Audit, Compliance and Risk Blog

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.

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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.

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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:

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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.

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

Regulatory Compliance: Do These Penalties Seem Larger To You?

Posted by Jon Elliott on Mon, Nov 25, 2013

Most laws include penalty provisions, for assessment against people who fail to comply with legal responsibilities created by the laws. Back in 1996, Congress noticed that inflation was steadily reducing the deterrent effects of the penalties set forth in statutes, and that Congress itself was not reliably adjusting the maximum penalties assessable by enforcement personnel. Rather than burden itself with a responsibility to amend laws to keep up with inflation, Congress enacted the passed Debt Collection Improvement Act (DCIA) of 1996 to assign that responsibility to administrative agencies. DCIA requires most federal agencies to issue rules at least every 4 years, adjusting most penalties for inflation. In the ensuing 17 years, most agencies have made these periodic adjustments—larger in times of high inflation and lower in times of low inflation.

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Tags: Corporate Governance, Business & Legal, Environmental risks, Environmental, EPA

New Pacific Coast Climate Change Initiative

Posted by Jon Elliott on Thu, Nov 14, 2013

On October 28, British Columbia, California, Oregon and Washington signed the Pacific Coast Action Plan on Climate and Energy, committing themselves to align efforts to control greenhouse gas (GHG) reductions to combat climate change, and to promote clean energy. The Action Plan is adopted under the aegis of the Pacific Coast Collaborative, which encompasses these four jurisdictions plus Alaska.

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

Lead Poisoning Prevention Week

Posted by Viola Funk on Mon, Oct 21, 2013

It’s common knowledge now that lead is a systemic poison. Overexposure to it can damage our blood-forming, nervous, urinary and reproductive systems. In the past, lead was commonly added to industrial paints because of its characteristic corrosion resistance and color enhancement. Lead Poisoning Prevention Week takes place from October 20–26. Sponsored by the US Environmental Protection Agency (EPA), this year’s event focuses on protecting children from exposure to lead. EPA and partner agencies such as HUD are helping raise awareness among parents of ways to combat lead poisoning, from monitoring children’s consumption of certain types of imported candy to screening those most liable to be exposed to lead in the home.

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Tags: Business & Legal, California Legislation, Environmental risks, Environmental, EPA

Je me souviens de…Offsetting GHG Emissions

Posted by Viola Funk on Wed, Sep 25, 2013

The greenhouse gas cap-and-trade program overseen by California’s Air Resources Board (ARB), which began earlier this year, not only allows for use of approved offsets to meet a portion of an entity’s emission reduction requirements. Entities will soon also be able to comply with the program by participating in its counterpart in the Canadian province of Quebec. By January 1, 2014, ARB’s cap-and-trade program will be linked with Quebec’s. A press release from ARB sums up key features of the linkage:

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

California Adopts Safer Consumer Products Regulations

Posted by Jon Elliott on Thu, Sep 19, 2013

Do you know what's in the chemical products you buy and use, and whether they're "safe?"  Effective October 1, 2013, California regulations provide criteria and procedures for state-level identification and listing of likely-hazardous chemicals of concern.  Manufacturers and importers will be required to evaluate chemicals of concern in consumer products, their potential alternatives, and how best to limit exposure or reduce hazards.  Assemblers and retailers will have related responsibilities.  Although these requirements apply directly only within California, any reviews and reformulations are likely to affect global production and distribution decisions.

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

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