Environmental Health and Safety Blog | EHSWire

The DOT has listed its requirements for Clean Natural Gas fuel containers as regulated by Standard 304. The standard is aimed at reducing death and injury from fires that may result from leakage during and after crashes and applies to CNG used as a fuel on any motor vehicle.

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Topics: DOT, Clean Natural Gas fuel containers, Standard 304, CNG, publication TP-304-03

In an effort to educate young workers, the Department of Labor's Occupational Safety and Health Administration (OSHA) recently held a contest to build a mobile app. Four winners were awarded prizes between $3,000 and $15,000. 

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Topics: Emilcott, Occupational Safety and Health Administration (OSH, DOT, Worker Safety and Health App Challenge, OHS Phone Applications

A reminder to commercial truck drivers and the companies who hire them: The U.S. Department of Transportation's Federal Motor Carrier Safety Administration's new safety requirements go into effect on July 1, 2013.



The maximum hours of service (HOS) will be reduced, meaning the maximum number of hours that a driver may operate their equipment goes from 82 hours within one week to 70 hours within one week.  The new HOS Rule also prohibits drivers from driving more than eight hours at a time without taking a break for at least thirty minutes.  Prior rules had no provisions regarding limitations on minimum “34-hour restarts,” but the new rules state that such a restart must “include two periods between 1 a.m.-5 a.m. home terminal time, and may only be used once a week.”  The new HOS rules also place limitations on time resting in a sleeper berth, what constitutes a real “rest,” and how hours are to be calculated by drivers and companies.

Proponents of the new safety requirements for commercial truck drivers state that reducing the hours a driver is required or even able to work will reduce accidents.  The DOT's stated goal is “to limit the ability of drivers to work the maximum number of hours currently allowed, or close to the maximum, on a continuing basis to reduce the possibility of driver fatigue."

Critics of the new rules state that they do not go far enough towards meaningful reform of current HOS, and will ultimately “have a negative impact on manufacturers' supply chains, distribution operations and productivity,” says Jay Timmons, National Association of Manufacturers President and CEO.

Penalties to companies who violate the new HOS rule are stiff: up to $11,000 per offense, plus drivers may face fines up to $2,750 per offense.

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Topics: Emilcott, DOT, General Industry H&S, HOS Rule, DOT Revisions, safety requirements for commercial truck drivers

Carrie Bettinger, CHMM, CSP

As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our “General Industry” clients in an effort to lift their game with dealing with hazardous waste.  There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan!  The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.

The Rules

The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage  and disposal of Hazardous Waste, which “ General Industry” businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; …well, just about everyone) needs to know!

OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA's general industry standards, directives, and standard interpretations.

Give me an R! Give me a C ! Give me an R! Give me an A! What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t have a side business of burying industrial waste on the family farm.   RCRA is a complex law with lots of parts and many industries are affected by its components.  In addition to being complex, the text of the Act with all of its parts and sections is hard to follow.  My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262) . RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training.

But the EPA’s RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site.  The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H.   The International Air  Transport Association (IATA) has rules for the air transport of hazardous materials ( http://www.iata.org/) including training requirements.

To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s hazardous materials in DOT and IATA eyes.  For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.

The Required Training

So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have -- per both EPA and DOT/IATA.

All employees at sites that generate hazardous waste need to be trained in how to:

• Properly identify what qualifies as regulated “Hazardous Waste” per federal (EPA) or your state requirements.


• Know where to properly dispose of any hazardous waste you may generate (I will give you a hint:   It’s NOT down the sink drain!).


• Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.

Employees who are designated as responsible for the management and control of this hazardous waste need additional training. And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to

• Properly label containers


• Implement accumulation area requirements and time-on-site limits


• Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems


• Complete Hazardous Waste shipping manifests


• Ensure proper shipping methods and a qualified transporter are used


• Develop site-specific procedures


• Know and implement emergency procedures and site contingency plans

Refresher Training

A common point of confusion is when refresher training is needed for employees.  The DOT and EPA have two separate requirements:

• The EPA requires annual refresher training for their regulations.


• The DOT requires refresher training every 3 years for their regulations.

And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations .

The Bottom Line

We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans – everything that DOT/IATA and RCRA training develops for your company – are vital in the cleanup of the environment and protection of employee and public health and safety.

For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott.  As part of  The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA:

• 4-hour Introduction to RCRA Compliance (40 CFR 260-273)


• 4-hour Introduction to DOT/IATA Compliance (49 CFR 172.704 & DGR 1.5.0)

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Topics: Emilcott, OSHA, DOT, General EHS, EPA, Emergency Response, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, Lab Safety & Electrical, regulation, General Industry, emergency response training, Occupational Training, IATA, Resource Conservation and Recovery Act, Lab Safety, hazwaste, transportation, hazmat, generation, RCRA

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

Megan Grennille

Your next visit to a truck stop may be more pleasant in a few years.  New standards were announced on October 25th from the DOT (Department of Transportation) and EPA (Environmental Protection Agency) to reduce greenhouse gas emissions in heavy-duty trucks and buses.  The standards, which are set to be phased in on new vehicles in 2014, will include requirements to improve fuel efficiency which benefits businesses, the shipping industry, and cities and towns.

