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

New York City Clean Act Controls Industial Laundries Within the City

The Clean Act was passed by the New York City Council in June 2016. Pending the Mayor’s signature industrial launders doing business in New York City will have 180 days in which to submit the license application.



The Clean Act adds licensing requirements for linen and uniform supply launderers serving New York City. Each licensee will be required to attach a label or tag to all handcarts and pushcarts that displays the licensee’s name, address and license number. In addition, all bills, tickets, cards, advertising or stationery issued or distributed by any licensee shall contain such licensee’s name, address and license number. In addition, each vehicle used for retail or industrial laundry delivery shall display the licensee’s name, business address and business telephone number and the license number assigned.

The Clean Act also includes minimum standards of cleanliness and hygiene to be observed by each permitee.



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 

NY DEC Emergency Rule Making Restricting Use Of Perfluorooctane Related Chemcials

The New York State Department of Environmental Conservation (DEC) filed a Notice of Emergency Adoption and Proposed Rule Making to classify perfluorooctanoic acid (PFOA-acid), ammonium perfluorooctanoate (PFOA-salt), perfluorooctane sulfonic acid (PFOS-acid), and perfluorooctane sulfonate (PFOS-salt) as hazardous substances at the request of the New York State Department of Health (NYSDOH).


This rule making also provides time for facilities storing fire-fighting foam containing one or more of these newly listed hazardous substances to properly dispose of it and provides time for firefighting operations to find replacement foams. This proposal also corrects the tables of hazardous substances by providing units for reportable quantities.



The temporary emergency rule was effective on April 25, 2016, while the state finalizes the proposed amendments to 6 NYCRR Part 597, Hazardous Substances Identification, Release Prohibition, and Release Reporting. DEC has concluded that these substances meet the definition of a hazardous substance based upon the conclusion of NYSDOH that the combined weight of evidence from human and experimental animal studies indicates that prolonged exposure to significantly elevated levels of these compounds can affect health and, consequently, pose a threat to public health in New York State when improperly treated, stored, transported, disposed of or otherwise managed. NYSDOH scientists have concluded that it is essential to list these chemicals as hazardous substances.



Once substances are determined to be hazardous substances, DEC regulates their handling and storage and has authority to remediate sites contaminated with them. The Chemical Bulk Storage regulations (6 NYCRR 596-599) provide standards for the proper handling and storage of bulk quantities of hazardous substances to prevent spills and releases to the environment, prohibit the release of hazardous substances to the environment, and require the reporting of certain releases of hazardous substances to DEC. Certain facilities that store hazardous substances must apply to DEC for a registration certificate to operate.



A new provision, paragraph 597.4(a)(3), will allow entities with fire-fighting foam the time necessary to determine if stored foam contains one or more of these hazardous substances. If the stored foam contains one of these substances, the facility would not be allowed to use the foam for fire-fighting after April 25, 2017. It may be used for fire-fighting until then but not for any other purpose such as training. Foam that is prohibited for use after April 25, 2017 should be safely disposed in accordance with federal, state, and local requirements. Replacement foam may not contain a hazardous substance at a concentration that would result in the release of more than the reportable quantity (one pound) when used as a fire-fighting foam.


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 

RCRA Program Delegation Approved For New York State DEC

US EPA has approved the delegation for its hazardous waste programs to the New York State Department of Environmental Conservation (NYSDEC or DEC) relating to used oil management. New York had applied to EPA for final authorization of changes to its hazardous waste program under the Resource Conservation and Recovery Act (RCRA). This final authorization will become effective on May 10, 2013 unless EPA receives adverse written comment by April 10, 2013.

New York has responsibility for permitting Treatment, Storage, and Disposal Facilities (TSDFs) within its borders (except in Indian Country) and for carrying out the aspects of the RCRA program described in its revised program application, subject to the limitations of the Hazardous and Solid Waste Amendments of 1984 (HSWA).

The effect of this decision is that a facility in New York subject to RCRA will now have to comply with the authorized State requirements instead of the equivalent Federal requirements in order to comply with RCRA. New York has enforcement responsibilities under its State hazardous waste program for violations of such program, but EPA retains its authority under RCRA. This includes the authority to:

• Do inspections, and require monitoring, tests, analyses, reports or other actions
• Enforce RCRA requirements and suspend or revoke permits
• Take enforcement actions regardless of whether the State has taken its own actions.

