REACH, ROHS, Prop 65 and Other Chemical Compliance Certifications

Caltha LLP Project Summary

Project: Certification of REACH, ROHS, Prop 65, Conflict Minerals, Biocidal Products Compliance
Client: Component Manufacturer 
Location(s): Minnesota

Key Elements: EU Chemical Regulations, California Proposition 65 Labeling, Conflict Minerals Compliance Certifiaction

Overview: Caltha LLP was retained by this component manufacturer to compile compliance documentation and to prepare Certification of Compliance. Certification of compliance was required by customers who purchased manufactured components and incorporated them into their final products which were exported to the European Union and other areas.

Caltha prepared a certification form and background information to be completed by raw material suppliers that allowed each supplier to provide an informed certification statement regarding presence/absence of regulated chemical substances, and if present, documentation that concentrations are below regulatory thresholds.

Amendment Proposed To California Hazardous Waste Generator and TSDF Training

The California Department of Toxic Substances Control (DTSC) has proposed revisions to the state’s unique Title 22 hazardous waste facility requirements. In addition to permitted treatment, storage & disposal facilities (TSDF) portions also apply to large quantity generators (LQG) of hazardous waste in the State.

The proposed hazardous waste revisions include a new reporting requirement; by March 1 each year, hazardous waste generators will be required to submit a report to DTSC that certifies that every employee has been trained on all requirements applicable to his or her job. The proposed revisions will also require employers to keep employee-signed or -certified hazardous waste training records on site and makes numerous changes to the training content required.

Click here to review examples of Caltha's EHS Training projects, including California hazardous waste training.

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.


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Certified Environmental Health and Safety Audit Services

Caltha LLP provides IAA-BEAC certified auditors to perform internal EH&S audits to support ISO 14001 registered organizations or to support routine internal audit programs implemented as part of an overall governance system. Caltha can provide:

• Single auditors to support audit teams as a media or regulatory expert,
• Audit teams to address multiple program areas, or
• Due diligence auditors / audit teams.

Caltha auditors can act as adjunct auditors to augment your existing internal audit team, or can act as an independent third party auditor.


Caltha auditors have conducted assessments in all 50 US States, Canada, Mexico, South America, Europe and Asia.


Click here for more information on Caltha Compliance Audit, Management System Audit and Due Diligence Assessment services

Photovoltaic - Solar Modules Proposed As California Universal Waste

California Department of Toxic Substance Control has proposed regulations to add photovoltaic - solar modules as a category under the Universal Waste regulations. Solar modules are a form of photovoltaic technology where a semiconductor material, such as silicon, cadmium telluride or copper indium selenium, is encapsulated between two sheets of tempered glass. Solar modules are relatively simple, being comprised predominantly of a silicon or semiconductor substrate, which for thin–film modules is a thin layer of two or more metal– based semiconductors applied to the surface of glass. Solar modules are likely to exhibit the characteristic of toxicity due to heavy metals (such as cadmium, copper, lead, and selenium) and thus would be classified as hazardous waste, if disposed.

Currently, the volume of waste solar modules in California is very small with the exact number unknown. However, with the increase in deployment of solar modules throughout the state to meet its increasing energy needs, as well as meet the renewable energy goals established by the Governor, that volume of waste solar modules is anticipated to increase at a steady rate over the next 20 years.

The broad objectives of the DTSC regulations are to:

• Establish a conditional exemption in section 66261.6 (recyclable materials) for non–RCRA hazardous waste solar modules that are collected, transported and recycled by being reclaimed as part of a reclamation program administered by a solar module vendor (as defined in the proposed regulations).
• Designate hazardous waste solar modules, that are either RCRA hazardous waste or non–RCRA hazardous waste, as universal waste provided that the solar modules are recycled, not disposed, and are managed in accordance with the existing requirements of chapter 23 (Standards for Universal Waste Management).
• Maintain the existing hazardous waste requirement for recycling activities, including reclamation activities and other forms of hazardous waste treatment activities, which require a hazardous waste facility permit or other grant of authorization from DTSC.

