Environmental, Health and Safety Consulting

MACT stands for Maximum Achievable Control Technology. You might be thinking you do not know much more now than when you thought MACT was just some four-lettered acronym that did not apply to you. The Clean Air Act Amendments (CAAAs) of 1994 are responsible for the MACT acronym. As part of the 1994 CAAAs, National Emission Standards for Hazardous Air Pollutants (NESHAPs) were required to be established for approximately one hundred and 188 hazardous air pollutants (HAPs). The basis for these...

According to the Occupational Safety and Health Administration (OSHA), there are approximately 30,000 industrial facilities in the United States at risk for dust explosions due to the materials they utilize and the processes they operate. OSHA states there have been in excess of 350 dust explosions resulting in more than 100 fatalities and numerous injuries since 1980. There were 15 fatalities in 2003 alone including the dust explosion at Hayes Lemmerz, a plastic dust explosion at a...

In today’s economic condition, an abundance of commercial and industrial properties have been surfacing in the marketplace. While the list of availability grows, the environmental stigma associated with past business at these facilities has continued to rise and continues to be one of the largest deterrents for perspective buyers.  It seems unless the property is “clean”, no one wants to assume “the environmental skeletons” that may reside in the property’s proverbial closet. But “How clean is...

The Environmental Protection Agency (EPA) regulation of fugitive volatile organic compounds (VOC) emissions, or leaks, arose out of the research projects conducted between the 1950s and 1980s at several facilities throughout the United States. The research concluded the cumulative effect of all the leaking components may present environmental and health problems to the surrounding area. The research also concluded when most components leak, they do so at very low levels, thus a majority of...

It is estimated leaking components in facilities nationwide emit more than 40,000 tons of volatile organic compounds (VOCs) each year. Recent EPA audits suggest that actual facility leak rates are over five times as much as what had been previously reported. The EPA is increasing enforcement and more facilities are becoming applicable to Leak Detection and Repair (LDAR) program requirements through the Clean Air Act via New Source Performance Standards (NSPS) and National Emission Standard for...

The Occupational Safety and Health Administration (OSHA) violations and fines can be time consuming to correct, expensive and bring a negative light to a company’s overall reputation. Repeat violations, or willful or knowing violations, will compound these issues exponentially. OSHA views repeat violations as a company’s indifference to safety in general and can put you in a high risk category. In fact, OSHA has a clear set of programs and procedures designed to concentrate resources...

On May 13, 2010, the U.S. Environmental Protection Agency (EPA) issued a final rule to address air permitting of six greenhouse gases (GHGs). This final rule “tailors” the Clean Air Act (CAA) permitting program to limit which facilities are required to obtain a Prevention of Significant Deterioration (PSD) and/or Title V operating permit. The EPA will phase in the Clean Air Act (CAA) permitting requirements in two initial steps.

To learn more about the Greenhouse Gas Tailoring Rule, click here...

Spills, or other releases of hazardous constituents to the environment, can have many forms including emergency response situations like fuel releases to a ditch during an accident, a release of petroleum from an underground storage tank (UST) or a release associated with waste storage. Regardless of the nature of the release, once a release has been identified, the responsible party must take actions to prevent further release, investigate the nature and extent of impacts and if warranted,...

The Environmental Protection Agency (EPA) proposed two regulations related to industrial boilers and process heaters which are intended to reduce the emissions of hazardous air pollutants (HAPs). The proposed rules include:

• Major Source Boiler & Process Heater Maximum Achievable Control Technology (MACT): National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters; and
• Area Source Boiler & Process Heater...

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) notified 15,000 workplaces nationwide that their injury and illness rates are higher than the national average. Two of the criteria OSHA used to identify these workplaces are the facility’s Days Away, Restrictions and Transfers (DART) rate and Days Away from Work Injury and Illness (DAFWII) case rate.

To learn more about whether or not OSHA is targeting your facility, click here to read an article written by...