Caltha LLP  is an environmental consultant providing specialized expertise to clients in New York and 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

VOC Content Restrictions on Consumer Products - Revised NYDEC Rule

In January 2010, revised New York Department of Conservation (DEC) regulations became effective relating to the volatile organic compound (VOC) content of certain consumer products. In 2009, DEC made revisions to Part 235-2.1 including definitions for eleven new categories of consumer products that are being regulated in the revised Part 235. The new categories are: adhesive remover, anti-static (non-aerosol), electrical cleaner, electronic cleaner, fabric refresher, footwear or leather care, graffiti remover, hair styling products, shaving gel, toilet/urinal care, and wood cleaner. DEC also added definitions for the contact adhesive product category and is revised the definitions for two previously regulated product categories: air fresheners and general purpose degreasers.

DEC also modified several of the existing definitions and added other new definitions. For example, the Department revised the existing definition of "deodorant" and added a new definition for "deodorant body spray." Some of the new definitions come from the revised Ozone Transport Commission (OTC) model rule for Consumer Products. These definitions include: "APC VOC Standard," "Energized electrical cleaner," and "Existing product."

The revisions to section 235-3.1 amended the Table of Standards to include the VOC limits for the new categories and the revised VOC limits for the Contact Adhesive product category. The prohibitions concerning sale of these consumer products apply to products manufactured on or after January 1, 2010 which contain VOCs in excess of the VOC content limits specified in the Table of Standards (Subpart 235-3.1[a]).

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

NY Proposed Rules for Used Electronic Equipment - CRT

The New York State Department of Environmental Conservation (NYSDEC) is currently drafting a proposed rules for the management of used electronic equipment. Posting of the preliminary draft regulation is anticipated for Spring 2009, followed by further opportunity for public comment.

The resulting proposed rulemaking will amend NYSDEC regulations to streamline the management of used electronic equipment, whether regulated as hazardous waste or solid waste. The main issues to be addressed in the proposed rulemaking are:

• Adopting provisions of the Federal Cathode Ray Tube (CRT) Rule


• Adopting management standards for Collectors, Dismantlers, and Recyclers of Used Electronic Equipment


• Adopting provisions of the New York State Wireless Telephone Recycling Act


• Amending the requirements of New York's current Generator "c7" Notification

Currently in NYS, intact CRTs destined for recycling are eligible for the hazardous scrap metal exemption. However, when the CRT glass is no longer adherent to the metal, CRT glass could be regulated hazardous waste. The Federal CRT Rule contains the provisions to conditionally exclude this CRT glass from hazardous waste rules.

The current c7 notification requirements require generators (other than CESQGs) sending used electronics for recycling under the hazardous scrap metal exemption to file notifications. In the rulemaking, the NYSDEC is proposing to change the requirement to “[generators] must maintain on site, for a period of three years from the date of each shipment, the names and locations of the dismantling or recycling facilities and any intermediate receiving facilities."

Caltha LLP provides specialized expertise to clients nationwide in the evaluation solid waste and hazardous waste rules, developing waste handling procedures, and preparing cost-effective waste management programs.

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

New York (NYDEC) Plastic Bag and Film Recycling Rules- Effective January 2009

On December 13, 2008, Governor Patterson signed New York State's Plastic Bag Reduction, Reuse, and Recycling Act. This law requires larger retail and chain stores to accept clean plastic bags for recycling starting January 2009.

Under the new law, retail establishments with more than 10,000 square feet of retail space, or those that are part of a chain with more than five stores (each with more than 5,000 square feet of retail space), must provide bins for the collection of used plastic carryout bags, recycle the returned bags and keep records for three years describing the amount of plastic bags collected and recycled.

The new state law will pre-empt local governments from adopting their own plastic bag recycling laws. However, it is expected that additional legislation will be enacted to amend the bill signed by the governor to allow New York City to retain an effective and popular local law that established a citywide recycling program for plastic carryout bags and film plastics. Another expected amendment will require the recycling of film plastics as part of the statewide program.

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