Multimedia Compliance Audits, Management System Audits, EHS Audits

Brief project summaries for consulting work completed by Caltha LLP. Project summaries archived here include compliance audits, multimedia audits, regulatory program audits, including air rule audits, hazardous waste - RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits, audit training and others.


Click here to see a summary of projects completed by Caltha LLP related to compliance audits, multimedia audits, regulatory program audits, air rule audits, hazardous waste, RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits.

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

Hazardous Waste Generator Improvements Rule

Hazardous Waste Generator Improvements Rule proposes an update to the hazardous waste generator regulations to make the rules easier to understand, facilitate better compliance, provide greater flexibility in how hazardous waste is managed, and close important gaps in the regulations.

Two key provisions where EPA is proposing flexibility are:
1.Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed and
2.Allowing a conditionally exempt small quantity generator (CESQG) to send its hazardous waste to a large quantity generator under control of the same person.

In addition to proposing key flexibilities, the rule will enhance the safety of facilities, employees, and the general public by improving hazardous waste risk communication and ensuring that emergency management requirements meet today’s needs.

EPA is also proposing a number clarifications without increasing burden including a reorganization of the hazardous waste generator regulations so that all of the generator regulations are in one place

Recent Changes to Comment Period


UPDATE:
This rule was finalized on October 28, 2016. Click here is review a summary of the final Hazardous Waste Generator Improvement rule and information on which States and other areas will be affect immediately.


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

Tier 2 Reporting Under EPCRA 311 and 312 and Local Hazardous Material Reporting Regulations

With the end of the year approaching, many facilities will soon be reviewing the hazardous chemicals they store on-site to determine if they exceed the thresholds for Tier 2 reporting under EPCRA 312 (40 CFR 370) and equivalent State regulations. Local emergency response agencies can have additional hazardous chemical reporting requirements, in addition to Tier 2 reports.

The EPA rules that determine reporting requirements set out two options for determining thresholds.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.

Click here to review example Caltha projects for EPCRA and other compliance reporting support.