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 

 

Formaldehyde Standards Under Composite Wood Products Act

The Formaldehyde Standards for Composite Wood Products Act was enacted in July 2010. This law amended the Toxic Substances Control Act (TSCA) to establish specific formaldehyde emission limits for hardwood plywood, particleboard, and medium-density fiberboard. By law, the limits are identical to the California emission limits for these products. The law further requires EPA to promulgate implementing regulations by January 1, 2013.

US EPA has issued an Advanced Notification of Proposed Rulemaking to implement these formaldehyde emission limits. This rulemaking will address the mandate to promulgate regulations to implement the statutory formaldehyde emission standards for hardwood plywood, medium-density fiberboard, and particleboard sold, supplied, offered for sale, or manufactured (including imported) in the United States. As directed by the statute, EPA will also consider provisions relating to, among other things, laminated products, products made with no-added formaldehyde resins, testing requirements, product labeling, chain of custody documentation and other recordkeeping requirements, and product inventory sell-through provisions.

A separate Regulatory Agenda entry (RIN 2070-AJ44) covers the mandate for EPA to promulgate regulations to address requirements for accrediting bodies and third-party certifiers. EPA anticipates publishing the Notice of Proposed Rule Making (NPRM) in the Federal Register in April 2012.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

California DTSC & EPA Sign Cooperative Agreement Under Green Chemistry Initiative

The California Department of Toxic Substances Control (DTSC) and the U.S. Environmental Protection Agency have signed a formal agreement which outlines principles by which DTSC and EPA will cooperate to reduce toxic chemicals in consumer products, create new business opportunities in the emerging safer consumer products economy, and reduce the level of effort required for consumers and businesses to identify the components of the products.

This agreement will allow DTSC and U.S. EPA to minimize duplication of effort and promote consistency in their assessment methodologies. The agreement also creates a partnership between the two agencies and sets up a framework to collaborate on Green Chemistry issues related to California’s “Green Chemistry” program. The U.S. EPA’s Green Chemistry Program supports fundamental research in the area of environmentally benign chemistry as well as a variety of educational activities, international activities, conferences and meetings, and tool development, all through voluntary partnerships with academia, industry, other government agencies and non-government organizations.

DTSC’s informal draft Safer Consumer Products Regulations, scheduled to be finalized in 2012, will require manufacturers of selected products sold in California to identify safer alternatives to a potential range of 3,000 chemicals known to be harmful to public health and the environment. DTSC expects to release its draft Safer Consumer Products Regulations in early 2012 for public comment. The Regulations are a key element of California’s Green Chemistry Initiative signed into law in 2008.

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

EPA Approves Some California PM2.5 Plans

The U.S. Environmental Protection Agency is proposing to approve California's air quality plans for fine particles (PM2.5) in the South Coast and San Joaquin Valley. These plans will reduce particulate emissions to the level required by the health based 1997 PM2.5 standard by 2015.

Over the past 10 years, PM2.5 has improved by 14% in the San Joaquin Valley and by 43% in the South Coast. Diesel mobile sources such as trucks, construction equipment and marine vessels are the largest source of PM2.5 in California. Trucks and buses account for about 40 percent of diesel emissions from all mobile sources.

In November 2010, EPA proposed to disapprove the South Coast and San Joaquin Valley PM2.5 air quality plans because the agency believed they relied heavily on emissions reductions from several State diesel and marine vessel rules that had not been finalized or submitted to the EPA for review.

Since then, the California Air Resources Board (CARB) is finalizing these rules. They include the In-Use Diesel Truck and Bus rules, the Drayage Truck Rules and the Ocean Going Vessels Clean Fuels rule. In addition, CARB has revised the plans that were originally submitted to EPA to account for the original overestimation of activity and emissions from trucks and construction equipment as well as the economic recession. As a result, future emissions are forecasted to be lower and fewer emissions reductions are needed to meet the standard. For the San Joaquin Valley, the effect is that about 5% fewer reductions are needed due to the recession and about 18% fewer reductions are needed because of better emissions estimates. For the South Coast, about 5% fewer reductions are needed due to the recession and about 5% fewer reductions are needed due to better emissions estimates.

However, EPA is proposing to disapprove the plans’ contingency measures because the agency believes they do not provide sufficient emissions reductions. EPA is continuing to work with the State to demonstrate and deploy near zero emitting technologies.

The proposed actions will be published in the Federal Register and will include a 30-day public comment period from the date of publication.

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

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website