The Environmental Protection Agency (EPA) will begin implementation and operation of the e-Manifest system on June 30, 2018. The e-Manifest requirements will be effective in all states on this date affecting to those required to use a hazardous waste manifest–generators; transporters; owners and operators of treatment, storage and disposal facilities (TSDF); and handlers of state-only…
Tag: ehs compliance

Preparing for an Unannounced Inspection
While at a client site yesterday, I received a call that the Fire Department wanted to visit the facility. About an hour later a representative from the local fire department was on-site. Believe it or not, he wanted to see the chemicals reported on the Tier II report for the facility submitted earlier in the…
Polychlorinated Biphenyls (PBCs) Regulatory Changes Ahead
Polychlorinated biphenyls (PCBs) are a class of man-made organic materials that are desirable because of the following characteristics: non-flammable, chemically stable, have a high boiling point and electrical insulation properties. Unfortunately the same characteristics cause them to persist and bioaccumulate in the environment. In addition, PCBs
Not all bulbs are created equally
In the last post I summarized requirements for universal waste. One waste stream that falls into this category are bulbs (lamps). Did you know that not all lamps need to be managed as universal waste that, in fact, some are not even classified as hazardous waste or universal waste?
Universal Waste Requirements
Universal waste is a special category of hazardous waste that includes batteries, pesticides, mercury-containing equipment and lamps. For the most part, these wastes are self-explanatory but often confusion arises from mercury-containing equipment which includes a device or part of a device (including thermostats, but excluding batteries and lamps) that contains elemental mercury integral to its function. Some…
Hazmat Transportation Training, Do You Need it?
Yesterday I shared the link to the Department of Transportation’s (DOT) Pipeline and Hazardous Material Safety Association’s (PHMSA) free training modules on my Facebook page and Twitter account. I wanted to use this post to discuss the training requirements for the Department of Transportation Hazardous Materials. In Are you Shipping Batteries? I mentioned that for many companies,…
Are You Shipping Batteries?
Based on my experience, one of the largest areas of non-compliance is the transportation of hazardous materials (hazmat). Many times logistics or warehouse personnel are unaware that hazardous materials are required to be packaged, unloaded, loaded, documented and shipped in a manner that is compliant with the Department of Transportation (DOT), the International Air Transportation…
Six Competence Boosting Strategies
The last thing most companies should want is to waste hundreds, possibly thousands, of hours and dollars; yet when we consider the ineffectiveness of most training that is exactly what occurs. The question we must consider is: “are the employees competent?” Are they able to perform the job or task in a way that meets…
Five Free EHS Resources for Small Businesses
Environmental, Health and Safety (EHS) is a broad field that is constantly changing. It is often beneficial to have a few guides or resources that can be referenced to assist with program development and implementation. Small businesses often do not have a dedicated EHS resource but the following free resources can be of great value…
The Devil is in the Details…Hazardous Waste Accumulation Areas
I have discussed identifying hazardous waste in What is Hazardous Waste? and determining hazardous waste generator status in The Devil is in the Details…What Type of Generator are You? Today we will tackle the issue accumulation time–the amount of time a hazardous waste generator is allowed to store hazardous waste on site. These requirements are…