Audit, Compliance and Risk Blog

Energy companies have used hydraulic fracturing—often referred to as ‘fracking’—since the 1940s in order to enhance recovery of oil and natural gas from low-permeability (“tight”) rock formations.
Frackers pump high-pressure fluids into rock formations to create and expand cracks and create pathways for valuable hydrocarbons to flow out.  The stimulant fluids are usually water-based, with additional chemicals (acids, surfactants, biocides, etc.) to improve the effectiveness of the fracking process as well as solid ‘proppants’, which prop open the expanded openings (sand, etc.). 

Increasingly, your approach to climate change issues provides an important basis for your customers’ and other stakeholders’ purchasing and investment decisions with your organization. They may research how your organization manages its  greenhouse gas (GHG) emissions (your  ‘carbon footprint’) because, if you provide them with goods and services, the GHG emissions associated with your activities may be attributed to them.

On June 26, the federal District of Columbia Circuit Court of Appeals issued a major decision, upholding four rulings by the U.S. Environmental Protection Agency (EPA).  All four rulings expand the regulation of greenhouse gas (GHG) emissions under the Clean Air Act (CAA). The case is Coalition for Responsible Regulation v. EPA.1 

Although federal and California regulations have introduced numeric effluent limits (NELs) for stormwater discharges, technical issues and an adverse regulatory environment have stalled these efforts. Here is a summary of stormwater regulatory history, and the current regulatory atmosphere.

The Santa Barbara County Air Pollution Control District is proposing to amend District rules to reduce air pollution caused by cleaning solvents.  The provisions would include requirements for work practices, reactive organic compound (ROC) content limits, and solvent cleaning devices and methods.The Santa Barbara County Air Pollution Control District is seeking to amend rules concerning Surface Coating of Metal Parts and Products (Rules 330), Surface Coating of Aerospace Vehicles and Components (Rules 337), Polyester Resin operations (Rules 349), and Adhesives and Sealants (Rules 353). 

OSHA’s New Hazcom Explained

Everything you think you know about

about hazardous chemicals is about to change

Since the 1980s, most employers throughout the U.S. and Canada have been required to protect workers from workplace chemical hazards, and to train workers to protect themselves.  The cornerstones of these programs have been manufacturer-supplied summaries called Material Safety Data Sheets (MSDSs).  Sad to say, but sometimes they’re wobbly cornerstones, because they start with hazard information developed by company scientists for agency scientists, and may or may not extend that information into practical hands-on guidance for employers and workers.  They also vary in detail, because the Occupational Safety and Health Administration (OSHA) provides guidance for appropriate topics but no requirements that the content be practical.  While some MSDSs are fine, we’ve all grumbled about others that report clinical results of the lethal dose of constituent chemicals to half the test population (LD50), but then recommend no more than "use appropriate personal protective equipment."

A free report authored by Gary Lucks is now available from Specialty Technical Publishers.   The 23-page 2011 California Environmental Legislative Year in Review provides a comprehensive synopsis and analysis of the 2011 environmental legislation enacted by the state of California. This comprehensive report covers the California Environmental Quality Act (CEQA), energy, land use, climate change solid waste, hazardous waste and materials, storage tanks, and water quality. Download the Free Report Now. The following is the introduction to the report:

In November 2011, EPA proposed substantial revisions to current regulations addressing petroleum releases from underground storage tank (UST) systems. The regulations (40 CFR Part 280) were promulgated in 1988 and imposed strict controls on tank design, construction, and installation. The proposed revisions (76 FR 71708) target and further reduce releases caused by poor operation and maintenance, releases from piping, spills and overflows associated with deliveries (especially releases at the dispenser), and ineffective release detection equipment. The revisions minimize retrofitting requirements for existing underground storage tank systems, while mandating additional release prevention requirements for new underground storage tank systems.