Inventory Update Reporting Rule, Emilcott can guide you through the reporting.  We can also help you navigate the maze of reporting a potential Form U violation from prior filing years to the EPA (See http://www.emilcott.com/services/svcenvcompliance.asp). 

As more information becomes available from the EPA regarding the IUR and as testing of the electronic tool begins, Emilcott will keep you up-to-date via EHSWire and our “Regulatory Updates” Newsletter.  

Please give me a call at 1-800-886-3645 or write a comment below if you have any questions or additional information to contribute.

by Paula Kaufmann

What’s the job of a Respiratory Protection Program (RPP) Administrator? 

This individual is officially listed in the site’s written Respiratory Protection Program and is accountable and responsible for the day-to-day operation of the program. Some of those “day-to-day” tasks include

• Maintaining the site Respiratory Protection Program
• Assessing the workplace for potential respiratory hazards
• Defining worker exposure for these hazards
• Selecting appropriate respirators to provide protection from defined hazards
• Ensuring
  • Medical evaluations are conducted of employees required to wear respirators PRIOR to fit testing
  • Respirators are fit tested for all required users
  • Proper use of respirators during routine and emergency operations
  • Respirators are appropriately cleaned, disinfected, stored, inspected, repaired, discarded, and maintained
  • Adequate air quality air is supplied if supplied air respirators are used.
  • Respirator users are trained in respiratory hazards, and the proper use and maintenance of respirators
  • Periodical evaluation of the Respiratory Protection Program implementation
  • Workers who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation, and cleaning, storing and maintenance requirements of the standard
  • All voluntary-use respirator users understand Appendix D of the standard

Yes, these incessant and critical health and safety tasks can be quite overwhelming!  What’s the big deal? For the company or job site or administrator who does not understand why a qualified and empowered RPP Administrator is a big deal, here is a triple-play of Top 5 facts that illustrate the importance of qualified training for Respiratory Protection Program Administrators!

Top 5 OSHA Violation!

Did you know that the Respiratory Protection Standard was in the Top 5 most frequently cited standards by OSHA compliance officers last year?  Why be a part of that statistic?  More about 2010’s Top 10 cited violations can be found in a recent EHSwire blog by Emilcott’s Sarah Damaskos.

Top 5 Reasons YOU need to be “Qualified”

1. Workers at your site are required to wear respirators for protection from respiratory hazards – and you selected these respirators.
2. You train respirator users on how to put on and take off their respirator – along with the limitations on their use, and their maintenance.
3. Implementation of the site respiratory protection program (which you wrote) is just another one of your jobs!
4. Airline (atmosphere-supplying) respirators are used at your site – and you make sure that an adequate air supply, quantity, and flow of breathing air is available.
5. You coordinate the medical evaluation of employees who must use respirators.

Top 5 OSHA Compliance Indicators!

If you get a visit from an OSHA Compliance Safety and Health Officer, they review these essential factors to help determine if the Respiratory Protection Program Administrator is “Qualified”:

1. The written Respiratory Protection Program and interviews with the program administrator reveal an understanding of the familiarity with the respirator standard, site respiratory hazards, and the use of the respirators in the workplace.
2. Respiratory fit testing is conducting annually or at assignment and the program administrator maintains.
3. Hazardous airborne contaminants that employees may inhale have been identified.  Reasonable estimates of employee exposures were used in determining the appropriate respirator for employees to use.
4. Recent changes in the workplace such as new processes have been evaluated for necessary respiratory program changes
5. The program administrator keeps a written assessment of the program operations and implements changes that may be considered as efforts toward improvement.

How to Become a Qualified RPP Administrator

Focused, hands-on training with experienced health and safety instructors can make the difference for a Respiratory Protection Program Administrator – clarifying the waters by understanding the objectives of the law and how it applies to each work site!

As Health and Safety consultants to many types of companies, Emilcott staff are on job sites each day and see health and safety violations such respirators perched on foreheads or tissues jammed in the sides to ensure a bitter fit. Are these problems an employee violation or a company-wide result of not understanding the importance of a competent Administrator who can develop, maintain and enforce a respirator protection program that reduces occupation risk?

