Get a Leap on 2020’s Environmental, Health, and Safety Issues
February 3rd, 2020
Who couldn’t use an additional day every now and then to tackle that project, that pile of laundry or that book you have been meaning to read. Every four years we get that extra day through a Leap Year and 2020 just happens to be a Leap Year.
In the Environmental, Health and Safety (EHS) compliance world we have repetitive tasks and reports that occur every year like posting your OSHA 300 log, filing your Tier II report, and conducting Spill Prevention, Control and Countermeasure (SPCC) Plan training. There are a few tasks that are due every two years like biennial hazardous waste reports for Large Quantity Generators (LQGs) of hazardous waste and recurring International Air Transit Association (IATA) training for shipping dangerous goods by air. Every three years marks the requirement for recurring Department of Transportation (DOT) Hazardous Materials training for those that engage in the shipping of hazardous materials and Risk Management Program (RMP) audits and Process Safety Management (PSM) audits. And just like Leap Year coming along every four years, there are at least two EHS related tasks that follow a similar cycle of every four years: the new requirement for Small Quantity Generators (SQG) of hazardous waste to re-notify of their status and the release of the Emergency Response Guidebook.
Under the hazardous waste generator improvement rule finalized in 2016, SQGs must re-notify every four years of their SQG status. This re-notification must occur by September 1 of the re-notification year. The first re-notification year is 2021 (and then 2025, 2029, and so on thereafter) and one would re-notify using the EPA Form 8700-12. Check with you state for any state variations of this federal requirement. To learn more about the hazardous waste generator improvement rule, check out the recording of a webinar we presented previously on the subject: https://hrpassociates.com/training/outline-rcra-updates-overview/
DOT Pipeline and Hazardous Materials Safety Administration releases its Emergency Response Guidebook every four years. This book is often referenced in DOT Hazardous Materials training. Your hazardous materials registration fees support the compilation and release of this guidebook. 2020 will bring the newest addition of this guidebook to reference for emergency situations related to hazardous material shipments. To learn more about shipping of hazardous materials and the use of this emergency response guidebook, check out our online DOT training at https://hrpassociates.com/training/outline-dot-hazardous-materials/ or one of the live training events scheduled in your area https://hrpassociates.com/training/training-courses/
Jackie Baxley, PE, EHS Practice Leader at HRP Associates, Inc.