Revised 2018 Flammable and Combustible Liquids Code Released

The National Fire Protection Association (NFPA) has released a revised 2018 edition of NFPA 30 Flammable and Combustible Liquids Code. This version replaces the prior edition published in 2015. NFPA 30 is referenced in numerous OSHA, emergency prevention and pollution prevention regulatory programs and becomes enforceable under OSHA and many state and local regulations, NFPA 30 provides safeguards to reduce the hazards associated with the storage, handling, and use of flammable and combustible liquids.

The NFPA 30 code applies to the storage, handling, and use of flammable and combustible liquids, including waste liquids. It is intended to "reduce the hazard to a degree consistent with reasonable public safety, without undue interference with public convenience and necessity, of operations that require the use of flammable and combustible liquids." Compliance with the code does not eliminate all hazards in the use of flammable and combustible liquids.

Improper Storage And Labeling of Flammable 

Waste Observed During Audit

The NFPA 30 code does not apply to:

• Any liquid that has a melting point of 100°F (37.8°C) or greater
•  Any cryogenic fluid or liquefied gas
• Any liquid that does not have a flash point, but which is capable of burning under certain conditions
• Mixtures of flammable or combustible liquids and halogenated hydrocarbons either do not exhibit a flash point using the standard closed-cup test methods or will exhibit elevated flash points.
• Any aerosol product, which are addressed in NFPA 30B, Code for the Manufacture and Storage of Aerosol Products.
• Any mist, spray, or foam
• Transportation of flammable and combustible liquids as governed by the U.S. Department of Transportation, which are addressed in NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, and in the U.S. Department of Transportation’s Hazardous Materials Regulations, Title 49, Code of Federal Regulations, Parts 100–199.
• Storage, handling, and use of fuel oil tanks and containers connected with oil-burning equipment, which are addressed in NFPA 31, Standard for the Installation of Oil- Burning Equipment.
• Use and installation of alcohol-based hand rub (ABHR) Dispensers, which are addressed in NFPA1, Fire Code, and NFPA101, Life Safety Code.

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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.


States, such as Washington, has proposed their own interim policies regarding shipping of waste drugs which would otherwise be regulated as hazardous waste or dangerous waste.

TSCA Compliance Expert Technical Support For NJ Chemical Company

Caltha LLP Project Summary

Project: TSCA Certification Support
Client: Chemical Distributor 
Location(s): New Jersey


Key Elements: TCSA Import Certification, TSCA reporting, Hazardous Material Storage, Hazardous Material Transportation


Overview: Caltha LLP has provided on-going ad hoc technical support to this chemical importer and distribution company. Services are provided on an "as needed" basis and include review of product SDS, chemical storage requirements, and TSCA import certifications (positive certification, negative certification).


Click here for more information on Caltha LLP TSCA Compliance services.

Chicago Multimedia Compliance Audit For Manufacturing Plant

Caltha LLP Project Summary

Project: HSE Compliance Audit
Client: High Tech Manufacturer
Location(s): Chicago, Illinois

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, PPE assessment, hazard communication


Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this manufacturing facility located in Cook County. The scope of the audit included:

• EPCRA
• Hazardous and Solid Waste Management
• Current IEPA Air Permit
• Cook County Air Emission Ordinance
• Current wastewater discharge permit
• TSCA
• Tanks
• Hazard communication
• DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

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

Hazardous Waste and DOT Hazardous Material Training For Minnesota Facility

Caltha LLP Project Summary

Project: Employee training on Hazardous Waste management, Universal Waste Management, and DOT HazMat training for shipping of regulated hazardous materials
Client: Medical product manufacturer
Location(s): Minnesota

Key Elements: Waste management, Employee training, DOT hazardous material shipping

Overview: Caltha LLP assisted this medical product manufacturer by conducting employee training sessions at the client's facility covering:

• Hazardous waste management, for conditionally exempt small quality generator (CESQG)
• Universal waste management
• DOT HazMat employee training for individuals responsible for preparing and shipping hazardous materials, including wastes

For more information on Caltha LLP training services provided to small and medium sized facilities, go to Employer's Environmental Health and Safety Training Center.