The large vehicles being targeted by the proposed standards are divided into three categories: combination tractors, heavy duty pickups and vans, and vocational vehicles.  Combination tractors will have a 20% decrease in CO ₂ output as well as fuel consumption.  Heavy-duty pickup trucks and vans will have separate gas and diesel standards; by 2018 CO ₂ emissions and fuel consumption will decrease by 10% in gas vehicles and 15% for diesel.  Vocational vehicles, such as buses and utility trucks, could see a 10% reduction in fuel consumption and CO ₂ emissions by 2018.  

The new regulations bring environmental and economic benefits.  People who live near bus depots, cities, and highways should be happy.  And, on those hot smoggy days near the end of this decade, the air will be a little cleaner.

What do you think of the regulations? Will they impact your business?

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Topics: DOT, indoor air quality, General EHS, EPA, Hazardous Materials, worker safety, Occupational Health, Air Sampling, Exposure, chemicals, environmental air monitoring, Working Green, greenhouse gas emissions

Dian Cucchisi, PhD, CHMM

Environmental Health and Safety Professionals are often faced with questions that do not seem to have black and white answers, but, in reality, regulatory requirements are not that gray.  A common question: When do the requirements for 29 CFR 1910.120 and 29 CFR 1926.65 (OSHA’s Hazardous Waste Operations and Emergency Response regulations) apply?  The challenge for EHS professionals is to communicate to workers the distinction between what are considered environmental health risks and the risks to human health, and to clarify the difference of the word “hazardous” as used by various environmental protection agencies and Occupational Safety and Health Administration (OSHA).

The Environmental Protection Agency (EPA) and the state environmental protection agencies have standards for soil and groundwater “cleanliness” for residential and non-residential properties.  Soil or groundwater in exceedence of those standards needs to be remediated (usually by removal), but to add to the confusion, sometimes when soil and/or groundwater is removed from the site and transported to a disposal facility it may not fall into the EPA’s definition for hazardous waste.  So here lies the misunderstanding; if it is not classified as “hazardous waste” by the EPA, people often make the determination that it is not considered hazardous to workers and, therefore, it is not necessary to take measures to protect the workers’ health and safety.

When it comes to worker safety and the risks to human health, we must look at the requirements provided by OSHA.   OSHA is focused on exposure potential and the resulting hazard assessment evaluation to workers from the chemicals that may be encountered when working in areas with potentially contaminated soil and/or groundwater.  If the chemicals present are regulated by OSHA with a Permissible Exposure Limit (exposure based on an 8-hour average), the employer is required to conduct exposure assessments and air monitoring to determine potential risks to the workers onsite.  It also requires that workers are protected from these potential exposures through either engineering controls or personal protective equipments (such as tyvek, gloves and respirators).

 There is also a need to protect the workers and meet all the other applicable OSHA standards that mitigate health and safety risks to workers on this site.   Such required protection would include: 

• developing a site-specific health and safety plan,


• training workers in chemical hazards and controls,


• conducting environmental monitoring to determine exposure,


• instituting controls (PPE and Engineering) to protect from exposure potential,


• clean up (decontamination).and a number of other procedures.  

It is surprising and frustrating that this issue is still debated, but if it is, doesn’t it make sense to use the guidelines in these standards to clarify? We are talking about human health and the regulations are clear about the requirements for worker training and personal protection when dealing with chemical contamination.  You can use the environmental classifications to determine how to treat the situation, but you must look to OSHA to protect the workers as they are doing it.

Have you ever had workplace confusion regarding environmental risk and hazardous to human health? If so, I'd like to hear about your situation and how you resolved it.

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Topics: OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety

Diego Tolosa, CHST

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Topics: DOT, Personal Protective Equipment, Construction H&S, Emergency Response, worker safety, Occupational Safety

Topics: Emilcott, OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Emergency Response, H&S Training, Hazardous Waste Management, HazCom, worker safety, Occupational Health, Occupational Safety, MSDS, Hazard Communication Standard, Occupational Training, Safety Training in Spanish

Dian Cucchisi, PhD, CHMM

1. Is the material hazardous? This can be determined by looking at the Material Safety Data Sheet (MSDS) or the label.

2. Does the Department of Transportation consider the material a hazardous material for transportation? Check the Hazardous Material Table (HMT) found in 49 CFR 172.101.

3. Is the material listed by name in the HMT? If so, that would be the proper shipping name.

4. Is the material not listed by name in the HMT but is a hazardous material due to flammability, corrosivity, etc.? If so, a generic proper shipping name would be used. The generic proper shipping names are also located in the HMT.

5. Do you have personnel trained according to 49 CFR 172.704?

6. Do you have the proper label(s) as required by 49 CFR 172.400 - .450?

7. Is the packaging approved for the shipment of hazardous materials according to 49 CFR 173?

8. Have you completed the Shipper's Declaration of Dangerous Goods?

9. Is the listed emergency response telephone number answered by a "live person?"

10. Failure to ship hazardous materials properly has resulted in monetary fines in the hundreds of thousands of dollars.

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Topics: OSHA, DOT, health and safety, General Industry H&S, Emergency Response, H&S Training, Hazardous Materials, Occupational Health, Occupational Safety, emergency response training, MSDS, Respiratory, Occupational Training, Safety Training in Spanish