GHS Compliance Dates

The first of the Globally Harmonized System (GHS) compliance dates are fast approaching.  These compliance dates are listed below: Effective Completion Date Requirement(s) Who December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers June 1, 2015December 1, 2015   Compliance with all modified provisions of this final rule, except:  The Distributor shall not ship containers labeled by the chemical … [Read more...]

Auto Body Refinishing Operations: What EPA’s 6H Means To You

If your organization is involved in auto body refinishing, you may have received a letter recently from the Indiana Department of Environmental Management (IDEM), outlining the requirements set forth by 40 CFR 63 Subpart HHHHHH (or 6H), the “National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.” To further our commitment to keeping our clients informed and in compliance, we have created an overview of this … [Read more...]

Going Green

Many companies think about going green. Some even talk about going green. But still only a small percentage of companies today are taking that leap. Why? In most cases, the trepidation stems from a fear of the process. What is it going to cost? Will it bring me unwanted attention from regulatory agencies? Will it increase my liability?D&W Incorporated, a company that supplies glass and mirrors to the recreational vehicles industry, had the same questions. The story of their going green is … [Read more...]

Waste Profiling

Do you profile your waste? Believe it or not, this is a high-priority task for many manufacturing companies. And, unfortunately, it is one environmental issue that commonly slips through the cracks. Profiling means to determine the characteristics of the waste, and determine whether it is hazardous waste or non-hazardous waste. Profiling can be done using the MSDS to inform the landfill what is in the waste or by using a laboratory to analyze the waste. Many industrial waste streams are … [Read more...]

Reasonable Estimates for Woodworking PTE

The Indiana Department of Environmental Management (IDEM) Air Permitting section, in my opinion, has made some great strides. Currently, they have been hiring excellent people at all levels of the organization. This is resulted in more reasonable and technically correct permitting determinations. We recently had some success working with an IDEM permit writer. The process being controlled was a wood milling operation. The control device was a cyclone as the first stage, and a baghouse as the … [Read more...]

Integrated Air Toxics

EPA is close to promulgating the first national emission standards for hazardous air pollutants (NESHAP) for area sources engaged in paint stripping, surface coating of motor vehicles and mobile equipment, and miscellaneous surface coating operations. We predict this will go into the Federal Register early next year. This NESHAP potentially could apply to everyone in the above industry categories regardless of whether they are a major source of Hazardous Air Pollutants (HAPs) or not. (A major … [Read more...]

Extension on FESOP and MSOP Permit Terms

The Indiana Department of Environmental Management (IDEM) is finalizing a rulemaking which will extend the permit term for Federally Enforceable State Operating Permit (FESOP) renewals and Minor Source Operating Permit (MSOP) renewals from 5 years to 10 years. The permit term for initial MSOPs and FESOPs will remain the same. You can choose to implement this change only if you are on your second or subsequent renewal. This will be processed by the IDEM as either an Administrative Amendment … [Read more...]

Notes on NFPA 33

Recently a client wanted to know why he had to ventilate his paint booth outdoors instead of back into the building. Off the top of my head I told him that it was a safety issue more than an environmental issue, and that the concentration of flammable vapors should not exceed 25% of the Lower Flammability Limit (LFL). This answer was only partially correct. Recently I viewed NFPA 33 (Spray Application Using Flammable or Combustible Materials 2007 ). This publication, and many others, as well as … [Read more...]