The first week of April has ended—is your site experiencing “April showers that bring May flowers?” If so, make sure that your storm drains and other runoff devices aren’t clogged and that any regulated discharge doesn’t get into those storm drains. That tends to be a serious non-compliance issue for local municipal authorities who have to deal with downstream treatment. The week wasn’t super busy, however there are some items of high interest, especially for those dealing with hazardous waste testing or shipping flammable liquids by rail to, through, within, or from Canada. Here are the highlights:
The agency published a proposed rule that will modernize the way that ignitability is determined for hazardous waste classification. The modification does away with the requirement to use mercury based sensing devices when performing the testing. This should aid test labs, since maintaining mercury containing equipment on a site introduces potential hazards (Mercury being very toxic) as well as compliance issues for transport and disposal. See the NPRM here
From time to time the various federal agencies adjust their penalty fees for matters of non-compliance to keep up with inflation. This week several agencies of interest did so. Here are links to their respective announcement publications:
Federal Agency Civil Penalty Adjustments
- U.S. Coast Guard: https://www.govinfo.gov/content/pkg/FR-2019-04-02/pdf/2019-05878.pdf
- Department of Homeland Security: https://www.govinfo.gov/content/pkg/FR-2019-04-05/pdf/2019-06745.pdf
- TSA: https://www.govinfo.gov/content/pkg/FR-2019-04-05/pdf/2019-06745.pdf
- U.S. Customs: https://www.govinfo.gov/content/pkg/FR-2019-04-05/pdf/2019-06745.pdf
Our northern neighbor’s sister agency to PHMSA published a revised rule governing transport of dangerous goods by rail. The new rule incorporates the new TP 14877 standard for tank cars that was published last year. Some highlights:
- requires all tank cars used to transport toxic inhalation hazard (TIH) substances to be constructed of normalized steel. The interim TIH tank car standard will also be changed to the permanent TIH tank car standard.
- enhances alignment between Canada and the United States for One-Time Movement Approvals (OTMA).
- aligns with best practices by permitting 304L and 316L stainless steel varieties as an acceptable material of construction for tank cars and accounting for mileage into the stub sill inspection requirements.
- consolidates and clarifies the regulatory requirements.
Canada continues to lead the way in revising safety standards for transport by rail; nearly six years down the road from the tragic oil train derailment and fire, Lac Megantic continues to cast a long shadow over this mode of transport. Here’s your link to the rule
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