Regulatory Overview

The overall objective for this module is that participants will recognize key

environmental rules and regulations, worker responsibilities, and related

requirements important to HHW/CESQG fixed collection facility operations

Expectations List the primary three classes of

regulatory agencies List the four types of regulations List two rights you have as an

employee List two responsibilities you have as an

employee Explain the Universal Waste Rule and

its applicability

Regulatory Agencies Regulatory Intents

– Uniform Fire Code Protects occupants, fire fighters, and

property

– OSHA Safeguards the workplace and protects

employees from hazards

– State/US EPA Protects human health and the environment

Regulatory Agencies Federal

– EPA, DOT and OSHA State

– Environmental– Industrial Safety

Local– Health District– Fire Code

Regulatory Agencies Environmental Protection

– Environmental Protection Agency (EPA)

Protection of the environment (40 CFR) Established to create and assure

compliance with federal environmental laws

Regulatory Agencies Environmental Protection

– Department of Transportation (DOT) Protection during transportation of

hazardous materials (49 CFR) Establishes and enforces regulations to

ensure safe transport of hazardous materials and hazardous waste

Regulatory Agencies DOT Requirements

– Hazard classification– Proper shipping names– Shipping papers/manifests– Markings– Labels– Placards– Emergency response information– Training– Packaging requirements– Loading, moving, and unloading of containers

Regulatory Agencies Worker Protection

– Occupational Safety and Health Administration (OSHA)

First uniform federal safety and health regulation

Purpose is to enforce the worker protection standards outlined in 29 CFR for industry, construction, agriculture and shipyards

Established by the Occupational Safety and Health Act of 1970

Federal and State

Environmental Laws and

Regulations

Resource Conservation Recovery Act of 1976

(RCRA) “Cradle-to-grave” management of

hazardous wastes Covers hazardous waste treatment,

storage, and disposal (TSD) sites Permits

– TSD facilities - Subtitle C– Solid wastes - Subtitle D

What is Hazardous Waste?

HazardousWaste

What is a Hazardous Waste?

Listed Characteristic Radioactive Mixed Nonregulated Unknown

Listed Waste Generic sources Discarded chemical products Waste from specific or

nonspecific sources– F- List: non-specific source– K- List: specific source

Characteristic Waste Ignitability Corrosivity Reactivity Toxicity

Ignitability Liquid with a flashpoint greater

than 60 degrees Celsius (140 degrees Fahrenheit) Compressed ignitable gas

Oxidizer Spontaneous combustion

Corrosivity

Liquid with a pH less than 2 or more than 12.5

Corrodes a steel plate at a rate of a 1/4” per year at 150 degrees Fahrenheit

Reactivity Unstable and readily undergoes violent

change Reacts violently with water Contains cyanide or sulfide and generates

toxic gas Capable of detonation

Toxicity Fails the Toxicity Characteristic

Leaching Procedure (TCLP) Termed hazardous if sample or

leachate contains a regulated level of any chemical

Other Waste Types Radioactive Mixed Nonregulated Unknown

The Hazardous and Solid Waste Amendment of 1984

(HSWA)

Added waste minimization requirements and two other major subtitles of RCRA to govern:– Solid waste disposal– Underground storage tanks

Comprehensive Environmental Response,

Compensation and Liability Act of 1980 (CERCLA)

“Superfund” Established the National

Contingency Plan and the National Priorities List

Established reportable quantities (RQs)

Comprehensive Environmental Response,

Compensation and Liability Act of 1980 (CERCLA)

Regulates and enforces the clean-up of abandoned and hazardous waste sites

Report of chemical spills to National Response Center

Superfund Amendments and Reauthorization Act of

1986 (SARA)

Extended and amended CERCLA Lists “Extremely Hazardous”

chemicals that must be reported to authorities when spilled or released

Superfund Amendments and Reauthorization Act of

1986 (SARA)

Requires planning for emergencies on site (Tier 1, 2)

Addresses need to protect employees from hazardous waste

Title I-V

Other Environmental Laws

Toxic Substances Control Act of 1976 (TSCA)– Regulates the manufacture, use and

disposal of polychlorinated biphenyl’s (PCBs)

– Establishes requirements for the manufacturing of new chemicals

– Removal and disposal of asbestos

Other Environmental Laws

Clean Air Act of 1970, 1977, 1990 (CAA)– Regulates atmospheric pollutants and

governs discharges

Clean Water Act of 1972, 1977 (CWA)– Covers surface water pollutants and

governs discharges

Other Environmental Laws

Safe Drinking Water Act of 1974 (SDWA)– Regulates drinking water systems– Establishes maximum contaminant

levels (MCLs) – Regulates underground injection

wells

Federal Insecticide, Fungicide and

Rodenticide Act (FIFRA) Concerns:

– Pesticide manufacture requirements– Pesticide labeling requirements – Pesticide use requirements

Worker Protection Standards (PL 91-596)

“General Duty Clause” – Prescribes minimum requirements for

the prevention and control of conditions hazardous to workers’ health

– It includes work environments where chemical or other hazards exist and mandates that:

Worker Protection Standards(PL 91-596) (Cont’d)

“Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death and serious physical harm to his employees; shall comply with occupational safety and health standards promulgated under this act.”

“Each employee shall comply with occupational safety and health standards and all rules regulations and orders issued pursuant to this act which are applicable to his own actions and conduct.”

Standards Hazard Communication

Standard Hazardous Waste Operations

Standard

Hazard Communication

The Hazard Communication Standard , 29 CFR 1910.1200, was

established by OSHA to protect you and your co-worker from the chemical hazards that may be encountered in the workplace

Hazard Communication in the

Work Place

Written hazard communication program Hazard evaluation Training for workers so they are informed of

hazards and how to protect themselves against them

Product labels include a hazard warning, product name, manufactures and address

Material Safety Data Sheets (MSDS) are required from all manufacturers and importers

Hazardous Waste Site Operations

Assure that companies doing hazardous waste work have provisions in place to identify, evaluate and control the related hazards

Intent is to ensure worker protection during these operations

Covers cleanup, hazardous waste, emergency response operations and TSDF operations

Worker Rights and Responsibilities

Complying with established standards, procedures, and practices

His or her own safety and the safety of assigned company equipment

Promptly reporting unsafe conditions, practices, work-related accidents, and injuries to the supervisor

Protecting employer and self from civil and criminal liability under environmental law; this can be done by creating an atmosphere of compliance

Worker Rights and Responsibilities

Follow the rules, regulations, and employer’s program

Attend training Do things right the first time Speak up if something is not being

done right Ask questions whenever in doubt or

unsure about a situation in the workplace

Uniform Codes Uniform Building Codes (UBC) Uniform Fire Code (UFC) Uniform Mechanical Code (UMC) National Electric Code (NEC)

Universal Waste Managed under the US EPA’s

Universal Waste Rule (UWR) found in 40 CFR 273 adopted in May 1995

Generated by household or commercial generators– Examples

batteries mercury-containing thermostats pesticides