Hazardous Material Storage Review For Minnesota Manufacturer

Caltha LLP Project Summary

Project: Hazardous Material Storage Review
Client: Specialty Plastics Manufacturer
Location(s): Minnesota

Key Elements: Haz Mat regulatory review, Site storage inspection

Overview: Caltha LLP was retained by the specialty plastics manufacturer to conduct a review of Federal, State, County and City requirements related to planned on-site storage of several new hazardous materials. Once complete, Caltha staff conducted a pre-start-up on-site review on storage and handling practices and waste management.


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

Solvent Wipe Exemption Roll Out By States | States That Have Not Exempted SCW By Rule

In July 2013, US EPA published a final rule which exempted launderable (reusable) and some disposable wipes containing solvent ("Solvent-Contaminated Wipes" or SCW) from regulation as solid wastes and as hazardous waste. Solvent wipes are very common waste streams generated by a broad range of industrial, commercial, service and institutional sector facilities. This rule streamlined management of this waste stream and allowed these materials to be stored, transported* and cleaned/disposed of outside of the hazardous waste rules that would otherwise apply. This provides a benefit to both facilities that generate these wipes and companies that handle them.

 

* Although the rule exempts transporters from hazardous waste rules, Federal and State DOT HazMat rules still apply.

 

Click here for more information on the Federal Solvent Contaminated Wipe Rule.

 

Although the Federal rule became effective on January 31, 2014, in majority of States the Federal exemption does not apply until State Rules were revised to include this exemption. In many cases, States had operated for many years under policies or guidance which functionally excluded these wipes from regulation as hazardous waste until a Federal Rule was finalized. With the publication of the Federal Rule in 2013, States needed to update State rules to reflect this exemption, if they wanted to allow generators to take advantage of it. Because this rule change was less stringent than existing hazardous waste rules, States were not required to accept the Federal exemption and could require generators to handle these wipes as hazardous waste.

 

State Rule Update - March 2017

 

As of March 2017, 61% of State agencies have updated State rules to exempt solvent wipes, with most using Federal language or Federal language with very minor edits. One State (Rhode Island) implemented a rule that exempted reusable wipes only.

 

 

 

States Where Policy or Guidance Applies

As of March 2017, almost 1/3 of States have not revised State rules to reflect the SCW exemption and are still operating under policies or guidance documents written 10 to 15 years ago.

 

• Colorado
• Connecticut
• Delaware
• Kentucky
• Maryland
• Massachusetts
• New Mexico
• New York
• Oregon
• South Dakota
• Vermont
• Washington
• Wisconsin

 

In most cases, this policy or guidance is similar to the Federal Rule, but typically less specific and less stringent. Currently, many of these States are still planning to update State rules in the near future and are allowing generators to follow the Federal rule.

 

States Without Policy or Guidance

As of March 2017, three States have not revised State rules and had not established a policy in the past to exempt these wipes from hazardous waste rules:

 

• Nevada
• Maine
• Hawaii

 Maine and Hawaii both anticipate having a rule revision in 2017.

States With State-Specific Rules

Two States, California and Minnesota, have rules (California) or policies (Minnesota) that are significantly different than the Federal Rule and do not plan to revise them. In California, the Reusable Soiled Textile Rule excludes all hazardous waste (not just solvent) on a wider range of textiles (not just wipes). In Minnesota, guidance exempts some wipes ("sorbents") but wipes containing certain listed solvents ("toxic solvents") remain hazardous waste and also must be included in their monthly calculation of the generator size.

 

 

 

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

 

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. For further information or to request a quote, go to Caltha's "Employer's Environmental Health and Safety Training Center".



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:

• HazMat inventory
• TSCA compliance support for international shipments subject to TSCA regulations
• DOT HazMat Compliance 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 Material Shipper Fees Reduced By PHMSA

The Pipeline and Hazardous Materials Safety Administration (PHMSA), US DOT has announced a temporary reduction in registration fees it charges hazardous material shippers. Due to an unexpended balance that has accumulated in the Hazardous Materials Emergency Preparedness (HMEP) Fund, PHMSA is lowering the registration fees for registration year 2013-2014 for all persons that transport or offer for transportation in commerce certain categories and quantities of hazardous materials.

