By Jeryl L. Olson and Craig B. Simonsen
Seyfarth Synopsis: Last week the U.S. Environmental Protection Agency (EPA) finalized a “streamlined system” for managing hazardous waste aerosol cans as Universal Waste. The Agency believes that the new system will be “clear, practical, and protective” and will promote recycling, and estimates the change will save at least $5.3 million annually
Continue Reading EPA Promulgates “Streamlined System” for Managing Hazardous Waste Aerosol Cans
By Andrew H. Perellis, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: For companies in the freight industry, if sustainability is important at your company or to its board of directors, then you may wish to investigate the EPA’s updated Smartway program, with its new resources and tools.
The U.S. Environmental Protection Agency’s SmartWay program has recently
Continue Reading EPA Updates and Republishes SmartWay Freight Transportation Sustainability Program
By Jeryl L. Olson, Ilana R. Morady, Patrick D. Joyce, Philip L. Comella, and Craig B. Simonsen
The Pipeline and Hazardous Materials Safety Administration (PHMSA) just announced that it has amended the Hazardous Materials Regulations (HMR). 81 Fed. Reg. 18527 (March 31, 2016).
It has done so by adopting its proposed regulatory amendments applicable to the reverse
Continue Reading DOT Publishes Final Rule on “Safe Reverse Logistics” for Retail “Returns” of Hazardous Materials to Distribution Centers
By Ilana R. Morady and Craig B. Simonsen
On August 6, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule modifying the requirements governing the transportation of lithium cells and batteries. 79 Fed. Reg. 46012.
The final rule revised hazard communication and packaging provisions for lithium batteries to harmonize the Hazardous Materials Regulations with applicable
Continue Reading DOT Partially Extends Compliance Date for HazCom and Labeling of Lithium Cells and Batteries
By Brent I. Clark, Kerry M. Mohan, and Craig B. Simonsen
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a Safety Advisory, 79 Fed. Reg. 64646 (October 30, 2014), to provide guidance on the U.S. Department of Transportation’s Hazardous Materials Regulations (HMR), 49 CFR, parts 171–180, for persons who prepare, offer, and transport materials contaminated
Continue Reading Safety Advisory on Handling and Transporting Materials Suspected of Being Contaminated with Ebola
By Jeryl L. Olson and Craig B. Simonsen
The Pipeline and Hazardous Material Safety Administration (PHMSA) has proposed to modify its hazardous materials regulations as it affects the retail industry by adding a definition for “reverse logistics.” 79 Fed. Reg. 46748 (August 11, 2014).
PHMSA has been working on the proposal since July 2012, when it had requested public comment
Continue Reading Retail Industry Update: DOT’s “Reverse Logistics” Rulemaking to Add Exception for Transportation of Hazardous Materials
Janet McCabe, Acting Assistant Administrator, U.S. Environmental Protection Agency, discussed yesterday’s Supreme Court opinion, and other topics, while speaking before the Air and Waste Management’s Association’s Annual Conference today.
The Supreme Court
The Supreme Court yesterday ruled, in-part, that “EPA lacked authority to ‘tailor’ the Clean Air Act’s unambiguous numerical thresholds of 100 or 250
Continue Reading McCabe Addresses Supreme Court Decision and Other Topics – EPA is “Very Pleased”
By James L. Curtis and Craig B. Simonsen
In a recent U.S. General Accountability Office (GAO) whistleblower protection program report, the GAO recommends that the Secretaries of Labor and Transportation evaluate their current and in-process memoranda of agreements (MOAs) to ensure that the MOAs incorporate key practices for collaboration. “Opportunities Exist for OSHA and DOT to Strengthen Collaborative Mechanisms
Continue Reading GAO Report on OSHA, DOT Whistleblower Issues
By Ilana R. Morady and Eric E. Boyd
Earlier this month in Geneva, the U.N. Subcommittee of Experts on the Transport of Danger Goods (Subcommittee) convened to consider additions and revisions to the U.N. Model Regulations (Regulations). The Subcommittee approved two noteworthy proposals.
By way of background, the Regulations cover all aspects of the transportation of dangerous goods (known as
By James L. Curtis and Craig B. Simonsen
The U.S. Bureau of Labor Statistics (BOL) has just released preliminary findings in its 2011 Census of Fatal Occupational Injuries Summary.
Key preliminary findings of the 2011 Census of Fatal Occupational Injuries data indicate that fatal work injuries in private truck transportation rose fourteen percent in 2011, the second consecutive year
Continue Reading BLS Releases Preliminary Census of Fatal Occupational Injuries