In these cases, we conduct urgent and immediate on-site RPP Administrator training that often includes high level managers to ensure that there is a top to bottom understanding of the importance of proper respirator usage. In addition to our private training, the Emilcott Training Institute offers public enrollment Respiratory Protection Program Administrator training courses in two formats:  an intense 3-hour course with a small class size and an in-depth two-day course.  In both classes, students learn the level of information required for their sites and are taught by an experienced H&S instructor that can answer questions. 

So if you are unfamiliar with your required duties as an RPP Administrator or you want a better understanding of how to encourage better respirator usage by your site personnel, look around for an effective RPP Administrator training class. Once complete and in practice, you should dicover aTop 5 list that looks more like this:

1. OSHA respirator inspection passed without any problems, fines or additional action.
2. Site personnel actively wear their respirators – the way that they are supposed to!
3. Site workers reinforce the importance of respirator use to their colleagues (even when you’re not around)!
4. Managers understand the need for respirator use and support related site activities such as testing of hazardous airborne contaminants.
5. Written assessments of program changes are treated as a necessity for business to move forward rather than resented.

You ARE a Qualified Respiratory Protection Program Administrator!

If you have any questions about RPP Administrator duties, training or effectiveness, let me know!  As a consultant with lots of respirator stories to share, it’s always great to hear how proper respirator usage and the influence of a qualified administrator has really made a difference at the work site.

Carrie Bettinger, CHMM, CSP

As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our “General Industry” clients in an effort to lift their game with dealing with hazardous waste.  There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan!  The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.

The Rules

The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage  and disposal of Hazardous Waste,  which “General Industry” businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; …well, just about everyone) needs to know!

OSHA uses the term “general industry” to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA’s general industry standards, directives, and standard interpretations.

Give me an R! Give me a C! Give me an R! Give me an A!  What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t have a side business of burying industrial waste on the family farm.   RCRA is a complex law with lots of parts and many industries are affected by its components.  In addition to being complex, the text of the Act with all of its parts and sections is hard to follow.  My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262).  RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training. 

But the EPA’s RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site.  The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H.   The International Air  Transport Association (IATA) has rules for the air transport of hazardous materials (http://www.iata.org/) including training requirements.

To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s hazardous materials in DOT and IATA eyes.  For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.  

The Required Training

So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have — per both EPA and DOT/IATA.

All employees at sites that generate hazardous waste need to be trained in how to:

• Properly identify what qualifies as regulated “Hazardous Waste” per federal (EPA) or your state requirements.
• Know where to properly dispose of any hazardous waste you may generate (I will give you a hint:   It’s NOT down the sink drain!).
• Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.

Employees who are designated as responsible for the management and control of this hazardous waste need additional training.  And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to 

• Properly label containers
• Implement accumulation area requirements and time-on-site limits
• Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems
• Complete Hazardous Waste shipping manifests
• Ensure proper shipping methods and a qualified transporter are used
• Develop site-specific procedures
• Know and implement emergency procedures and site contingency plans

Refresher Training

A common point of confusion is when refresher training is needed for employees.  The DOT and EPA have two separate requirements:

• The EPA requires annual refresher training for their regulations.
• The DOT requires refresher training every 3 years for their regulations.   

And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations. 

The Bottom Line

We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans – everything that DOT/IATA and RCRA training develops for your company – are vital in the cleanup of the environment and protection of employee and public health and safety. 

For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott.  As part of The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA:

• 6-hour Introduction to RCRA Compliance (40 CFR 260-273)
• 6-hour Introduction to DOT/IATA Compliance (49 CFR 172.704 & DGR 1.5.0)
• 4-hour RCRA Refresher
• 4-hour DOT/IATA Refresher

Also – check out the EPA web page on hazardous waste. There is a plethora of information that you can use to make hazardous waste management a snap!