For registration year 2013-2014 the fee for a small business or not-for-profit organization is revised to be $125 (plus a $25 processing fee), and for all other businesses the fee is $1300 (plus a $25 processing fee). After the 2013-2014 registration year, the registration fees will return to 2012-2013 registration year levels. PHMSA is issuing this final rule without a prior notice of proposed rulemaking and the final rule is effective 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 
 

Labeling Requirements For Exported Pesticides Revised

EPA has published a final rule revising the regulations on the labeling of pesticide products and devices intended solely for export. The final rule restructures the current regulations to clarify which provisions apply under various circumstances. EPA is also increasing specificity in the regulations by requiring that people who transfer unregistered pesticide products between registered establishments operated by the same producer within the United States must also comply with the requirements of the rule if those products are intended solely for export at the time of such transfer. EPA believes that this requirement is necessary to ensure appropriate handling of such products as they move in commerce before they actually leave the United States.

This final rule is effective March 19, 2013. The compliance date for the requirement to label unregistered pesticide products intended solely for export that are being shipped between registered establishments operated by the same producer is January 21, 2014.


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 

 

PHMSA Asks For Comments On Air Transport Of Lithium Cells And Batteries

PHMSA is soliciting additional comments on the impact of changes to the requirements for the air transport of lithium cells and batteries that have been adopted into the 2013-2014 International Civil Aviation Organization Technical Instructions on the Transport of Dangerous Goods by Air (ICAO Technical Instructions), and subsequently incorporated by reference in a HMR final rule.

PHMSA is considering the long-term impacts of permitting shippers and carriers to choose between compliance with the existing HMR, or compliance with the ICAO Technical Instructions 2013-2014 edition, when transporting batteries domestically by air. ICAO Technical Instructions will allow each shipper and carrier to choose the method of compliance that is most appropriate for its operation. Each shipper and carrier will have the responsibility to ensure that the proper method of compliance is chosen for each shipment, since the chosen method may not comply with the ICAO Technical Instructions.

PHMSA is seeking comment on whether to require mandatory compliance with the 2013-2014 ICAO Technical Instructions for all shipments of lithium batteries by air, both foreign and domestic. Based on the comments received, PHMSA may issue a final rule to revise the HMR to reflect the lithium battery provisions specified in the 2013-2014 Edition of the ICAO Technical Instructions.


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 

 

Amendment For Diesel Sulfur Rule For Transmix and Pipelines

EPA has issued a final rule to amend provisions in the diesel sulfur fuel programs to provide necessary flexibility for transmix processors and pipeline operators who produce locomotive and marine diesel fuel. The diesel transmix amendments will reinstate an allowance for transmix processors and pipeline operators to produce 500 ppm sulfur diesel fuel for use in older technology locomotive and marine diesel outside of the Northeast Mid-Atlantic (NEMA) Area and Alaska after 2014.

These provisions were originally put in place as a necessary flexibility to address feasibility and cost issues associated with handling of the transmix volume generated in the pipeline distribution system. These provisions allowed the fuel distribution system to continue to function while transitioning to ultra-low sulfur diesel fuel (ULSD). The technology to economically reduce the sulfur content of transmix distillate product to 15 ppm at transmix processor and pipeline facilities did not exist, and any alternative measures of disposing of transmix were likewise deemed infeasible or cost prohibitive as the market was then configured. Thus, in order to implement the ULSD regulations, an outlet for the consumption of transmix distillate product was necessary. With no outlet, transmix would build up in storage tanks and pipelines would need to cease operations. When the ULSD standards were expanded to nonroad, locomotive, and marine (NRLM) diesel fuel, this would have removed the sole outlet in most areas of the country.

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

Performance Metrics For Integrity Management Programs

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin to operators of gas transmission and hazardous liquid pipeline facilities regarding their responsibilities under federal integrity management regulations to perform evaluations of their integrity management programs using meaningful performance metrics.

Advisory Bulletin (ADB-20l2-10) advises operators to critically review their processes and methods for evaluating integrity management program performance and take action to strengthen these processes where warranted. An effective operator performance evaluation process is expected to have the following characteristics:

• A well-defined description of the scope, objectives, and frequency of program evaluations.
• The use of periodic self-assessments, internal or external audits, management reviews, performance metrics analysis, benchmarking against other operators, or other self-critical evaluations to assess program effectiveness.
• Clear performance goals and objectives to measure the effectiveness of key integrity activities
• Clear assignment of responsibility for implementing required actions.
• Review and follow-up of program evaluation results, findings, and recommendations, etc., by appropriate company managers.

