Sophic Pursuits, Inc. - Practical Solutions for Today's Regulatory Environment
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TSCA Time
Keeping your LDAR Program Current
It is time to start watching - S697
New Chemicals under Prop 65
Toxicity - Sensationalism versus reality

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Regulation

Keeping your LDAR Program Current

The 15th LDAR Symposium Sponsored by the ISA just concluded in New Orleans.  If you were unable to attend that session, here is a webinar that was presented prior to the Symposium "Keeping your LDAR Program Current."

It is time to start watching - S697

After several years of hearing that it is coming, it appears it is finally happening.  There has been a move afoot to "modernize" the Toxic Substance Control Act (TSCA). Over time there has been a bill that has been introduced and then never acted upon.  However, this session of Congress appears to be moving this one along.

It seems that Senate Bill 697 (S697) has become the consensus leader in the pursuit of action. And, so far seems to be moving at a rapid pace.  This Bill - the "Frank R.

New Chemicals under Prop 65

For those of you who have to do Prop 65 labeling - there are 12 new chemicals that have to be included:


Year in review - preparation for 2015

2014 is quickly drawing to a close.  Which means that many of the regulatory specialists are in the process of developing a plan of attack for the year end reporting.  January always brings a slew of data gathering, and requests to parse that data for a variety of reports.  So, it is always helpful to look at what changes may have occurred in the past year that you need to be aware of as there may be changes to the lists of materials, slight definition changes that may require a bit of analysis to determine if the data you are collecting is correct, and there may even be a new form or report that you haven't considered.

Compressors

On November 28, 2014  - the Department of Energy issued a proposed rule that will impact commercial and industrial compressors.  From the summary of the proposed rule:

"The U.S. Department of Energy (DOE) is considering establishing energy conservation standards for commercial and industrial compressors. To date, DOE has considered energy conservation standards only for compressors intended to compress air, rather than natural gas. As a result, DOE's current efforts have focused on air compressors.

Legislation, Regulation and Impacts

For those of you that follow this blog, you have heard me discuss the unintended consequences of regulation before.  But look at the following items:

According toGovTrack

The 113th Congress has passed 186 Laws 
The 112th Congress passed 284 Laws
The 111th Congress passed 385 Laws

According to an article published inMarch 2014- the 17,522 pages of regulations have been added to the Code of Federal Regulations since 2009 - essentially an 11% increase in the regulatory burden. 

Just prior to this holiday weekend - the

The Chemical Safety Board & the Chevron Refinery Incident

The Chemical Safety Board (CSB) had released its final report on the Chevron Refinery Incident that occurred on August 6, 2012.  (The final report can be foundhere.)  Additionally, the CSB has issued some recommendations regarding how refineries should be regulated.  (See the CSBpress release) At issue is the process safety management (PSM) program and how it is managed.  Today the CSB sees PSM as primarily reactive rather than a proactive adapted program. 

PSM and other regulations such as the SARA Community Right to Know have been under a great deal of scrutiny of late due to incidents like this one and the one that occurred in West, TX.

Need a detailed look at the Proposed Refinery Air Rule?

October 28, is the current deadline for comments to the Proposed Refinery Air Regulations.  You can find a copy of the rule making and supporting information on EPA's website. This site has links to all the petroleum refinery air regulations as well as information about the current rule making.  If you want to get an overview of some of the critical portions of the rule - Check out this month's cover story in Pollution Engineering.

Has the Clean Air Act Worked?

When working in a regulated industry, the focus is usually on how can I comply with the regulation, or questioning why the regulation has been drafted that way.  The ultimate purpose of the regulation has a tendency to get lost in the day-to-day management of how the regulation is worded, how it is inspected, and what types of violations have been recently highlighted.  Such is the case of the Clean Air Act. 

If you look at the history of the Clean Air Act in the United States, there was a need to do something.

Update - Proposed Petroleum Refinery Air Rule

One may have anticipated that an extension period was likely in the Proposed Petroleum Refinery Risk and Technology Review and New Source Performance Standards rule making process.  EPA has made it official - the comment period on the the proposed rule will now close on October 28, 2014.  (You can see the Extension Noticehere.The Federal Register Notices is locatedhere.

The Public Hearings on the proposed rule have been very active, if local newspaper accounts are to be believed.

The extension in this case is very much needed due to the breadth and scope of the proposed rule making.
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