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EPA and DOT/PHMSA Regulatory Update
Greetings!
The year is half over, and most annual EPA reports are behind you. However, as you know, the regulatory agencies don't give you a break from compliance. Take advantage of the slow summer period to send an employee to training required by both the EPA and DOT. Or, schedule on-site training and have all your employees trained in one day.
Please pay special attention to the article below about PHMSA's HazMat Registration Program. |
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PHMSA's HazMat Registration Program 
It has been my experience that many persons are not aware of their requirement to register for this program. The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the US Department of Transportation has since 1992 required facilities that ship or offer for shipment hazardous materials to register if they meet one of six criteria. You may view the criteria and complete instructions, or take this simple survey to make the determination for yourself. If you determine registration is necessary and have missed the 2011-2012 deadline, or have never registered before, have no fear. In my experience, retroactive reporting while costly (and required) does not result in an enforcement action by the PHMSA or DOT.
If you are required to register, then you are also required to train your HazMat Employees.
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USEPA Encourages Homeowners to Remove Hazardous Substances Before Flooding.
While acknowledging a primary concern for human safety, a USEPA Fact Sheet, requests that homeowners prepare their homes for flooding by removing and/or safely storing some household hazardous substances that can cause environmental pollution during a natural disaster if not secured. Ask yourself: Could a natural disaster - such as flooding - at my place of business result in environmental pollution for which I will be held responsible?
Also, review EPA's guidance for preparing your home and business for a natural disaster.
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Georgia Environmental Protection Division Announces Top RCRA Violations
The list below is specific to Georgia, but could well be the same in any state in the U.S. Note the simplicity of most of the violations.
- 40 CFR 262.34(d)(5)(ii) - Posting of information by the telephone by Small Quantity Generators.
- 40 CFR 279.22(c) - Labeling during Used Oil storage by Used Oil Generators.
- 40 CFR 262.34(a)(1)(i) - Weekly inspection of containers by Large Quantity Generators.
- 40 CFR 262.11 - Hazardous waste determination.
- 40 CFR 262.34(a)(1)(i) - Keeping hazardous waste containers closed during storage by Large Quantity Generators.
- 40 CFR 262.34(a)(2) - Labeling of containers at 90-day accumulation areas with the date accumulation begins by Large Quantity Generators.
- 40 CFR 262.34(a)(3) - Labeling of containers at 90-day accumulation areas with the words "Hazardous Waste" by Large Quantity Generators.
- Permit condition violation - "Monitoring well maintenance" by Treatment, Storage and Disposal Facilities.
- 40 CFR 273.13(d)(1) - Containing Universal Waste Lamps in structurally sound packaging and keeping the packaging closed by Small Quantity Handlers of Universal Waste.
With the exception of #8 above, all of the above violations are easy to avoid and are routinely addressed by Daniels Training Services' nationwide events.Click here for to view the list on the Georgia EPD website.
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The Uniform Hazardous Waste Manifest
The Uniform Hazardous Waste Manifest has been required by the US EPA for all hazardous waste shipments since September 5, 2006. Did you know that your State may have retained some of its own requirements? Check out the USEPA website to ensure you are in compliance with both State and Federal regulations. |
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On-Site Training
For a flat fee of $1,500 plus $10/trainee we can come to your facility and provide site-specific training that fulfills the regulatory requirements.
Contact us directly to schedule your on-site training event.
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Are you a HazMat Employer? 
In order to determine if the DOT hazardous material regulations apply to your facility, you must first determine if you or your employees meet the DOT definition of a HazMat Employee. Take this one question survey to find out.
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What Hazardous Waste Training Requirements are You Subject to?
It is important for any commercial or industrial facility to determine its hazardous waste generator status and the applicable training requirements. Take this three question survey to determine your status.
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Testimonials
"I strongly would suggest this training to any employee who deals with EPA & DOT regs. Thanks, I learned a lot." - Johnathan Jankowski, EHS Coordinator at Huntsman "Fabulous training! Easy to understand and follow for the beginner and the seasoned professional. Dan really knows this subject well." - Lance Meyer, E.S. Tech at Delta Faucet Company |
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How to Contact Us
815.821.1550
www.DanielsTraining.com
Info@DanielsTraining.com
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