Friday, September 16, 2016

MPCA Rules On Puncturing and Venting Spent Aerosol Cans Changes January 1, 2017

In Minnesota, generators can puncture waste aerosols or gas cylinders that have been shown to be empty or that have been evaluated as non-hazardous, as long as any unavoidable liquid residuals are collected and properly managed.


However, hazardous waste aerosols and gas cylinders may no longer be punctured or vented in Minnesota after January 1, 2017, unless all hazardous waste propellant gases, product gases, and liquids are captured and properly disposed. MPCA does not allow charcoal and activated carbon filters to be used to capture hazardous waste propellants or gases for disposal.


The deliberate release of hazardous waste propellant or compressed gas to the atmosphere has been prohibited by the Minnesota Hazardous Waste Rules for many years, but MPCA chose not to enforce this prohibition. This allowed generators and collection sites to puncture hazardous waste aerosols and dispose of ignitable hazardous waste to the atmosphere. This practice is not allowed after 1/1/2017.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

New Rules Allow Handling Aerosol Cans As Universal Waste In Minnesota

A handful of States allow spent aerosol cans to be handled under State Universal Waste rules (email Caltha LLP if you would like to know if your State is included), although this waste stream is not a Federal universal waste under 40 CFR 273. The Minnesota Pollution Control Agency has finalized rules that will allow generators to manage aerosol cans as universal wastes.



Because documenting that an aerosol container or gas cylinder meets “RCRA Empty” standard can be impractical, MPCA allows generators to assume that an aerosol container is empty when both the following conditions are met:
· No liquid is felt or heard when the container is shaken by hand; and
· No gas or liquid is released when the spray/discharge valve is activated and the container rotated through all directions, as long as the valve is not observably or known to be clogged.



Hazardous waste aerosols and gas cylinders that are not empty can be managed under rules equivalent to universal wastes in Minnesota. Generators must accumulate hazardous waste aerosols and gas cylinders in closed containers labeled with one of these phrases:
· Universal Waste Aerosols/Gas Cylinders (whichever is appropriate)
· Waste Aerosols/Gas Cylinders
· Used Aerosols/Gas Cylinders



Accumulated hazardous waste aerosols/gas cylinders can be stored on-site for no more than one year and must be dated to verify how long they have been stored. Generators can ship hazardous waste aerosols/gas cylinders without a hazardous waste manifest to any site that has agreed to accept and properly manage them.





Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Saturday, August 27, 2016

DOT Certification Training - Initial and Triennial Training For Minnesota HazMat Employees

Caltha LLP offers training services to HazMat Employers who need to have initial or reoccurring triennial training for their designated HaMat employees. Training is tailored for each facility and is based on specific DOT hazardous materials actually shipped or handled. Training is provided at your location or can be provide "live" through a webinar format. Caltha provides training exams and issues training certifications.

In addition to training services, Caltha offers a wide range of compliance support services to operations that periodically ship and/or handle DOT regulated HazMat, including RCRA hazardous waste:
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Safety Training In Minnesota - OSHA Compliance Training

Caltha LLP provides a range of OSHA required training programs for OSHA regulated operations located in Minnesota. This includes:
  • OSHA safety awareness training
  • Hazard communication training / HazCom training
  • GHS training
  • Incidental spill response training
  • PPE training
  • Lock out tag out LOTO training
Training is tailored for each facility and can be provided in-person or through "live" webinar sessions. To request more information, including cost information, contact Caltha LLP at info@calthacompany.com



Caltha LLP also provides:
  • Safety program auditing
  • OSHA compliance audits
  • PPE assessments
  • Safety program development
  • Written plans
  • Employee exposure assessment


 Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Thursday, August 25, 2016

Changes Proposed To Regulation of Agrichemical Facilities In Missouri

The Missouri Department of Natural Resources is proposing an amendment to storage containment requirements for pesticides and fertilizers under 10 CSR 20-8.500 – Agrichemical. The purpose of this rule is to remove the requirement that agrichemical facilities without earthen basins obtain construction permits. Agrichemical facilities are sites where bulk agrichemicals are stored in non-mobile containers or dedicated containers and are being mixed, applied, repackaged or transferred between containers. Agrichemicals include any pesticides or fertilizers but do not include anhydrous ammonia fertilizer. Although a construction permit will no longer be required for Agrichemical facilities, they must continue to be constructed according to the design criteria detailed in rule.