Operators are also advised that a clear and meaningful set of performance metrics is essential to program effectiveness. An effective program for measuring integrity management program effectiveness should have the following characteristics:

• A description of the type of performance measures to be used, along with the data sources, data validation and quality assurance activities, the frequency of data collection, and any normalization factors.
• A means to update the performance measures (if needed) to assure they are providing useful information about the effectiveness of integrity management program activities.
• The use of performance metrics data to check and calibrate the operator's risk analysis tools to assure these best represent the performance of the operator's specific assets.

The performance metrics that are required to be reported to PHMSA annually, such as the number of miles of pipeline assessed, number of anomalies found requiring repair or mitigation, etc., are a small subset of the overall suite of metrics used by an operator to evaluate its program. A much larger set of operator-specific metrics to be used internally is needed to effectively evaluate an integrity management program performance. Metrics should be developed for each of the following:

• Overall program effectiveness indicated by the number of releases, number of injuries or fatalities, volume released, etc.
• Specific threats that include both leading and lagging indicators for the important integrity threats on an operator's systems. These include:
  • Activity Measures that monitor the surveillance and preventive activities that are in place to control risk
  • Deterioration Measures that monitor operational and maintenance trends to indicate if the program is successful or weakening despite the risk control activities in place. (Also identified as Operational Measures in ASME B31.8S.
  • Failure Measures that reflect whether the program is effective in achieving the objective of improving integrity. (Also identified as Direct Integrity Measures in ASME B31.8S)
  • Metrics that measure and provide insights into how well an operator's processes associated with the various integrity management program elements are performing. Examples of such processes would include integrity assessment, risk analysis, the identification of preventive and mitigative measures, etc.

Finally, operators must keep records supporting the decisions, analyses, and processes developed and used in their evaluation of integrity management program effectiveness. These records should include those justifying the selection of performance metrics, the performance metric data and trends, and how these metrics are used to improve the integrity management program. Operators should also be diligently working to eliminate information and data gaps throughout their entire integrity management program.

Caltha LLP provides specialized EH&S 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

FERC Proposed Rulemaking To Reduce Reporting and Filings

The Federal Energy Regulatory Commission (FERC) announced on October 18 three proposed regulatory reform actions to ease the regulatory burdens on the natural gas and oil pipeline industries. The Commission issued three Notices of Proposed Rulemaking that would reduce the pipeline industries' regulatory burden:

• A proposal to eliminate 145 annual filings made by Natural Gas Act pipelines as a result of a change in the annual charge assessment unit surcharge;
• A proposal to streamline the processing of rate and other filings by intrastate pipelines performing interstate service under section 311 of the Natural Gas Policy Act and Hinshaw pipelines; and
• A proposal to eliminate oil pipelines' unnecessary filings, update requirements for service, and update requirements for posting tariff information.

Comments on each proposal are due 30 days after publication in the Federal Register.

FERC staff also issued a report that identifies minor revisions to the Commission's natural gas pipeline regulations that may be appropriate to remove reporting requirements that no longer serve their intended purpose. The report was issued pursuant to the Nov. 8, 2011, Plan for Retrospective Analysis of Existing Rules prepared in response to Executive Order 13579, which requested independent regulatory agencies issue plans for periodic retrospective analysis of their existing regulations. Comments on the FERC staff report are due November 18.


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

State Pipeline Damage Prevention Program Grants

The Pipeline and Hazardous Materials Safety Administration (PHMSA) announced over $1.5 million in grants to 22 states to strengthen and support pipeline damage prevention programs. States will use the damage prevention grants to continue implementation of the nine elements of an effective damage prevention program, outlined in the Pipeline Inspection, Protection, Enforcement and Safety Act of 2006. Program elements include effective communications, partnerships, fair and consistent enforcement, training and technology.

Excavation damage is the number one cause of pipeline accidents resulting in fatality or injury. Since 2002, excavation damage resulted in over $190 million in property damage nationwide. Between 2002 and 2011, more than 28 % of all serious pipeline accidents were caused by excavation damage, resulting in 38 fatalities and 148 injuries.

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 

 

Implementation of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is moving forward to implement its new statutory authority to strengthen federal pipeline safety regulations. A notice of proposed rulemaking (NPRM) is the first step to implement the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, which toughened pipeline safety regulations and PHMSA's ability to enforce them.

