gguilford's blog

New Railroad Oil Spill Response Rules Issued by Pipeline and Hazardous Materials Safety Administration

Thu, 03/21/2019 - 14:44

On February 28, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), “in consultation with the Federal Railroad Administration and pursuant to the Fixing America’s Surface Transportation Act (FAST Act) of 2015, issued a Final Rule “to revise and clarify requirements for comprehensive oil spill response plans (COSRPs)” and “[e]xpands the applicability for COSRPs; modernizes the requirements for COSRPs; requires railroads to share information about high-hazard flammable train (HHFT) operations with State and tribal emergency response commissions to improve community preparedness; and incorporates by reference a voluntary standard.


Request; Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System

Thu, 03/21/2019 - 14:40

Information Collection Requests (ICRs) issued by EPA are typically pro forma notices alerting the regulated community that EPA is submitting a federally-required form for renewal to the Government Printing Office (GPO). On February 8, 2019, however, EPA issued an ICR that would alter the information contained in the RCRA hazardous waste manifest. 84 Fed. Reg. 2854.

IHMM Leadership Update

Thu, 03/21/2019 - 14:38

IHMM’s Chair of the Board Matthew Redmann had some good professional news for us in that he has been assigned the task of creating a new initiative at Harley Davidson. Unfortunately for us that also means he will not be able to take the helm as Chair, so Richie Spangler our Vice Chair, has assumed the role as Chair of the Board and Matthew has gone back to the position of Vice Chair. Congratulations to Richie, and all the best to Matthew in his new challenges with Harley!

EPA National Compliance Initiatives

Thu, 03/21/2019 - 14:37

EPA on February 4, 2019, issued a notice seeking comment and recommendations on its National Compliance Initiatives (NCIs) for Fiscal Years (FY) 2020-2023.  The notice should be published in the Federal Register within the next few days.  EPA is considering adding to its enforcement priorities reducing childhood lead exposure and ensuring Safe Drinking Water Act (SDWA) compliance.  EPA focuses enforcement and compliance resources on the most serious environmental violations by developing and implementing national enforcement and compliance program priorities, previously called National Enfo


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