Bloodborne Pathogens: Slow Down Before Jumping In

It is human nature that people want to help other people. However, before providing assistance to an injured party, it is important to take a moment to pause and assess any given situation and absorb the details. This is applicable in business and everyday life.  When somebody has fallen or is in pain, one’s first instinct is to immediately jump in and help. However, it is crucial to assess the situation to determine if you are potentially exposing yourself to unwanted risks or hazards. If a first responder doesn’t take a moment to evaluate the situation to make sure the area is safe to enter, then they may injure themselves while attempting to help someone else. You can’t help someone if you are injured along with them! In the rush to provide aid to an associate in need, I have seen people fall themselves, slip, breathe in the same chemical
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Stormwater Permits: Industrial, Construction or Neither?

Uncontrolled stormwater can lead to erosion, flooding, affect the ecological integrity and quality of our water resources, and create instability in our stream channels. Activities that occur at industrial facilities (such as waste handling and equipment cleaning), and construction sites (such as excavating and grading), results in the discharge of pollutants in stormwater runoff. Considering federal, state, and local requirements, it’s understandable if you are confused about what requirements your site is subject to and if it needs a Stormwater Pollution Prevention Plan (SWP3). To perhaps complicate it even further, did you know that there are multiple types of SWP3’s? Your site may need a SWP3 for construction and/or industrial activities. These are a few common questions we hear regarding SWP3’s: Does my site’s Standard Industrial Classification (SIC) code trigger the need for a SWP3? Do I need a construction stormwater discharge permit if my site disturbs half an acre?
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What Can We Expect Following the EPA Repeal of Waters of the U.S. Rule?

On September 12th, the Environmental Protection Agency (EPA) announced the finalized repeal of the 2015 rule that expanded the definition of “waters of the United States” under the Clean Water Act and limited pollution into surface waters of the U.S. through regulations and permitting. The EPA rule is now expected to cover fewer waterways and narrow existing protections, covering only wetlands adjacent to a major body of water, or ones that are connected to a major waterway by surface water. Opponents of this rule have felt this repeal was long overdue and expect that it will reduce federal permitting requirements for development and industry. HISTORY OF THE RULE Since 1972, the Act has regulated pollutant discharge to surface waters by requiring permitting and regulatory conditions for any industrial polluter, as well as discharges from rural and agricultural landowners and real estate developers. The applicability of the Clean Water Act has been controversial,
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Need an SPCC Plan but Barely Exceed the 1,320-Gallon Threshold?

If you find your facility in need of a Spill Prevention, Control, and Countermeasure (SPCC) plan, you may be in luck!  A full-fledged SPCC plan can be a costly expense because of the need for a Professional Engineer to seal the plan, the need for site figures outlining the oil storage areas, piping, transfer areas, and a detailed description of the processes at the facility.  Fortunately, there is an alternative for facilities that can reduce those costs by implementing a Tier I Qualified SPCC and self-certifying the plan if they meet some very specific criteria. “Self-certifying” means that someone within your company would need to be familiar enough with the rules of Title 40 of the Code of Federal Regulations, Chapter 112 (40 CFR §112) to certify that the information within the plan is accurate and meets the requirements.  The Environmental Protection Agency (EPA) developed the Tier I Qualified SPCC
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Regulatory Changes Impacting Healthcare Hazardous Waste Generators

When the Resource Conservation and Recovery Act (RCRA) was initially signed into law in 1976, it largely and rightly focused on the generally easily distinguishable chemical wastes generated by industrial facilities.  Where most waste streams generated by the average industrial facility are predictable, those from hospitals and healthcare facilities are far more varied in type and amount. Additionally, the protocol for identifying, managing and disposing of them properly can be especially complex. To help address the complexity of these regulatory compliance requirements for one particular hospital and healthcare facility waste stream — pharmaceuticals — the United States Environmental Protection Agency adopted on August 21, 2019, the Management Standards for Hazardous Waste Pharmaceuticals.   Below are just a few of the major changes taking effect that are intended to provide greater clarity and consistency in managing hazardous waste pharmaceuticals across states: Waste Determinations Hazardous waste pharmaceuticals are generated by many different employees
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Mid Permit-Cycle Changes for Stormwater Discharge Monitoring Reporting? Not Quite Yet.

