PSM/RMP: Exceptions to the Rule

2020 has necessitated change and adaptability on many levels. To abate the many risks posed by the pandemic, many facilities have started to explore additional service lines or processes, which means an entirely new set of equipment, chemicals, and employees. These additions create an additional set of hazards to mitigate in the workplace. If your businesses pivoted manufacturing practices earlier this year, you may now be faced with the dilemma of installing and implementing new processes at your facility associated with the storage of flammable liquids. Do you know if you have the appropriate permitting or programs in place to...

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The PFAS Significant New Use Rule Goes into Effect This Week. What Entities are Affected?

On July 27, the U.S. Environmental Protection Agency (EPA), published the final Significant New Use Rule (SNUR) for long-chain perfluoroalkyl carboxylate (LCPFAC) and perfluoroalkyl sulfonate (PFAS)* chemical substances under the Toxic Substances Control Act (TSCA), first proposed in January 2015. The final SNUR requires persons to notify EPA at least 90 days before the start of manufacturing (including import), or processing of these chemicals for any use designated as a significant new use. This includes the import of a subset of LCPFAC chemicals as part of a surface coating on items, such as the PFOA utilized in Teflon in cookware....

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