Audit, Compliance and Risk Blog

Changes to California Carcinogen and Reproductive Toxin Lists

Posted by STP Editorial Team on Wed, Mar 19, 2014

The Office of Environmental Health Hazard Assessment (OEHHA) has made a number of changes to the list of chemicals known to the State of California to cause cancer or reproductive toxicity for purposes of the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).

Read More

Tags: Health & Safety, California Legislation, Environmental risks, Environmental, EHS, EPA, Hazcom

EPA Proposes To Revise The Agricultural Worker Protection Standard

Posted by Jon Elliott on Wed, Mar 05, 2014

The US Environmental Protection Agency (EPA) administers a Worker Protection Standard (WPS) designed to protect workers exposed to agricultural pesticides. WPS is patterned after the Occupational Safety and Health Administration (OSHA's) Hazard Communication Standard (HCS) for workers in most industrial and commercial settings. EPA adopted the WPS in 1992, and just proposed its first revisions on February 20, 2014. Some of these changes incorporate revisions to HCS adopted by OSHA in 2012 (see my earlier blog), while others catch up on two decades of industrial hygiene and worker safety practices. Comments will be due 90 days after the proposal is published, with final approval to follow sometime later.

Read More

Tags: Business & Legal, Employer Best Practices, Health & Safety, OSHA, Employee Rights, Environmental risks, Environmental, EPA, Hazcom

Environmental Compliance: EPA Adopts Hazardous Waste e-Manifests

Posted by Jon Elliott on Wed, Feb 26, 2014

The Resource Conservation and Recovery Act (RCRA) requires you to document all shipments of regulated hazardous wastes. Domestic transportation is documented using Uniform Hazardous Waste Manifests, which are shipping documents prescribed by the US Environmental Protection Agency (EPA) which revises Manifest forms occasionally—including major changes back in 2006. Now EPA has acted again, to create an electronic manifest (“e-Manifest”) option that will take force once EPA finishes the web-page data system required to receive and manage electronic filings.

Read More

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

Environmental Health & Safety (EHS) Roundup 2013

Posted by Jon Elliott on Mon, Feb 03, 2014

The year 2013 has been another relatively quiet one for most environmental health and safety (EH&S) compliance personnel. Continuing differences in Congress have stymied would-be initiatives on both sides of the partisan aisles, so there were no meaningful legislative changes.

Read More

Tags: Health & Safety, OSHA, Environmental risks, Environmental, EHS, EPA, Hazcom, Transportation

Canadian Oil Industry—Liability Insurance for Rail vs. Pipeline

Posted by STP Editorial Team on Wed, Jan 29, 2014

Canadian regulators are focusing their attention on facilitating development in the oil and gas industry, and they are also increasing the accountability of operators. Significantly, environmental liability insurance requirements are expected to increase for both pipeline and railway operators, reducing the extent to which governments and taxpayers cover the costs of cleanup and other damages caused by spills and accidents.

Read More

Tags: Business & Legal, Environmental risks, Environmental, Oil & Gas, Insurance, Insurance Claims, Transportation, Canadian

Hazardous Substances: New Form Offers Way Out Of Prop. 65 Prosecution

Posted by Viola Funk on Wed, Jan 22, 2014

A recent change to rules around Proposition 65 lawsuits will make it easier for some businesses to avoid being prosecuted for infringement of the Safe Drinking Water and Toxic Enforcement Act. The alteration covers cases in which individuals allege inadequate warning signage regarding the release of substances known to cause cancer or birth defects or other reproductive harm. Such suits have proliferated under the legislation, embroiling business owners in costly legal battles.

Read More

Tags: Corporate Governance, Business & Legal, Health & Safety, Environmental risks, Environmental, Hazcom

EPA Clarifies Regulation of CO2 Geologic Sequestration

Posted by Jon Elliott on Fri, Jan 17, 2014

With legislation action on climate change deadlocked by partisan divisions in Congress, the Obama Administration is pursuing a growing set of administrative and regulatory initiatives under existing authority. Many of these involve actions by the Environmental Protection Agency (EPA) applying Clean Air Act (CAA) authority, but some involve other EPA authority and/or other agencies.

Read More

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

Environmental Compliance: EPA Revises Volatile Organic Compounds

Posted by STP Editorial Team on Wed, Jan 15, 2014

Effective November 21, 2013, EPA exempted 2,3,3,3-tetrafluoropropene (also known as HFO–1234yf) from the regulatory definition of Volatile Organic Compounds (VOCs). This compound will not be counted as a VOC for entities using or producing HFO–1234yf in a product other than an aerosol coating, limiting the VOC emissions from a facility, or otherwise controlling the use of VOC for purposes related to attaining the ozone NAAQS. Emissions of this compound will not be considered in determining whether a proposed new or modified source triggers the applicability of Prevention of Significant Deterioration (PSD) requirements, in areas where the PSD program is implemented by the EPA or a delegated state, local, or tribal agency. This action may also affect whether HFO–1234yf is considered a VOC for state regulatory purposes, depending on whether the state relies on the EPA’s regulatory definition of VOCs.

Read More

Tags: Health & Safety, Environmental risks, Environmental, EPA, Greenhouse Gas, ghg, Hazcom, Oil & Gas

Common Violations at Dealerships, Service and Repair Facilities

Posted by STP Editorial Team on Mon, Dec 09, 2013

Based on a limited survey of the Certified Unified Program Agencies (CUPAs) of the California Environmental Protection Agency (Cal/EPA), the Department of Toxic Substances Control (DTSC) found the following top eight violations:

Read More

Tags: Corporate Governance, Health & Safety, Environmental risks, Environmental, EPA

Environmental Compliance: EPA Tracks Reductions in GHG Emissions

Posted by Viola Funk on Fri, Dec 06, 2013

Do you ever wonder whether auditing of greenhouse gas emissions is working? It may be a bit early in the game to say for sure, given that GHG emission tracking standards are a recent phenomenon. But an annual report compiled by the U.S. Environmental Protection Agency (EPA) may be a good gauge of trends in emission reductions, judging by its latest installment.

Read More

Tags: Corporate Governance, Business & Legal, Health & Safety, Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, ghg