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  www.specialtytechnicalconsultants.comWinter 2011  
In This Issue
STC News
Did You Know?
EHS Training For Results
Chem Supplier Responsibility
Tier II Battery Reporting
Texas MSGP Renewal
STC Educational Webinar
STC News

MedShare appoints new member.

Sara Broadbent has been appointed to Western Regional Council of MedShare. >>> 

STC Activities.  Kathryn Nobrega has joined the Communications Committee of the Connecticut River Valley Chapter of ASSE. >>> 

Did You Know?

EPA updates its guidance on clean up  broken compact fluorescent lamps (CFLs). CFLs contain a small amount of mercury sealed within the glass tubing that is released as vapor when broken. >>>

EPA expands TRI list of reportable chemicals. This action is part of EPA's ongoing efforts to examine the scope of TRI chemical coverage and provide more complete information on toxic chemical releases. >>>

Cal/EPA to post an SB 14 guidance document. California's Department of Toxic Substances Control has announced it will post the Hazardous Waste Source Reduction guidance to assist with the preparation of reports due September 1, 2011. >>>
 
SEC proposes changes to the reporting rules for conflict minerals. The proposed rules would require any issuer of conflict minerals to disclose if its conflict minerals originated in the Democratic Republic of the Congo or an adjoining country. >>> 

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EHS Training for Business Results

Carol J. Robinson, CIH, CSP, Principal & Vice President, Oakland, CA

Kathryn J. Nobrega, Senior Program Director, Amherst, MA

  

What might these facility EHS program issues share in common?

  • Containers of hazardous chemicals are not labeled properly.
  • A supervisor reprimands an employee for identifying a hazard.
  • A complete set of hazardous waste manifests are not available for review during an audit.
  • Repetitive motion injuries are increasing among office staff.

Most EHS professionals would likely prescribe training as the common solution to solve these and similar problems. While training could be an important part of an effective solution, training as a panacea, isolated event, or uninspired lecture is rarely effective in the long-term. This article shows how to avoid the training trap, and instead use EHS training to achieve not only regulatory compliance, but also business results. >>>


OSHAAgency Clarification of Chemical Supplier Responsibility Compliance Programs

Randy Roig, PhD, Co-Founder STC, Oakland, CA

Kathy McKinney-Tovar, Senior Analyst, Vallejo, CA

 

OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Program (RMP) regulations prevents or minimize the consequences of a catastrophic release of hazardous chemicals from regulated processes.  When an industrial facility is the only owner or operator at the site, the responsibility for complying with the program elements is clearly the industrial facility. However when a chemical supplier (vendor) owns and operates a gas or chemical supply system that is connected to a production process owned by the industrial facility, the compliance responsibilities are not clear. STC wrote a letter requesting interpretation of the PSM and RMP regulations as they apply to a facility where the vendor and industrial facility each owns and operates process equipment at the facility.  Both agencies have responded. >>>

 

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Battery ImageIt's Tier II Reporting Time, Do You Know Where Your Batteries Are?

Barbara Jo Ruble, CPEA, QEP, Principal & STC President, Baltimore, MD

 

As an EHS compliance auditor, one of the most common problems I find when reviewing Emergency Planning and Community Right to Know (EPCRA) Tier II reporting, is that facilities with large quantities of lead-acid batteries fail to report inventories of sulfuric acid and lead from those batteries on their chemical inventory reports-or for facilities in California, on their Hazardous Materials Business Plan (HMBP) reports. Most people tell me that they thought batteries were excluded or exempt from chemical inventory reporting, but they're wrong. Why? Let's look at what makes a chemical reportable under EPCRA. >>>


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Texas Industries Need to Renew Industrial Storm Water Permits

Curt Johnson, CPEA, Senior Program Director, Richmond, TX

 

Storm water discharges from industrial facilities located in Texas are meant to be covered by the state's Multi-Sector General Permit (MSGP) (TXR050000). Covered industries are expected to submit a Notice of Intent (NOI) to comply with the storm water MSGP or a No-Exposure Certification (NEC) depending on their particular circumstances. The MSGP was issued to the state by the US Environmental Protection Agency (EPA), and it is due to expire on August 14, 2011. The Texas Commission on Environmental Quality (TCEQ) is going through the process of renewing the permit and industries in Texas will be required to re-submit their NOIs or NECs once the new MSGP is issued (expected in July). >>>

    
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Opportunities for Learning

STC Educational Webinar Series 2011

NESHAP Area Source Standards for 9 Metal Fabrication and Finishing Source Categories

Russell Boesch, CPEA, CHMM

 

February 23, 2011

2:00 PM EDT/11:00 AM PDT

Free! All are welcome.


EPA's new National Emission Standards for Hazardous Air Pollutants (NESHAP) rule will soon affect a broad swath of industries that fabricate and/or finish metal products. The rule (40 CFR 63 Subpart XXXXXX), which takes effect on July 25, 2011, will impose operating, reporting and record keeping standards on nine metal fabrication and finishing source categories. This rule applies to an "area source" (that is, a stationary source of HAP that is not a "major source") where the primary activity matches one of the following source categories:
  • Electrical and electronic equipment finishing operations
  • Fabricated metal products
  • Fabricated plate work
  • Fabricated structural metal manufacturing
  • Heating equipment, except electric
  • Industrial machinery and equipment finishing operations
  • Iron and steel forging
  • Primary metals manufacturing
  • Valves and pipe fittings
This webinar will discuss the regulatory requirements and strategies for compliance with notification, emission controls, record keeping and reporting obligations, and employee training. Our presenter will be Mr. Russ Boesch, CPEA, CHMM and STC Senior Program Director with 25 years experience in EHS compliance management.

Space is limited; Reserve your Webinar seat now at: Register   

 

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UPCOMING EVENTS

 

Naem EHS MIS Conference 2011 Banner 

Melanie Powers-Schanbacher, STC-Bridgewater, will be attending the 2011 NAEM EHS MIS Conference. The 2011 EHS MIS Conference will take place at the Omni San Antonio Hotel at the Colonnade on March 2-3, 2011. The Conference provides attendees with an opportunity to view the leading software systems that meet these challenges. This Conference allows attendees to view 12 leading EHS MIS solutions in one venue. Sessions feature software solutions that address the following areas:  

  •    Carbon accounting and GHG reporting
  •    EHS compliance and auditing management
  •    Incidents and illness tracking
  •    Sustainability metrics management
  •    Material safety data sheet creation and distribution
  •    Global Materials Shipping
  •    EHS change management
  •    Ergonomic assessments

 An exciting addition to this year's conference is a Special Interest track. These sessions, lead by NAEM's Affiliate Council, will cover management challenges that include system selection, implementation and maintenance. For full details about the conference and to register on line, go to NAEM

 

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We hope you have enjoyed this quarterly newsletter. If you would like more information about any of these articles, I invite you to contact our team members. You can find contact details for our team members on our website - Specialty Technical Consultants.
  
Please fee free to contact me if you have any questions or would like more information about STC's EHS training services.
  
Thank you.
  Carol Robinson Signature
arol J. Robinson, CIH, CSP
Principal and Vice President
Tel: (510)495-6070

Questions about this Newsletter?

Melanie Powers-Schanbacher

Telephone: 908.707.4001

Email: mpowers@stcenv.com