Strategic planners around the world are preparing “climate change adaptation plans,” designed to identify their organization’s key activities and missions, evaluate how climate change might affect them, and develop organizational changes designed to anticipate and adapt in ways that preserve the organization’s performance. On October 31, the US Environmental Protection Agency (EPA) issued its own Climate Change Adaptation Plan. EPA’s divisions (Water, Air and Radiation, etc.) and 10 regional offices also issued plans covering their activities. These Plans provides a collective model for multi-level organizational plans, and also tell organizations in the US what help to expect from EPA when they plan for their own adaptations to climate change.
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Important Clean Air Act (CAA) elements direct the US Environmental Protection Agency (EPA) to reduce emissions of hazardous air pollutants (HAPs). Unlike the conventional pollutants associated with regional problems such as smog or acid rain, HAPs represent a list of 187 specific air toxics that can be harmful in low concentrations in much smaller areas. HAPs are subject to tighter controls and lower permitting thresholds.
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The Clean Water Act (CWA), as amended after the Exxon Valdez spill by the Oil Pollution Act of 1990, imposes oil spill planning requirements on onshore and offshore facilities involved in the handling and transport of oil. These facilities may be required to prepare and implement a Spill Prevention, Control and Countermeasure (SPCC) Plan (and perhaps a more detailed Facility Response Plan). During 2001-2011, EPA adopted a series of significant changes to its SPCC Plan regulations, requiring compliance by most facilities no later than November 10, 2011.
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In August 2013, President Obama issued an Executive Order directing federal regulatory agencies to review specified regulatory programs that are designed to prevent catastrophic releases of toxics: Occupational Safety and Health Administration (OSHA) Chemical Process Safety Management Standard (PSM); Environmental Protection Agency (EPA) Accidental Release Prevention (ARP) program and Emergency Planning and Right-to-Know Act (EPCRA) program; and Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program (I blogged about the EO here, OSHA’s consideration of PSM changes here, and about one of the agencies’ joint reports on progress here). EPA has just issued a request for information on the possible revisions to ARP requirements, which are described below.
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Did you know that if all the oil from American do-it-yourself oil changers were recycled, it would be enough motor oil for more than 50 million cars a year? Wow! Imagine how much foreign oil that would eliminate.
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Since the US Supreme Court affirmed in 2007 that the Clean Air Act (CAA) provides the Environmental Protection Agency (EPA) with authority to regulate carbon dioxide (CO2) and other greenhouse gases (GHGs), EPA has pursued a growing set of regulatory initiatives. In each, EPA has attempted to fit GHGs into statutory and regulatory programs originally designed for more conventional pollutants – and the entities it targets have sued the agency claiming the stretch to GHGs exceeds EPA’s authority. Each court decision has adjusted the contours of EPA’s CAA authority, legitimizing some stretches and vacating others.
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Investigation of the 2010 spill at Marshall, Michigan, the largest on-land spill in US history, underlines the reality that a Facility Response Plan (FRP) is more than a government-required document—an inadequate document or plan can lead to environmental and economic disaster. Owners and operators of onshore pipelines must review and update FRPs every five years from the date of last submission or last approval, and whenever new or different operating conditions arise that would affect the plan. (49 CFR 194.121 Response Plan Review and Update Procedures). PHMSA recently released two Advisory Bulletins reminding operators what it requires in an FRP and listing five of the most common reasons for it to reject an FRP.
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Last August, President Obama issued an Executive Order (EO 13650) to agencies with responsibilities for chemical facility safety (I blogged about it here). The EO provides for a Chemical Facility Safety and Security Working Group, co-chaired by the Department of Homeland Security (DHS, which administers the Chemical Facility Anti-Terrorism Standards (CFATS) program), Environmental Protection Agency (EPA, which administers the Accidental Release Prevention (ARP) program under Clean Air Act) and Department of Labor’s Occupational Safety and Health Administration (OSHA, which administers Chemical Process Safety Management (PSM) Standard), and also including the Departments of Transportation, Justice (DOJ) and Agriculture. It directs them to work together to improve their operational coordination, and to consult with other security and environmental agencies at all levels of government, as well as the White House.
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On June 2, the U.S. Environmental Protection Agency (EPA) proposed a new Clean Power Plan, in which the agency will apply its authority under the Clean Air Act (CAA) to dramatically reduce greenhouse gas (GHG) emissions from fossil fuel-fired electric generating units (EGUs). EPA calculates that these power plants account for roughly one-third of all domestic GHG emissions in the US. Advocates on opposite sides of this controversial proposal claim this Plan would either become the most important US initiative to address climate change, and/or would crash economies through much of the US heartland by strangling coal-fired electricity production. Let’s hope we end up closer to the optimistic scenario!
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It's nearly time to start worrying that outdoor work in the summer sun will lead to heat illness. The federal Occupational Safety and Health Administration (OSHA) provides some guidance to employers and their workers, while the Sun Belt California's Division of Occupational Safety and Health (Cal/OSHA) administers detailed regulatory requirements promulgated under state law. If you have outdoor workers in California you must comply with the following requirements, while if you're anywhere else you should at least consider them.
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