IHMM Today November 15, 2022

IHMM RECENT NEWS

• Something in the Wastewater

• New sewage treatment step improves biogas conversion

• In a Deskless Economy, What do Workers Want?

• The ROI of Streamlined Contractor Management

• Construction Responsible for Almost Half of Electrocutions

• 4 Reasons Why You Should Dig Out Your Emergency Response Plan

• Manage change before it manages you

• EPA publishes Fifth Drinking Water Contaminant Candidate List

• New research details high consumer confusion around plastics recycling

• EPA signals changes to truck emissions standards

• Waste industry responds to EPA’s proposed PFAS CERCLA rule

• Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NNSR): Reconsideration of Fugitive Emissions Rule; Extension of Comment Period

• Drinking Water Contaminant Candidate List 5-Final

• National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources Technology Review

• EPA and PEMEX Announce Collaboration to Reduce Methane Emissions

• EPA Requests Public Comment on Proposed Cleanup at the Pierson’s Creek Superfund Site in Newark, New Jersey

• US Executive Branch Update – November 11, 2022

• EPA Requests Nominations for Science Advisory Committee on Chemicals

• Proposed Rule Would Require Government Contractors to Disclose Climate-Related Risks

• Revised Flood Hazard Area Control Act & Stormwater Rules to be Proposed on December 2, 2022

• US Department of Labor cites two contractors for demolition, asbestos hazards after mezzanine collapse at former South Boston power plant

• Federal workplace safety investigation of Mapleton foundry worker’s fatal fall into molten iron finds Caterpillar failed to install required fall protection

• US Department of Labor initiative seeks to protect food processing workers in Illinois, Ohio amid significantly higher injury rates

• Overcoming challenges in trace analysis of toxic gases in the air around us

• 4 Critical Layers of Flammable Fixed Gas Detection

• Choosing Effective Safety Training Methods

• Construction’s supply chain outlook: more shortages, price hikes ahead

• Transportation/Hazardous Materials: U.S. Pipeline and Hazardous Materials Safety Administration Addressing Wet Battery Recycling Issue Question

• Pipeline Safety:Fully Implementing Key Practices Could Help Improve Transparency of Enforcement Website

• UL Solutions Helps Companies Shipping Dangerous Goods to Enhance Trust with Launch of Industry-First Certification Program

• TT Club: Dangerous Goods Shippers Still Need to Work on Fire Safety

Congratulations to IHMM Board Election Participants

IHMM thanks Stephen Bennett, CSMP, Gerard Breton, CSMP, John Kasanicky, CSMP, Matthew Rehlander, CSMP, Ryan Sharratt, CHMM, Shawn St. Peter, CSMP, Erika Winning, CHMM, Jan Rosenberg, CSHM, and Ivan Schmelczer, CDGP for putting your names forth in the recently completed IHMM Board elections.

We are grateful to you for your willingness to serve. Here are the winners of the election and the seats they fill on the IHMM Board. Their terms begin January 1, 2023.

Jan Rosenberg, CSHM Seat

Ivan Schmelczer, CDGP seat

Erika Winning, CHMM, At-Large seat

In 2019 Mark Bruce from AHMP and Gene Guilford from IHMM worked on a project to get the Commonwealth of Pennsylvania to recognize the CHMM and CDGT credentials. With Mark’s work on the ground in  Pennsylvania, we succeeded.

• We have already succeeded in 13 states – New York, Connecticut, Pennsylvania, Indiana, California, Colorado, Nebraska, Minnesota, Arkansas, Oklahoma. Ohio, North Dakota, and Georgia. [Red states in the map above]. These are states where IHMM credentials are cited or 40 CFR 312.10 is cited by reference.
• We have partially succeeded in another 16 states – Alaska, Hawaii, Idaho, Montana, Arizona, Kansas, Iowa, Missouri, Illinois, Kentucky, Florida, Delaware, Rhode Island, Massachusetts, Vermont, and Maine. [Orange/Black Stripe states in the map above] These are states where the requirements of an “environmental professional” or QEP are cited that coincide with an IHMM credential so that relatively little work would need to be done to clarify the desired outcome.
• We have 21 states where no reference to an IHMM credential is made in either statute or regulation, nor is there anything defined in the area of an environmental professional. These states will require legislation or regulatory work. [Yellow states in the map above].

