Environmental Health and Safety Consulting

Hazardous Materials and Toxic Substances

Hazardous materials are regulated under a number of federal, state and local environmental health and safety regulatory programs. The Environmental Protection Agency (EPA) has extensive authority under several federal environmental statutory mandates to reduce the risk of exposure to humans and the environment. The Occupational Safety and Health Administration (OSHA) has authority over the Hazard Communication Program which requires the safe handling of hazardous substances. The Department of Transportation (DOT) regulated any transport of hazardous materials and the packaging of hazardous materials for transport.

Our organization specializes in ensuring environmental compliance and can help outline the required environmental programs, permits, and training in an easy to understand way. Clients are then in control and have the opportunity to address any issues that they need to before a lawsuit or serious situation occurs. An environmental disaster or regulatory inspection can be devastating, but our organization can help you to prepare. 

Environmental health and safety consulting is designed to bring new light to the ever-changing requirements and regulations that often confound business owners. A lack of awareness is common and can cause many problems throughout a business. 


Hazardous Waste Management

Business and household activities generate a considerable amount of hazardous waste each year. Any generator of any waste must determine whether their waste meets the definition of hazardous waste by their knowledge of the chemicals and processes involved or laboratory testing of representative samples. 

The process of hazardous waste determination is very complex and many state laws, like California, further complicate this process. In general, wastes become hazardous wastes if they are either listed or meets one of the following characteristics: 

The business must label the container with information about the waste, dispose of the waste within the right time frames based upon the overall amount of waste generated at the facility, provide employees with varying degrees of training, and maintain accurate records for at least three years. 

This process is extremely burdensome on businesses because of the complexity and increased disposal costs. Moreover, the maximum penalties for non-compliance with RCRA are $93,750 per day per violation. 

Federal and state requirements are never clear when it comes to defining hazardous wastes. This can lead to the mismanagement of such waste, which can result in a number of issues. Ultimately, it is the responsibility of the generator to determine whether the waste is hazardous. 

Our organization can expertly advise businesses on the most cost-effective way to manage hazardous waste, avoiding mismanagement. We work with our clients and their Certified Unified Program Agency (CUPA) to ensure waste is managed efficiently throughout its lifecycle. 

Tiered Permitting

If a facility is to treat hazardous waste on-site, something called a Tiered Permit is required. A facility may be treating waste using any technique or process which changes the waste in some way, whether that is physical, chemical, or character composition. This might, for example, remove or reduce the harmful properties for the purpose of PH adjustment, reduction of metals, or something else, including: 

    • Oil/water separation
    • Precipitation
    • Evaporation
    • Reduction in volume

Assembly Bill 1772 brought in a five-tiered program for authorizing the treatment/storage at a number of businesses that require state authorization to treat/store hazardous waste, but don’t need a hazardous waste facility permit.

  1. The RCRA equivalent “Full Permit” 
  2. The “Standardized Permit” 
  3. The “Permit by Rule”
  4. The “Conditional Authorization” tier 
  5. The “Conditional Exemption” tier

We can help you to understand the above tiers in more detail so that it is clear to you how you are able to treat and store hazardous waste right from the get-go.

Risk Management Plans 

The 1990 amendments to the CAA established a program to prevent the accidental release of highly hazardous chemicals. Facilities that process, handle or store these chemicals are required to conduct off-site hazard assessments and prepare risk management plans (RMP). 

The EPA has authority within the United States to enforce CAA permit conditions. Citizen suits can also be filed to force the EPA, states and/or individual sources to enforce clean air laws. Violation of the CAA can result in a maximum civil penalty of $200,000. Any organization that knowingly commits a violation of the CAA is subject to criminal fines of up $1 million, and potential imprisonment of maximum 15 years. 

Risk management plans are required for companies and facilities that may use large quantities of materials that are extremely hazardous. They are a federal requirement for facilities that exceed the threshold of certain chemicals, based on a federal RMP list. 

Our organization can take on the studies required, as well as prepare the full documentation and programs you need to comply with the State of California, the County, and Cities RMP requirements.

Injury and illness prevention plan

All companies must have a written injury and illness prevention plan, required by CalOSHA. The plan should outline safety rules and guidelines, as well as procedures for reporting and investigating injuries, training programs, and accident reporting. 

We are able to take on the OSHA hazard analysis for you and develop a full health and safety program that not only meets the requirements but suits your business. We can also include conducting safety meetings and training courses. Having a plan like this in place will improve the safety of your workplace and reduce costs.

Our organization will use the elements above and take all requirements into consideration to ensure that a proper plan is put in place.

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