With its proposed revisions to California’s hazardous waste management regulations, the California Department of Toxic Substances Control (DTSC) continues to make California’s hazardous waste management program more onerous and complex than the federal Resource Conservation and Recovery Act (RCRA). DTSC proposes substantial changes to hazardous waste personnel training requirements, financial assurance obligations, and hazardous waste permitting decisions.[1] Almost every facility that manages hazardous waste in California will be impacted if DTSC’s proposal is finalized. Public comment on DTSC’s proposed revisions remains open through November 6, 2017.     Continue Reading Proposed Changes to California’s Hazardous Waste Regulations Could Significantly Impact Your Operations

The good news about the Process Safety Management (PSM) standard is that it is a performance-based standard. The bad news about PSM, well, is that it is a performance-based standard. While it provides the operator some flexibility on complying, it can often lead to being second-guessed by an agency. Not only does the operator have to comply with the regulations, the operator must  comply with and document compliance with relevant codes and standards or Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). These include widely adopted codes such as the National Fire Protection Association (NFPA), consensus documents such as the American Society of Mechanical Engineers (ASME), non-consensus documents such as the Chlorine Institute (CI) and in most cases Internal Standards. Continue Reading Making Sense of and Complying with RAGAGEP

The effects of the regulatory reform initiatives of the Trump Administration are beginning to be felt at the Occupational Safety and Health Administration (OSHA) with the formal action by OSHA to finalize withdrawal of the “Volks Rule” regulation. On May 3, 2017, in response to a CRA resolution of disapproval, OSHA published a final rule removing amendments to OSHA’s recordkeeping regulations from the Code of Federal Regulations.

Continue Reading I’ve Been CRA’d! What Happens Now? OSHA Formally Repeals Volks Rule