Toxic Substances Control Act Update
There was much discussion at a recent RadTech EHS Committee meeting focusing on the revisions to the Toxic Substances Control Act (TSCA) as amended by the Lautenberg Chemical Safety for the 21st Century Act (LCSA). Although the rule is not yet final, responses from the US Environmental Protection Agency (US EPA) to new pre-manufacturing notices (PMNs) are being delayed or consent orders are being issued. RadTech held a webinar on this topic, archived at www.esf.edu.
More recently, US EPA has published a list of the first 10 chemicals it will evaluate for potential risks to human health and the environment under TSCA reform. Additional chemicals will be designated for evaluation, and all of the remaining Work Plan chemicals will be reviewed for their potential hazard and exposure. For each risk evaluation that US EPA completes, TSCA requires that the agency begin another. By the end of 2019, US EPA must have at least 20 chemical risk valuations ongoing at any given time. For more information, go to tinyurl.com/h5hggez.
On December 14, 2016, US EPA held a public meeting to update TSCA stakeholders and the public on changes to the TSCA. Presentations have been archived on US EPA’s website as follows:
- Reviewing New Chemicals under the Toxic Substances Control Act
- Reviewing New Chemicals under the Toxic Substances Control Act: Science Issues
- How to Make the Review Process More Efficient
Listen to the recording and view slides presented at the public meeting at http://mp163422.cdn.mediaplatform.com/163422/wc/mp/4000/15208/30195/69304/Lobby/default.htm.
Hazardous Waste Generator Improvements Rule Finalized
US EPA has finalized revisions to the Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulatory program. Several controversial revisions include the following:
- reorganizing the hazardous waste generator regulations to make them more user-friendly and thus improve their usability by the regulated community;
- providing a better understanding of how the RCRA hazardous waste generator regulatory program works;
- addressing gaps in the existing regulations to strengthen environmental protection to provide greater flexibility for hazardous waste generators to manage their hazardous waste in a cost-effective and protective manner; and
- making technical corrections and conforming changes to address inadvertent errors and remove obsolete references to programs that no longer exist.
More information on RCRA can be found at www.epa.gov.
OSHA Issues Proposed Changes to Lockout/Tagout Rule
The Occupational Safety and Health Administration (OSHA) has proposed a controversial revision to the lockout/tagout rule under the Standards Improvement Project-Phase IV (SIP IV), a collection of 18 OSHA rule revisions changed to “remove or revise outdated, duplicative, unnecessary and inconsistent requirements” in OSHA’s standards. The current lockout/tagout standard applies to servicing and maintenance operations “in which the unexpected energization or startup of the machine or equipment, or release of stored energy could harm employees.” OSHA intends to revise the lockout/tagout rule by removing the word “unexpected,” such that the standard would apply to any energization, not just unexpected ones. More information about the changes to the lockout/tagout program can be found at www.osha.gov.
Sustainability Gains Traction in the Printing Industry
Along with the major printing and ink associations, RadTech supports the Sustainable Green Printing Partnership (SGP) as an SGP Resource Partner. As such, RadTech encourages its members to learn more and get involved with SGP in its effort to promote sustainable printing. Recent SGP activities include certification of the printer of the licensed apparel for Major League Baseball, the National Football League, the National Basketball Association, Harley-Davidson and other properties. SGP introduced a new multi-location certification program and an updated guidance document that reflects the changes in the 2016 SGP Criteria. Read about GFX Internationals journey through the SGP process and how the certification has made the company more competitive at . Learn more about SGP and how your company might get involved and help support the sustainable printing movement at www.sgppartnership.org.
Doreen M. Monteleone, Ph.D.
Director of Sustainability & EHS Initiatives
RadTech International North America
News from the West Coast
SCAQMD Staff Revisits BACT
The South Coast Air Quality Management District (SCAQMD) recently proposed changes to its Best Available Control Technology (BACT) guidelines. BACT applies to any new or modified source. The guidelines had not been updated for more than 10 years. Due to RadTech’s opposition of the proposal brought forth in December 2016, the SCAQMD board unanimously supported resolution language proposed by RadTech, which read as follows:
“BE IT FURTHER RESOLVED that the Board directs AQMD staff to work with industry and other stakeholders on assessing Ultraviolet/Electron Beam (UV/EB) technology as an alternative to meet Best Available Control Technology. This analysis should include BACT determinations by other air districts. The staff analysis shall be presented to the board by June 2017.”
The language included a deadline of June 2017 to prevent another 10-year delay. RadTech (which holds a seat on the agency’s Local Government Small Business Committee) requested a status update. Staff gave a presentation in January and stated they are working with other air districts as well as reviewing permits. They also have visited district facilities that are currently using UV systems and reported that the operators had positive comments about the technology. Staff reported that RadTech’s application for membership on the BACT advisory committee is under consideration. Staff has requested cost information from RadTech to perform a cost-effective analysis. RadTech members that can provide cost data are urged to contact Rita Loof at email@example.com. Staff will continue with site visits and will report to the Stationary Source Committee by June of this year.
SCAQMD Seeks to Expand Authority
The South Coast Air Quality Management District is sponsoring legislation that would broaden its authority to shut down operations the agency believes present “an imminent and substantial endangerment to the public health or welfare, or the environment…” The proposal would give the air pollution control officer the power to issue an accusation against a company and issue an “order of abatement.” Staff is basing its approach on recent cases in the city of Paramount, where elevated levels of hexavalent chromium were found, purportedly due to aerospace operations.
Staff also presented a proposal that fines for violations be increased, arguing that the current fine structure does not present a sufficient deterrent to violators. SCAQMD board members questioned staff’s contentions and requested additional evidence that violators were performing a cost/benefit analysis based on the amount of the fines. Although staff has stated that a fine increase would only apply to “serious continuous violators,” no formal language has been presented for public review to support the argument.
Director of Regional Environmental Affairs
RadTech International North America