- 26
- Jun
- 2017
Direct Cost: Notice of Violation (NOV) letter: $200 Explanation to the Management on reasons for NOV: 10 hour Response to Management on other EHS compliance status: 40 hour Management time to make decisions: 1 hour Procurement time to issue check: 1 hour New checks & balance instituted by Management to avoid NOV: 40 hour Total […]
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If your facility uses HFC-134a, a common HVAC refrigerant, it is subject to many provisions of the new regulations. EPA’s original refrigerant rule on this subject was published in 1993 and is codified at 40 CFR Part 82, Subpart F. The revised final rule, 400+ pages, is scheduled to be published in the Federal Register […]
Continue Reading...- 29
- May
- 2017
When it comes to hiring an environmental auditor for a Merger & Acquisition (M&A) project, it is important to hire with end results in mind. The purpose of the audit is to look for critical items that can impact the M&A or cost of achieving compliance once the M&A is complete. Knowing what the senior […]
Continue Reading...- 17
- Mar
- 2017
On July 30, 2013, EPA published the final rule on the proper disposal of solvent-contaminated shop rags and wipes. These final rules are effective January 31, 2014. We have noticed that many facilities are treating their solvent contaminated wipes as hazardous waste; resulting in unnecessary operating expenses. Wipes contaminated with spent solvents, or if ignitable, […]
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Any facility that comes into possession of any Chemical of Interest (COI) listed on the CFATS Appendix A above the Screening Threshold Quantity (STQ) must complete and submit a Chemical Security Assessment Tool (CSAT) called “Top-Screen.” All facilities should review COI Appendix A list for applicability? After reviewing the Top-Screen, Department of Homeland Security (DHS) […]
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