In January 2021 Mark at AHMP and Gene at IHMM has launched 45 in 5, getting the other 45 states to recognize our credentials in 5 years. If we can find a volunteer like Mark in other states [see above] we can work with those volunteers on crafting the right message to the right agencies in state governments across the country. If we find enough volunteers we can get this done in less than 5 years.

In January 2022 Gene Guilford released the 40 CFR § 312.10 EPA regulation that states a private certification that meets or exceeds the requirements of the regulation is an Environmental Professional under the regulation. Here is the crosswalk between the 40 CFR § 312.10 EPA regulation and the Certified Hazardous Materials Manager [CHMM] blueprint. The CHMM meets or exceeds the requirements of an Environmental Professional. 

Here’s what we ask each volunteer to do:

• Watch legislative and regulatory developments in your state that provide an opportunity for us to create amendments or other interventions
• Be willing to speak with regulators and legislators in your area about the recognition efforts we craft together

Pennsylvania PPC Plans No Longer Require P.E. Certification

A Preparedness, Prevention, and Contingency (PPC) Plan is a type of emergency response plan required by the Pennsylvania Department of Environmental Protection (PADEP) for certain types of facilities. The purpose of the PPC Plan is to ensure that facilities have developed and implemented adequate actions and procedures to respond to emergencies and accidental spills of polluting substances. PADEP published a PPC Plan guidance document (No. 400-2200-001, Guidelines for the Development and Implementation of Environmental Emergency Response Plans) in April 2001 and updated it in August 2005. This document provides section-by-section guidance on drafting a compliant PPC Plan. This guidance document states that facilities subject to Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 must have their PPC Plan certified by a Professional Engineer (P.E.) and that the P.E. must recertify the PPC Plan once per year.

One broad category of facilities that are required to prepare and implement a PPC Plan are those which have a National Pollutant Discharge Elimination System (NPDES) industrial stormwater or wastewater discharge permit. In PA, one mechanism for a facility to obtain NPDES stormwater coverage is via the PAG-03 Authorization to Discharge under the NPDES General Permit for Discharges of Stormwater Associated with Industrial Activity, or simply the PAG-03 General Permit. The PAG-03 General Permit includes a requirement for the facility to prepare and maintain a PPC Plan.

PADEP revises and republishes the PAG-03 General Permit roughly every five years. Prior to 2016, the PAG-03 General Permit explicitly required the annual P.E. certification for Section 313 facilities, consistent with the guidance document. However, the current version of the PAG-03 General Permit, issued September 2016 (currently administratively extended), does not mention the necessity to have a PPC Plan reviewed and certified by a P.E. ALL4 confirmed with PADEP that this P.E. certification (and annual recertification) has been removed entirely as of the issuance of the September 2016 PAG-03 General Permit. Therefore, PPC Plans are no longer required to have P.E. certifications for their initial versions or any subsequent updates.

EPA Finds Methylene Chloride, as a Whole Chemical Substance, Presents an Unreasonable Risk to Human Health

PHMSA – 2022 Research, Development & Technology Forum

Pipeline and Hazardous Materials Safety Administration Pipeline Safety Research Program

PHMSA released web app for ease of research on rulemaking and to make interpretations more user-friendly

Phasedown of Hydrofluorocarbons: Allowance Allocation Methodology for 2024 and Later Years

–Inside EPA

Fearing Sackett, Environmentalists Eye ‘Stop-Gap’ Wetland Protections

Fearing a Supreme Court ruling that could curb Clean Water Act (CWA) protections for wetlands and other waterbodies, environmentalists are eyeing a series of alternative protections that they say can be used to temporarily protect waters, including increased conservation funding, stepped up local enforcement and new local mandates.

