Wednesday, October 18, 2017

SD Waste Rule Update | Hazardous Waste Generator Improvements Rule

The South Dakota Department of Environment & Natural Resources (DENR) has finalized its hazardous waste regulations in order to align the state regulations with updates to EPA’s federal hazardous waste management program. The final regulations do not include the new federal Hazardous Waste Generator Improvements Rule which went into effect on the federal level on May 2017.

Click here for more information on the EPA Hazardous Waste Generator Improvements Rule

Click here for an update on State implementation of solvent wipe rule

South Dakota’s revised hazardous waste regulations went into effect on September 12, 2017. The revised regulations incorporate federal regulations by reference, with some minor modifications. The federal regulations incorporated by reference are those amended as of July 1, 2016.

Click here for recent Caltha South Dakota project examples and regulatory updates for South Dakota.

South Dakota Finalizes Solvent Contaminated Wipe Exclusion

The South Dakota Department of Environment & Natural Resources (DENR) has finalized its hazardous waste regulations in order to align the state regulations with updates to EPA’s federal hazardous waste management program. South Dakota’s revised hazardous waste regulations went into effect on September 12, 2017. The revised regulations incorporate federal regulations by reference, with some minor modifications. The federal regulations incorporated by reference are those amended as of July 1, 2016.

The updated rule incorporates certain exclusions from the definitions of solid and/or hazardous waste are now available to hazardous waste generators. It also includes the conditional exclusions from the definitions of solid and hazardous waste for management of solvent-contaminated wipes and the hazardous waste exclusion for carbon dioxide streams in geologic sequestration activities.

The final regulations do not include the new federal Hazardous Waste Generator Improvements Rule which went into effect on the federal level on May 30 of this year.

Click here for recent Caltha South Dakota project examples and regulatory updates for South Dakota.

Thursday, October 12, 2017

Rule on Management of Hazardous Waste Pharmaceuticals

The EPA Management Standards for Hazardous Waste Pharmaceuticals Rule was published in the Federal Register on September 25, 2015. EPA received a number of requests to extend the comment period and in response provided a 30-day extension. A notice announcing this extension was published in the Federal Register on November 5, 2015.

The rule proposes a tailored, sector-specific set of regulations for the management of hazardous waste pharmaceuticals by healthcare facilities (including pharmacies) and reverse distributors. It is intended to provide standards to ensure the management of hazardous waste pharmaceuticals is safe and workable within the healthcare setting. In addition, the proposed pharmaceutical rule is intended to reduce the amount of pharmaceuticals entering surface water.

Wednesday, October 11, 2017

Beryllium Worker Exposure Rule Deadlines

OSHA has issued a final rule limiting worker exposure to beryllium and beryllium compounds. The rule contains standards for general industry, construction, and shipyards which take effect on May 20, 2017. Employers must comply with most elements of the rule starting March 12, 2018.


The key provisions of the rule are:
  • Reduces the permissible exposure limit (PEL) for beryllium to 0.2 micrograms per cubic meter of air, averaged over 8-hours.
  • Establishes a new short term exposure limit for beryllium of 2.0 micrograms per cubic meter of air, over a 15-minute sampling period.
  • Requires employers to: use engineering and work practice controls (such as ventilation or enclosure) to limit worker exposure to beryllium; provide respirators when controls cannot adequately limit exposure; limit worker access to high-exposure areas; develop a written exposure control plan; and train workers on beryllium hazards.
  • Requires employers to make available medical exams to monitor exposed workers and provides medical removal protection benefits to workers identified with a beryllium-related disease.

Click here for more details on the safety, health and emergency preparedness services Caltha provides.


Click here to review a sampling of our past safety related projects.

Safety And Health Consultant Services In Minnesota

The development of cost effective safety programs to manage risks and to comply with OSHA regulations is a core service provided by Caltha LLP. Caltha also provides expert professional & technical support in developing safety management systems and in OHSAS 18001 registration. Caltha also supports our clients’ liability management programs by providing both systems and compliance auditing services.

Developing safety management programs that are easy to implement, document & track is an important service Caltha provides to our clients. This includes integrating compliance management with other risk management, quality improvement and cost control initiatives that our clients may already have. Caltha will train your staff to successfully implement the safety management programs in the future.

Caltha can also provide "as needed" technical support in preparing and maintaining OSHA compliance records, and to conduct incident investigations to support a root cause analysis. Caltha staff have led multi-disciplinary teams to develop corrective action plans arising from variety of incidence, including injuries, accidents, spills and fires.

Click here for more details on the safety, health and emergency preparedness services Caltha provides.

Click here to review a sampling of our past safety related projects.

Thursday, October 5, 2017

Silica Rule Is Enforced Starting September 2017; General Industry Rule in 2018

US OSHA began enforcing the respirable crystalline silica rule for the construction industry on September 23, 2017. The rule had been set to go into effect in June; however, the Department of Labor and OSHA delayed enforcement of the rule by 90 days. The delay was intended to provide DOL and OSHA additional time to issue guidance to industry regarding compliance. The construction silica rule is a companion to OSHA’s general industry silica rule that is scheduled to be enforceable beginning June 23, 2018.

The rule lowers the permissible exposure limit (PEL) for respirable silica dust in the construction industry, to 50 microgram per cubic meter exposure limit, calculated as an eight-hour time-weighted average (TWA). Employers subject to the construction rule may comply by implementing required engineering and work practice controls and respiratory protection , or by completing exposure assessments  of employees above the action level of 25 micrograms per cubic meter.

Under the rule, employers must:
  • Make medical screening available to employees who are required to use a respirator more than 30 or more days per year;
  • Develop a written exposure control plan;
  • Maintain certain records; and
  • Comply with certain limitations on housekeeping practices, such as using wet sweeping, HEPA-filtered vacuuming, or other methods designed to reduce employee exposure when feasible.


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

Monday, October 2, 2017

Corporate HSE Department Needed Site Remediation Oversight Support

Caltha LLP Project Summary

Project: Corporate HSE Staffing-Site Remediation Oversight
Client: Multi-national Chemical Company
Location(s): California, Illinois, Indiana, Minnesota, North Carolina, Ontario, Canada, Michigan, Kentucky, Arizona


Key Elements: Environmental Health & Safety Staffing, Site remediation


Overview: This chemical company contracted with Caltha to provide temporary staffing in its corporate HSE Department for the position that oversaw numerous site remediation projects being conducted across the US and Canada. Due to staff turnover the position needed to be filled quickly to assure that process on projects continued, on-site contractors had questions and issues addressed, and that required agency submittals were reviewed, approved and submitted on time. Caltha provided a highly experienced HSE professional to fill the position until the corporation could hire a permanent replacement. Caltha staff were then able to provide transitional support.


For more information on Caltha LLP services, go to the Caltha Contact Page