Audit, Compliance and Risk Blog

EPA Revises Hazardous Waste Import-Export Requirements

Posted by Jon Elliott on Tue, Nov 29, 2016

The U.S. Environmental Protection Agency (EPA) administers rules governing the import and export of hazardous waste regulated by the Resource Conservation and Recovery Act (RCRA). These rules ensure that the U.S. meets its international responsibilities as a member of the Organization for Economic Cooperation and Development (OECD) by creating national rules that meet agreed-upon OECD standards.

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Tags: Environmental risks, Environmental, EPA, Greenhouse Gas, ghg, Hazcom

The World Decides To Help The Climate By Helping The Ozone Layer

Posted by Jon Elliott on Tue, Oct 25, 2016

Last month I blogged about basic provisions of the Montreal Protocol on Substances that Deplete the Ozone Layer, and ongoing negotiations to expand it to require phaseout of chemicals that harm the stratospheric ozone layer and contribute to climate change (click here, and included links to early blogs on Montreal Protocol issues). At that time, proposals all focused on hydrofluorocarbons (HFCs). At that point, global HFC use was increasing by roughly 10% annually, driven primarily by expanding use for air conditioning as hot developing countries sought to catch up with comfort levels in their developed counterparts. Proposed timelines and end-targets for reversing that expansion varied considerably.

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Tags: Environmental risks, Environmental, EPA, ghg, climate change

U.S. Commission on Civil Rights Criticizes EPA’s Environmental Justice Efforts

Posted by Jon Elliott on Tue, Oct 18, 2016

In September 2016, the U.S. Commission on Civil Rights (Commission) issued its annual “Statutory Enforcement Report for 2016”; this year’s topic is the Environmental Protection Agency’s (EPA’s) efforts to protect and promote “Environmental Justice.” The Commission reviews decades of EPA efforts, and criticizes longstanding inadequacies.

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Tags: Health & Safety, Environmental risks, Environmental, EPA, ghg, Hazcom, RCRA

California Tightens Restrictions On High-Impact Short-Lived Climate Pollutants

Posted by Jon Elliott on Tue, Oct 11, 2016

Attempts to reduce greenhouse gas (GHG) emissions are more complex than they first appear. Reports in the mass media tend to focus on carbon dioxide (CO2). The United Nations Framework Convention on Climate Change (Framework Convention) focuses primarily on six GHGs, including CO2 as well as methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride (SF6). Climate change scientists have identified hundreds of GHGs, with widely varying sources, relative contributions to climate change (numerical “global warming potential (GWP)”, where CO2 is defined as 1.0), and total contribution based on emitted volumes.

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Tags: California Legislation, Greenhouse Gas, ghg, Hazcom, climate change

U.S. and China Renew Climate Change Vows to Jumpstart Paris Agreement

Posted by Jon Elliott on Tue, Sep 27, 2016

In recent years, the United States and China have found a rare basis for cooperation in their joint efforts to accelerate international efforts to manage and reduce climate change. The first significant step in this cooperation was the two countries’ bilateral agreement in November 2014 to manage greenhouse gas (GHG) emissions within their boundaries (I blogged about it here). At the time, the two countries offered their commitments as a way to reinforce international climate change negotiations underway to replace the expiring Kyoto Protocol to the United Nations Framework Convention on Climate Change. In December 2015, those negotiations produced the Paris Agreement, which established global mechanisms for countries to declare self-enforcing national GHG management commitments (I blogged about the Paris Agreement here).

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Tags: EPA, Greenhouse Gas, ghg, climate change

White House Guidance for Agency Consideration of Climate Change in Environmental Reviews

Posted by Jon Elliott on Tue, Sep 20, 2016

On August 2, the White House’s Council on Environmental Quality (CEQ) issued guidance to assist federal agencies in their consideration of the effects of greenhouse gas (GHG) emissions and climate change when evaluating proposed federal actions. I refer to this documents as “the Guidance” below.

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Tags: Environmental risks, Environmental, EPA, Greenhouse Gas, ghg, climate change, CAA, CEQA

New Rules Tighten Greenhouse Gas Emission Standards for Heavy Duty Vehicles

Posted by Jon Elliott on Thu, Sep 15, 2016

The Clean Air Act (CAA) includes extensive regulatory requirements on “mobile sources,” which cover efficiency and emissions standards for a broad range of vehicles with internal combustion engines (automobiles, buses, aircraft), “nonroad engines and vehicles” (including lawnmowers, bulldozers and marine vessels), as well as motor fuel standards intended to promote cleaner burning fuels. The U.S. Environmental Protection Agency (EPA) uses CAA authority to set emission limits from engines, for CAA-regulated air pollutants, including carbon dioxide (CO2) regulated for its greenhouse gas (GHG) aspects.

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Tags: California Legislation, Environmental risks, Environmental, EPA, Greenhouse Gas, ghg, climate change, CAA, Transportation

Extending the Montreal Protocol to Address Climate Change

Posted by Jon Elliott on Tue, Sep 13, 2016

The Montreal Protocol on Substances that Deplete the Ozone Layer provides the international framework for protecting the earth’s stratospheric ozone layer, by identifying and minimizing emissions of ozone depleting substances (ODSs). The original Montreal Protocol was initialed in September 1987 (I summarized it here). It is widely considered an effective example of international cooperation (I blogged about the healing of the “ozone hole” here), in contrast with ongoing struggles to reach binding international agreements to address climate change. In fact, during 2016 efforts are underway to build on the Montreal Protocol’s strengths by amending it to address additional chemicals that may harm ozone and contribute to climate change.

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Tags: EHS, EPA, Greenhouse Gas, ghg, climate change

EPA Takes Another Step Towards Regulating GHG Emissions From Aircraft

Posted by Jon Elliott on Tue, Sep 06, 2016

On July 25, the Environmental Protection Agency (EPA) issued a formal finding under the Clean Air Act (CAA), that greenhouse gas (GHG) emissions from aircraft “endanger public health or welfare.” This aircraft-specific finding builds on EPA’s 2009 finding that GHGs endanger public health, covering the same six GHGs: carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. EPA calculates that aircraft produce 12 percent of all U.S. transportation GHG emissions and more than 3 percent of total U.S. GHG emissions, and that U.S. aircraft GHG emissions represent 29 percent of all global aircraft GHG emissions and 0.5 percent of total global GHG emissions.

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Tags: Environmental risks, Environmental, EPA, Greenhouse Gas, ghg

Paris Agreement On Climate Change Calls For Action By Non-National Entities

Posted by Jon Elliott on Tue, Jun 21, 2016

Last December, representatives of 195 countries agreed to continue to expand global efforts to combat climate change. The new Paris Agreement breaks a longstanding impasse with a clever mixture of multinational agreements and agreements-to-agree. I summarized its provisions (and the history of the United Nations Framework Convention on Climate Change (Framework Convention) it modifies) here.

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Tags: Health & Safety, EHS, Greenhouse Gas, ghg, climate change, global