The Act authorizes PHMSA to increase the maximum civil penalty for pipeline safety violations from $100,000 to $200,000 per violation per day. In addition, the agency will be able to collect a maximum of $2,000,000 for a related series of violations, up from $1,000,000. PHMSA proposes to apply the new maximums in cases that occur after Jan. 3, 2012, the date the Act was signed into law.

Proposed amendments to the Pipeline Safety Regulations also include technical changes and other minor corrections, including returning PHMSA's authority to enforce the provisions of the Oil Pollution Act of 1990, which had been transferred to the Coast Guard during the establishment of the Department of Homeland Security.


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 

 

Proposed Amendment To Hazardous Materials Regulations

The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking to amend the Hazardous Materials Regulations (HMR) to maintain alignment with international standards by incorporating various amendments, including changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations, and vessel stowage requirements.

These revisions are necessary to harmonize the HMR with recent changes made to the International Maritime Dangerous Goods Code, the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air, and the United Nations Recommendations on the Transport of Dangerous Goods-Model Regulations and subsequently address a petition for rulemaking.

Comments must be received by October 15, 2012.


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

 

Chemical Safety Board (CSB) 2012 - 2016 Strategic Plan

The U.S. Chemical Safety Board (CSB) has released its 2012 - 2016 Strategic Plan. The new strategy updates the 2007 - 2012 CSB Strategic Plan, including the CSB's strategic goals, objectives, and associated measures for managing and evaluating agency operations.The final version of the plan features a "CSB Most Wanted Program" that serves to focus CSB outreach initiatives for key CSB recommendations.

The plan contains measurable objections and concentrates on three main goals:

1. Conduct incident investigations and safety studies concerning releases of hazardous chemical substances. This goal fulfills the core missions of the Board by ensuring that CSB selects and completes incident investigations that have the potential to generate recommendations with high preventative impact. It also directs the CSB to develop and complete safety studies with an emphasis on emerging safety issues.
2. Improve safety and environmental protection by ensuring that CSB recommendations are implemented and by broadly disseminating CSB findings through advocacy and outreach. CSB says its successful safety videos are an important component of its dissemination efforts.
3. Preserve the public trust by maintaining and improving organizational excellence. CSB endeavors to use best practice project management in all agency processes, including administration and service functions.

The CSB is an independent federal agency charged with investigating industrial chemical accidents. CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems. The Board also makes safety recommendations to plants, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA.


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 

Rulemaking On Hazardous Materials In Reverse Logistics

The Pipeline and Hazardous Material Safety Administration (PHMSA) is seeking public comment to assist in forming a reverse logistics policy to address the unique requirements of the hazardous materials transportation. PHMSA is working to develop a cost-effective logistical solution that maintains the agency's safety standards. The advanced notice of public rulemaking seeks comment on whether providing a clear definition of reverse logistics will promote the safe transport of hazardous materials. Comments must be submitted by October 3, 2012.

Reverse logistics is the process initiated when a consumer product goes backwards in the supply chain, such as an item being returned to a store by a customer, or when a local retailer sends unused merchandise back to a regional distributor. While returns are a fairly straightforward process for most products, the effort is complicated when a consumer needs to return paint, batteries, or other regulated hazardous materials. That difficulty is multiplied for retailers trying to manage multiple returns to various suppliers at the same time.

Because many reverse logistics shipments contain regulated hazardous materials, shippers may unknowingly violate the hazardous materials regulations, which apply to consumers as well as those involved with the commercial transportation of goods. By clarifying the guidelines for hazmat reverse logistics and increasing public awareness, PHMSA hopes to greatly reduce the occurrence of improperly packaged and inappropriately congregated hazmat items being shipped, as well as the risks for danger when this happens.

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 
 

PHMSA Rule Making On DOT Cylinders

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed amendments to the Hazardous Materials Regulations (HMR) to revise certain requirements applicable to the manufacture, use, and requalification of DOT specification cylinders. PHMSA issued an advance notice of proposed rulemaking (ANPRM) in response to petitions for rulemaking submitted by the regulated community and a review of the regulations applicable to compressed gas cylinders.
PHMSA is not proposing specific amendments to the HMR; rather, the agency is seeking comment on the issues discussed in the ANPRM. The ANPRM focuses on specific petitions for rulemaking and special permits, however, PHMSA will accept comments on the HMR applicable to compressed gas cylinders. Comments must be received by August 27, 2012.

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