Audit, Compliance and Risk Blog

Two Important Oil & Gas Conferences

Posted by Lorraine O'Donovan on Wed, Sep 11, 2013

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Tags: Business & Legal, Environmental risks, Environmental, Greenhouse Gas, ghg, Oil & Gas

Motor Carrier Registration Systems to be Upgraded and Web-Based

Posted by Jon Elliott on Fri, Aug 30, 2013

Last week the Federal Motor Carrier Safety Administration (FMCSA) published major changes in the registration requirements it imposes on “motor carriers” that use roads and highways to transport materials—including hazardous materials.  Over the next two years, these changes will consolidate four separate registration systems into a new web-based Unified Registration System (URS), designed to cover every domestic entity subject to FMCSA authority.  Most elements of the new regulations will take effect on October 23, 2015, to allow FMCSA to develop additional URS features and to conduct several related rulemakings, and to allow regulated entities to prepare for the changes in compliance requirements.

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

Obama Issues Executive Order On Chemical Facility Safety

Posted by Jon Elliott on Wed, Aug 21, 2013

One small but critically important sub-category of chemical incidents consists of those that can produce mass casualties, usually when a cloud of toxic or superheated gases are spewed out by a fire or explosion.  Given America’s fragmented approach to hazardous materials regulation, it’s no surprise that separate regulatory programs have grown up to address these concerns—leading inevitably to overlaps and gaps in coverage.

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

EPA Excludes Solvent-Contaminated Wipes From RCRA Regulation

Posted by Jon Elliott on Wed, Aug 14, 2013

All hazardous wastes are not created equal.  The basic model is that:

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Tags: Business & Legal, Employer Best Practices, Health & Safety, Environmental risks, Environmental, EHS, EPA, RCRA

Environmental Compliance: One Chemical, Many Regulations

Posted by Jon Elliott on Fri, Aug 02, 2013

If government provided a unified approach to chemical regulation, then each chemical might be subject to a single set of requirements, which ideally would be tailored to reflect chemical-specific hazards throughout its life cycle.  Instead, each chemical is subject to its own loosely connected (some would say haphazard) collection of environmental, health and safety (EH&S) requirements.  Some are federal, some are state (or provincial if you’re in Canada), and others are regional and even local.  You may need to refer to agencies at all three levels (federal, state and local) to identify your regulators and their requirements – although many organizations only deal with the agency responsible for permitting and inspecting day-to-day activities.

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Tags: Audit Standards, Environmental risks, Environmental, EHS, EPA, Hazcom, MSDS, mact

Obama Administration Announces Climate Action Plan

Posted by Jon Elliott on Wed, Jul 17, 2013

Partisan divides in Washington are preventing legislative action to reduce emissions of greenhouse gases (GHGs) and climate change, but President Obama recently announced administrative initiatives to advance these efforts even without Congressional action.  His new Climate Action Plan reaffirms domestic initiatives led by the Environmental Protection Agency (EPA), and international GHG emission reduction and climate change efforts.  The Plan has the following three main “pillars”:

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

STP Launches New Industry-Specific MACT Standards Guides

Posted by Lorraine O'Donovan on Fri, Jul 12, 2013

Organizations increasingly need specialized guidance in order to self-audit and show efforts to comply with legislation, and demonstrate due diligence.

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Tags: Corporate Governance, Business & Legal, Audit Standards, Environmental risks, Environmental, EHS, mact

Environmental Compliance: TRI Reports Due

Posted by Jon Elliott on Fri, Jul 05, 2013

July 1 was the deadline for subject facilities to file their annual toxic chemical release inventory (TRI) reports with the US Environmental Protection Agency (EPA) and their state, on one of two EPA-mandated forms, Form R or Form A.  These TRI reports are mandated by Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), which was adopted as the first Congressional response to the December 1984 toxic gas disaster in Bhopal, India.

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

Environmental Compliance: Changes to California Training Requirements

Posted by Viola Funk on Wed, Jul 03, 2013

California Revises Wastewater Treatment Plant Operator Certification Rules

The latest State Water Resources Control Board (SWRCB) regulatory tweaks broaden coverage but also give wastewater treatment plant owners some welcome wiggle room. Effective April 1, 2013, the SWRCB has revised its regulations regarding wastewater treatment plant classification, operator certification, and contractor registration. The rules have been expanded to cover privately owned wastewater treatment plants. However, they also establish a provisional operator certification. This means owners of Class I wastewater treatment plants who are finding it hard to recruit certified operators may employ provisional operators while conducting their search. In addition, the definition of wastewater treatment plant has been revised to clearly state that water recycling treatment plants are included within the definition. Numerous other key changes affecting California CCR compliance have been made to these regulations.

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Tags: Corporate Governance, Employer Best Practices, Health & Safety, California Legislation, Training, Environmental risks, Environmental

Environmental Law: US Updates

Posted by Viola Funk on Tue, Jun 11, 2013

PSD Rules Rescinded In Part

Recent court decisions rescind portions of EPA Clean Air Act rules governing Prevention of Serious Deterioration (PSD) and renewable fuels. For example, in October 2010, EPA adopted rules allowing for significant impact levels (SILs) and significant monitoring concentrations (SMCs) for sources of PM-2.5. However, in January of this year the D.C. Circuit upheld most elements of the 2012 standards, but vacated and remanded provisions establishing and applying projections of cellulosic biofuel use. American Petroleum Institute v. EPA, ___ F.3d ___ (D.C. Cir. 2013).

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Tags: Health & Safety, OSHA, Environmental risks, Environmental, EPA, ghg