Audit, Compliance and Risk Blog

Extending the Montreal Protocol to Address Climate Change

Posted by Jon Elliott on Tue, Sep 13, 2016

The Montreal Protocol on Substances that Deplete the Ozone Layer provides the international framework for protecting the earth’s stratospheric ozone layer, by identifying and minimizing emissions of ozone depleting substances (ODSs). The original Montreal Protocol was initialed in September 1987 (I summarized it here). It is widely considered an effective example of international cooperation (I blogged about the healing of the “ozone hole” here), in contrast with ongoing struggles to reach binding international agreements to address climate change. In fact, during 2016 efforts are underway to build on the Montreal Protocol’s strengths by amending it to address additional chemicals that may harm ozone and contribute to climate change.

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Tags: EHS, EPA, Greenhouse Gas, ghg, climate change

EPA Takes Another Step Towards Regulating GHG Emissions From Aircraft

Posted by Jon Elliott on Tue, Sep 06, 2016

On July 25, the Environmental Protection Agency (EPA) issued a formal finding under the Clean Air Act (CAA), that greenhouse gas (GHG) emissions from aircraft “endanger public health or welfare.” This aircraft-specific finding builds on EPA’s 2009 finding that GHGs endanger public health, covering the same six GHGs: carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. EPA calculates that aircraft produce 12 percent of all U.S. transportation GHG emissions and more than 3 percent of total U.S. GHG emissions, and that U.S. aircraft GHG emissions represent 29 percent of all global aircraft GHG emissions and 0.5 percent of total global GHG emissions.

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

Paris Agreement On Climate Change Calls For Action By Non-National Entities

Posted by Jon Elliott on Tue, Jun 21, 2016

Last December, representatives of 195 countries agreed to continue to expand global efforts to combat climate change. The new Paris Agreement breaks a longstanding impasse with a clever mixture of multinational agreements and agreements-to-agree. I summarized its provisions (and the history of the United Nations Framework Convention on Climate Change (Framework Convention) it modifies) here.

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Tags: Health & Safety, EHS, Greenhouse Gas, ghg, climate change, global

Emissions in the Shipping Industry: Who Is Steering the Ship?

Posted by Jane Dunne on Tue, Apr 05, 2016

You might ask how it is possible that there is no direct mention of the shipping industry in the Paris Agreement at COP21. Many people wonder just how much air pollution is created by the shipping industry and who is working to improve this mysterious source of greenhouse gas emissions?

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Tags: EHS, Greenhouse Gas, ghg, Hazcom

Now in Effect: Electronic Logging Device Rules for U.S. Motor Carriers

Posted by STP Editorial Team on Tue, Feb 16, 2016

Trucks.jpgEffective February 16, 2016, the U.S. Federal Motor Carrier Safety Administration (FMCSA) has revised the requirements for logging of commercial motor vehicle (CMV) drivers’ hours of service or “HOS.” A motor carrier operating CMVs must install and require each of its drivers to use an electronic logging device (ELD) to record the driver’s duty status no later than December 18, 2017.

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Tags: Employer Best Practices, Health & Safety, Greenhouse Gas, ghg, Hazcom, Transportation

Paris Agreement Continues Progress On Climate Change

Posted by Jon Elliott on Thu, Feb 11, 2016

On December 11, 2015, representatives of 195 countries agreed to continue to expand global efforts to combat climate change. The new Paris Agreement breaks a longstanding impasse with a clever mixture of binding but unenforceable commitments, and present agreements and ongoing agreements-to-agree. It creates a structure that might, or might not, evolve fast enough to prevent the catastrophic climate changes otherwise predicted by most scientific experts.

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

EPA Proposes To Revise Hazardous Waste Generator Requirements–Part 2

Posted by Jon Elliott on Wed, Jan 20, 2016

Separate Summaries For Generator Categories

In September, EPA published substantial regulatory revisions (which EPA entitles collectively as the Hazardous Waste Generator Improvements Rule) to its regulation of hazardous waste generators under the Resource Conservation and Recovery Act. In Part 1 of this series of blogs (click here), I summarized the principal revisions. In this Part 2 I recast the proposal to compile changes applicable to different categories of generators: 

  • “Conditionally exempt small quantity generators (CESQGs)” – which are being renamed as “very small quantity generator (VSQG)”.

  •  Small quantity generators (SQGs).

  • Large quantity generators (LQGs).

What Requirements Would Apply To VSQGs?

EPA’s proposes to rename Conditionally Exempt Small Quantity Generators (CESQGs) as Very Small Quantity Generators (VSQGs), and to offer these generators additional flexibility. Eligibility for this category continues to be determine based on the following monthly waste generation volumes: Read More

Tags: Health & Safety, OSHA, EHS, EPA, Greenhouse Gas, Hazcom

Hazardous Materials Commentary as Textbook for Professionals

Posted by Jon Elliott on Tue, Nov 17, 2015

For more than 25 years, I’ve taught one of the core required courses in the Hazardous Materials Management Certificate program offered by University of California Santa Cruz Extension (UCSC-Ex). The program is intended to provide professionals with a solid foundation in the principles, regulations, and technologies required to manage hazardous materials and hazardous waste. In my course–the Regulatory Framework for Toxic and Hazardous Materials–I provide overviews of:

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Tags: Audit Standards, Health & Safety, California Legislation, Training, Environmental risks, Environmental, EHS, Greenhouse Gas, ghg, Hazcom, mact

10 Powerful Environmental Non-fiction Reads

Posted by Jane Dunne on Tue, Sep 08, 2015

How often do you read something that not only changes the things that you think about in life, it also changes the things you do?

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

California Sets Tighter Greenhouse Gas Emission Goals

Posted by Jon Elliott on Tue, May 12, 2015

As global attention to climate change and greenhouse gas (GHG) emissions has grown over the past two decades, California has been one of the leading jurisdictions. This began with statewide planning efforts in the 1990s, designed to identify and quantify GHG emissions. After the turn of the millennium it expanded to significant control requirements imposed on targeted source categories—notably a 2002 law (AB 1493) requiring the world’s first GHG emission limits on motor vehicles.

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