Any new agrichemical facility after the effective date of this rule will need to be in compliance with all of these rules before the commencement of any operational activities or any storage or use of agrichemicals. All existing agrichemical facilities will need to be in compliance with the rule as follows:


  • secondary and operational area containment for pesticides— five (5) years from the date the rule is adopted; and
  • secondary and operational area containment for fertilizers—five (5) years from the date the rule is adopted.



Storage of bulk liquid fertilizer in a mobile container for more than thirty days is prohibited unless the mobile storage container is located within a secondary containment or operational containment area. All new operations will need to be designed for no discharge.



Any existing agrichemical facility that has a discharge of agrichemicals or process generated wastewater to the environment will be required to take immediate steps to implement the secondary and operational containment requirements contained in this rule in addition to any other remedy required. All agrichemical facilities will need to apply for an operating permit.




Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Wednesday, August 24, 2016

New York City Clean Act Controls Industial Laundries Within the City

The Clean Act was passed by the New York City Council in June 2016. Pending the Mayor’s signature industrial launders doing business in New York City will have 180 days in which to submit the license application.



The Clean Act adds licensing requirements for linen and uniform supply launderers serving New York City. Each licensee will be required to attach a label or tag to all handcarts and pushcarts that displays the licensee’s name, address and license number. In addition, all bills, tickets, cards, advertising or stationery issued or distributed by any licensee shall contain such licensee’s name, address and license number. In addition, each vehicle used for retail or industrial laundry delivery shall display the licensee’s name, business address and business telephone number and the license number assigned.

The Clean Act also includes minimum standards of cleanliness and hygiene to be observed by each permitee.



Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

NY DEC Emergency Rule Making Restricting Use Of Perfluorooctane Related Chemcials

The New York State Department of Environmental Conservation (DEC) filed a Notice of Emergency Adoption and Proposed Rule Making to classify perfluorooctanoic acid (PFOA-acid), ammonium perfluorooctanoate (PFOA-salt), perfluorooctane sulfonic acid (PFOS-acid), and perfluorooctane sulfonate (PFOS-salt) as hazardous substances at the request of the New York State Department of Health (NYSDOH).


This rule making also provides time for facilities storing fire-fighting foam containing one or more of these newly listed hazardous substances to properly dispose of it and provides time for firefighting operations to find replacement foams. This proposal also corrects the tables of hazardous substances by providing units for reportable quantities.



The temporary emergency rule was effective on April 25, 2016, while the state finalizes the proposed amendments to 6 NYCRR Part 597, Hazardous Substances Identification, Release Prohibition, and Release Reporting. DEC has concluded that these substances meet the definition of a hazardous substance based upon the conclusion of NYSDOH that the combined weight of evidence from human and experimental animal studies indicates that prolonged exposure to significantly elevated levels of these compounds can affect health and, consequently, pose a threat to public health in New York State when improperly treated, stored, transported, disposed of or otherwise managed. NYSDOH scientists have concluded that it is essential to list these chemicals as hazardous substances.



Once substances are determined to be hazardous substances, DEC regulates their handling and storage and has authority to remediate sites contaminated with them. The Chemical Bulk Storage regulations (6 NYCRR 596-599) provide standards for the proper handling and storage of bulk quantities of hazardous substances to prevent spills and releases to the environment, prohibit the release of hazardous substances to the environment, and require the reporting of certain releases of hazardous substances to DEC. Certain facilities that store hazardous substances must apply to DEC for a registration certificate to operate.



A new provision, paragraph 597.4(a)(3), will allow entities with fire-fighting foam the time necessary to determine if stored foam contains one or more of these hazardous substances. If the stored foam contains one of these substances, the facility would not be allowed to use the foam for fire-fighting after April 25, 2017. It may be used for fire-fighting until then but not for any other purpose such as training. Foam that is prohibited for use after April 25, 2017 should be safely disposed in accordance with federal, state, and local requirements. Replacement foam may not contain a hazardous substance at a concentration that would result in the release of more than the reportable quantity (one pound) when used as a fire-fighting foam.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website