But in an issue paper released Nov. 1, the coalition of five groups — Natural Resources Defense Council, Anthropocene Alliance, Earthjustice, Environment America, the National Wildlife Federation and the Southern Environmental Law Center — say that such protections are “at best, stopgap measures,” and that Congress will have to “step in and reaffirm” the original intent of the CWA: “to establish broad protections for the nation’s waterbodies.”

The issue paper, “Clean Water Act on Trial: The Devastating Potential Consequences of Sackett v. EPA” examines possible outcomes if the Supreme Court sides with the petitioners in the Sackett case, in which industry and conservative groups have asked the justices to reinterpret the CWA and exclude most wetlands and streams from the definition of “waters of the United States” (WOTUS).

“If the court sides with the plaintiffs or their industry supporters in Sackett, it would put crucial water bodies at risk of pollution or other forms of degradation,” the issue paper says.

–Inside EPA

EPA Sued To Issue Novel Stormwater Permits But Faces Industry Scrutiny

Environmentalists are suing EPA to force the agency to implement its novel decision to expand Clean Water Act (CWA) permitting requirements to cover a large swath of currently unregulated stormwater sources in three Massachusetts watersheds, even as industry representatives are warning the precedent-setting decision could face legal scrutiny.

The Conservation Law Foundation (CLF) and Charles River Watershed Association (CRWA) Nov. 2 sued EPA in a federal court in Massachusetts, alleging the agency violated the water law by failing to take several mandatory actions to implement its decisions, including notifying covered dischargers of their designation, as well as issuing draft permits and timelines for finalizing them.

“These iconic rivers are suffering because of the EPA’s consistent foot-dragging,” said Heather Govern, CLF’s “These iconic rivers are suffering because of the EPA’s consistent foot-dragging,” said Heather Govern, CLF’s vice president of Clean Air and Water, said in a statement. “Despite all the evidence linking stormwater pollution to dirty and unsafe water, the agency has failed to take legally required steps to address this growing problem. We have waited over three years for them to regulate the pollution, and these rivers cannot wait any longer.”

EPA Region 1, which is the CWA permitting authority in Massachusetts, announced in September that it has used its so-called residual designation authority (RDA) to designate additional stormwater sources for regulation, the first time the agency has used the authority on such a large scale.

–Inside EPA

IHMM Scholarship Program

The Institute of Hazardous Materials Management is pleased to have created $32,000 in academic scholarships, divided equally between $16,000 for students enrolled in undergraduate or graduate education in approved schools and who are also Student CHMMs, and $16,000 for students enrolled in undergraduate or graduate education in approved schools and who are also Student ASHMs.

IHMM seeks to foster the growth and academic success of students whose courses of education, and participation in one of our Student certifications, will lead to those students becoming fully-certified IHMM credential holders later in their professional lives.

Go to >  https://ihmm.org/scholarship/

IHMM CHMMⓇ 2022 Salary Survey

IHMM is pleased to release its 2022 salary survey for Certified Hazardous Materials ManagersⓇ [CHMMⓇ] across a broad range of position titles in the CHMMⓇ community of practice.

You may download the CHMM survey here.

IHMM CSHMⓇ 2022 Salary Survey

IHMM is pleased to release its 2022 salary survey for Certified Safety and Health Managers Ⓡ [CSHMⓇ] across a broad range of position titles in the CSHMⓇ community of practice.

You may download the CSHM survey here.

Sponsored content

IHMM  – 26 Fellows Are Mentors |  Where are the Mentees?

IHMM Fellows Committee Chair Atanu Das, CHMM, is leading the effort within the IHMM Collaboration networking platform to provide instruction to the more than 75 IHMM Fellows in becoming mentors.

Given the extraordinary experience Fellows have, this is a unique opportunity for IHMM Fellows to help guide more recent certificants in their professional development activities.

Atanu and Gene exchanged information about this program on 10/3 and while we are grateful for the 26 Mentors – We Have No Mentees!  No one could use help?

IHMM’s Collaboration platform contains a “Mentor Match” module [see below at right] that allows mentors to signup designating the hours, number of mentees, subject areas, and length of time they wish to mentor – as well as allowing mentees to signup requesting assistance in specified areas. The mentor match module does the rest by matching mentors and mentees.