Normally there are not many expected changes to permit conditions or requirements when you are in the middle of a permit cycle, but if your site is subject to the Texas Commission on Environmental Quality’s (TCEQs) Multi-Sector General Permit (MSGP) for Industrial Stormwater discharges, then you should have been able to submit your numeric effluent limitations monitoring results via the TCEQ’s Network Discharge Monitoring Report (NetDMR) web-based system. SLOW TRANSITION TO WEB-BASED REPORTING However, since the current permit cycle began in 2016, the TCEQ has been issuing annual “electronic reporting waivers” that allow permittees to submit the annual DMR via the old, faithful pen and paper method.  Under the current MSGP, you are supposed to submit a request for an electronic reporting waiver to be able to use the approved paper version of the Discharge Monitoring Report (DMR) but the NetDMR has not been fully implemented and is currently not
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Rethinking Management Practices for Hazardous Waste in Healthcare

Recent federal Resource Conservation and Recovery Act (RCRA) hazardous waste regulation changes are increasing the regulatory oversight and scrutiny of the healthcare and hospital industry. Accompanying this additional regulatory scrutiny is an increase in the environmental risks this industry is facing. Since every hospital facility or healthcare campus is a hazardous waste generator, knowing the environmental compliance requirements your facility or campus is subject to is important but unfortunately very complicated given the hundreds if not thousands of wastes and waste streams generated.  In addition, your facility is also subject to state and sometimes local government hazardous waste regulations which are often more stringent than the federal RCRA rules. Sorting through and understanding these regulations and the corresponding hazardous waste program compliance requirements is step number one in minimizing the environmental, legal, financial and other risks inherent in being a hazardous waste generator. Given the nature and complexity of these
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The Most Common Hazardous Waste Management Mistakes and How to Avoid Them

Hazardous waste management mistakes are unfortunate, can amount to costly fines, and lead to a tarnished reputation in your community. Fortunately, hazardous waste management mistakes are avoidable. The following errors are a few of the most common violations noted during inspections: 1. Improper Container Labeling Improperly labeling hazardous waste containers can create an unsafe workplace and lead to costly fines. Knowing how to label containers correctly and how to identify waste management mistakes will help your facility stay in compliance and help prevent workplace accidents. The identification and labeling of waste containers notify individuals who may encounter container of its contents and associated hazards. 2. Open Containers Waste containers that are not correctly closed, latched, or sealed are not only a RCRA violation but a workplace safety hazard. Ensuring that employees are trained on the container closure requirements and immediately addressing open containers will keep your facility/site safe and prevent costly
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What is Air Quality? Definitions and Pollution Sources

Earlier this year, a very interesting New Yorker article was published regarding the air pollution commonly found in homes.  The article provided details about an indoor air quality study conducted in a ranch house on the engineering campus of the University of Texas at Austin.  This study prompted discussion amongst several W&M staffers about the different terminology and services related to ‘air quality’ that happens at W&M and how it can be very confusing to differentiate between each type if you aren’t “in the business”! Depending upon the goal of a project, the term ‘air quality’ may or may not be technically correct and it has different meanings depending upon the specifics of the project being requested.  W&M offers many different services to its industrial, oil & gas, education, and real estate clients, and each of these business sectors requires different types of ‘air quality’ support.  Industrial compliance is one
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Cleaning Up Your Act: Key Determinants in Successful Spill Response

What words come to mind when you hear the word spill? Emergency, disaster, mistake, and dangerous may be among the first few, and there isn’t much to think about positively. However, with proper spill prevention preparation, no matter how big or small the event, the spill response can be cost and time-efficient. Nobody wants to believe their company could be the next victim of an environmental spill or release, but the unexpected is always possible. If your company has plans in place to mitigate potential threats, instill safety, and identify appropriate preparation from the beginning, it can reduce the possibility of an unfortunate spill event. WHAT IS THE FIRST STEP IN MITIGATING SPILLS? Make sure they don’t happen. I know, it sounds obvious. It is certainly easier said than done but preventing spills from happening is the best line of defense. One of the best ways to foster prevention strategies
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