gguilford's blog

IHMM Government Affairs in Pennsylvania with PCC

Thu, 06/06/2019 - 11:01

Please see below links to recent media coverage related to occupational licensing reform efforts in Pennsylvania.  As you’ll note from the articles, there is widespread interest in this issue, and most of the coverage has focused on HB 1477 and SB 637, neither of which are problematic from the PCC’s perspective.  While we are encouraged that the bulk of the focus in PA is on those two unobjectionable bills, we are actively monitoring developments there to ensure that troublesome provisions – such as those found in HB 811 – do not appear in any moving legislative vehicles that contains occup

EPA National Priorities List

Wed, 06/05/2019 - 16:32

The Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA” or “the Act”), as amended, requires that the National Oil and Hazardous Substances Pollution Contingency Plan (“NCP”) include a list of national priorities among the known releases or threatened releases of hazardous substances, pollutants or contaminants throughout the United States. The National Priorities List (“NPL”) constitutes this list. The NPL is intended primarily to guide the Environmental Protection Agency (“EPA” or “the agency”) in determining which sites warrant further investigation.

EPA Hazardous Waste Pharmaceuticals Rule Mandates Changes for Health Care Facilities

Wed, 06/05/2019 - 12:14

Environmental Protection Agency (EPA) has issued a new rule that will impact the operations of a wide-range of health care facilities and the manner in which those facilities manage hazardous waste pharmaceuticals.  The “Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine” applies to health care facilities that distribute, sell, or dispense pharmaceuticals, including hospitals, ambulatory surgical centers, physicians’ offices, optical and dental providers, chiropractors, long-term care facilities (excluding assisted living facilities), and

Stericycle_EPA-image.jpg Navigating EPA’s Hazardous Waste Pharmaceuticals Rulemaking (Part Two)

Wed, 06/05/2019 - 12:08

Even with the U.S. Environmental Protection Agency’s (EPA) finalized standards for managing hazardous waste pharmaceuticals beginning to take effect in August, some healthcare waste facilities still don’t have hazardous or controlled substance programs in place.That’s something that Cara Simaga, director of regulatory affairs at Stericycle, a healthcare waste management company, has noticed with a handful of the companies she works with. On top of that, she has seen confusion on the enforcement side of things.

Amendments to the Transportation of Dangerous Goods Regulations (Emergency Response Assistance Plan)

Mon, 06/03/2019 - 16:40

Canada.  Recent amendments to the Transportation of Dangerous Goods Regulations (the Regulations) seek to enhance response to releases of dangerous goods; to ensure more effective, timely responses to incidents and clarify expectations of handlers and transporters of dangerous goods.  See: https://www.lexology.com/library/detail.aspx?g=4147fbc4-32db-4115-94ee-c47a59283aa3

Cargo Tank Marking/Placarding/Hazardous Materials Regulations: U.S. Pipeline and Hazardous Materials Safety Administration Addresses Ethanol/Gasoline Mixtures

Sat, 06/01/2019 - 11:21

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a February 7th letter a request for clarification of the Hazardous Materials Regulations (“HMR“) applicable to marketing and placarding of cargo tanks.The PHMSA letter was in response to a February 21, 2018, query from GATE Petroleum Company (“GPC”) of Jacksonville Florida.GPC informed PHMSA that it typically transports “UN1203, Gasoline” and “UN1202, Fuel oil” to customers in multi-compartmented cargo tanks.

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