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

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

EPA Proposes Review of SIPs For SSM Requirements

The EPA is proposing to take action on a petition for rulemaking filed by the Sierra Club in 2011 concerning the treatment of excess emissions in state rules by sources during periods of startup, shutdown, or malfunction (SSM). EPA is proposing to grant in part and to deny in part the request to rescind its policy interpreting the Clean Air Act (CAA) to allow states to have appropriately drawn state implementation plan (SIP) provisions that provide affirmative defenses to monetary penalties for violations during periods of SSM. The EPA is also proposing either to grant or to deny the Petition regarding existing SIP provisions related to SSM in each of 39 states identified in the petition.

For each of those states where EPA proposes to grant the petition concerning specific provisions, EPA also is proposing to find that the existing SIP provision is substantially inadequate to meet CAA requirements and proposes a "SIP call." For those affected states EPA will require the states to submit a corrective SIP revision. Comments on the proposed actions must be received on or before March 25, 2013.

Through this rulemaking, EPA intends to clarify its interpretation of the CAA regarding excess emissions during SSM events. EPA may find specific SIP provisions to be substantially inadequate to meet CAA requirements; if a state's existing SIP provision allows an automatic exemption for excess emissions during periods of startup, shutdown, or malfunction, then the EPA may determine that the SIP provision is substantially inadequate because the provision is inconsistent with requirements of the CAA.
The affected States include:

Alabama
Alaska
Arizona
Arkansas
Colorado
Delaware
District of Columbia
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
New Hampshire
New Jersey
New Mexico
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Rhode Island
South Carolina
South Dakota
Tennessee
Virginia
Washington
West Virginia
Wyoming

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

Schedule For Action On State Regional Haze Plans

The U.S. Environmental Protection Agency (EPA) has announced a court ordered schedule to review and act on more than 40 state regional haze reduction plans, designed to improve visibility in national parks and wilderness areas. The EPA action by itself does not establish control requirements; EPA will work with the states to approve their plans by the court ordered deadline in the agreement. Under the terms of the consent decree, if a state plan cannot be approved, EPA will determine an appropriate federal plan.

The dates for promulgation of final rules (either accepting or rejecting State plans) begin December 13, 2011 and run through November 15, 2011. States are grouped within this timeframe.

EPA initially issued a rule in 1999 requiring states to submit regional haze plans. These plans were due in December 2007, but no action was taken by the agency in response to the submittals. National Parks Conservation Association and other environmental groups sued the agency in August 2011 to take action on these plans, and the consent decree resolves this litigation. EPA will accept public comment on this agreement for 30 days following publication of a notice in the Federal Register.

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

Missouri DNR Electronics Scrap Management Rule

The Missouri Department of Natural Resources (DNR) has completed rulemaking under to regulate the collection and recycling of computers under 10 CSR 25-19.010 Electronics Scrap Management. These rules were required in the Manufacturer Responsibility and Consumer Convenience Collection and Recovery Act. The Act requires manufacturers of computers to implement recovery plans for the collection and recycling or reuse of their obsolete equipment. The recovery plan must be implemented and a copy of the plan submitted to the Department of Natural Resources before the manufacturer can sell its computers in Missouri. Manufacturers must also label their equipment to identify themselves as the manufacturer.

Requirements for the recovery plan and reporting by computer manufacturers are listed in the Act. Retailers are prohibited from selling new computers in Missouri unless the equipment contains a manufacturer's label and the manufacturer is listed by the department as having a recovery plan.

The Act required the DNR to promulgate rules by July 1, 2009 to implement the law. Although many of the details are found in the law itself, the intent of the rule is to implement the act by further defining some of the terms used, clarifying who the law applies to, clearly stating the requirements for both manufacturers and retailers and establishing the standards for handling equipment covered by the law. The proposed rule was published in the Missouri Register on Aug. 3, 2009.

The final rule scheduled to be published in the March 30 update of the Code of State Regulation and will be effective on April 30, 2010.

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

Tighter Water Quality Standards Required By EPA For Mississippi River

On December 15, 2008, USEPA informed the Missouri Department Natural Resources (MDNR) that new or revised water quality standards are necessary to protect the Mississippi River in Missouri. MDNR designated many stream segments and all of its lakes for recreational uses. However, Missouri did not assign the highest level of recreational use to a 195.5-mile segment of the Mississippi River that flows from St. Louis to the confluence of the Mississippi and Ohio Rivers. This EPA action directs the State to address approximately 160 miles of the Mississippi River to ensure that swimming, water-skiing and other recreational uses are protected. This will require MDNR to assign more stringent water quality criteria, which may in turn result in tighter wastewater discharge permit limits.

This action could impact many municipal and industrial NPDES permitted discharges in this reach of the Mississippi River, whether or not existing water quality data indicate that the river does/ does not currently meet recreational use standards.

Caltha LLP assists clients nationwide in addressing water quality standards in permitting and environmental reviews.

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

Missouri (MDNR) Nutrient Water Quality Criteria For Streams

The Missouri Department of Natural Resources (MDNR) has begun the formal process of setting nutrient water quality criteria for streams and rivers in the State, as required under section 304(a) of the Clean Water Act. This is the second phase of a process approved by US EPA in 2005 to set water quality standards for specific nutrients in waters of the State. This process was detailed in the document "Nutrient Criteria Plan".

Nutrient criteria for lakes and reservoirs have already been drafted and are scheduled for submission into the rulemaking process as a part of revision to Water Quality Standards.

Beginning in February 2009, MDNR will be conducted public meetings to solicit input into the development of nutrient criteria for streams and rivers.

Caltha LLP assists clients nationwide in assessing and addressing water quality standards.

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