Environmental

Changes are Coming to Hazardous Waste Management

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Changes Coming to Hazardous and Universal Waste Management in Ohio

Hazardous waste generator improvements are coming!   These changes are good, but will require generators here in Ohio to review their hazardous waste programs and be prepared to incorporate these changes by May 2019.

New definitions, requirements and regulatory references have been established for all categories of waste generators and also changing the smallest waste generator category known as Conditionally Exempt Small Quantity Generators (CESQGs), to now be called Very Small Quantity Generators (VSQGs).   All the changes are far too extensive to cover in a short blog, but some of the most significant changes will be covered.

Satellite Accumulation Point Management

 EPA has revised quantity limits for acute hazardous wastes (1 qt for liquids and 1 kg for solids) at satellite accumulation points as well as marking requirements on hazardous waste containers at satellite accumulation points.  Containers must still be marked with the words “Hazardous Waste” but now also have markings indicating the “Hazards” of the waste.

For Small and Large Quantity Generators, Satellite Accumulation Points must now meet generator-specific emergency preparedness and planning requirements, which previously only applied to a generators 90-day or 180-day centralized storage areas.

Emergency Preparedness and Planning

Requirements pertaining to emergency preparedness have been expanded to include posting emergency response information “next to telephones or in areas directly involved in waste generation and accumulation of hazardous waste”.  Further, all Large Quantity Generators (LQGs) will be required to prepare and submit to local first responders or the Local Emergency Planning Committee (LEPC) a Quick Reference Guide.

Episodic Generation

Many generators have been forced to scramble to meet higher generator category requirements or take the risk and liability of being in non-compliance when unplanned (or even planned) hazardous waste generation causes the generator to exceed their normal generator category limits.  Under the new rulemaking, EPA allows for a one time episodic hazardous waste generation event (planned or unplanned) allowing a VSQG or SGQ to remain in their normal waste generator category.

Source:  https://www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements

 

Embrace the Changes: Quality & Environmental Management Systems

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by Larry W. Sheppard, ISO 14001-2015 EMS & ISO 9001-2015 QMS Consultant

Companies currently certified to ISO 14001-2004 and ISO 9001-2008 must be re-certified to the revised standards by September 15th 2018 or risk the possibility of losing their certification.  The new standards did not add any new requirements; however, some of the existing requirements in the 2015 versions have significant changes. Transition for ISO 14001-2004 and ISO 9001-2008 certified companies should be easy to implement since they have an EMS/QMS base that meets most of the requirements of the 2015 version.

This is where the Alber Enterprise Center of The Ohio State University can assist your company during the transition to the new standards. We would be glad to meet with your management staff and present the new requirements in detail.

 Main changes in ISO 14001:2015 EMS

The new requirement is to understand the organization’s context has been incorporated to identify opportunities for the benefit of both the organization and the environment. Particular focus is on issues or changing circumstances related to the needs and expectations of interested parties (including regulatory requirements) and local, regional or global environmental conditions that can affect, or be affected by, the organization. Once identified as a priority, actions to mitigate adverse risk or exploit beneficial opportunities are integrated in the operational planning of the EMS.

 To ensure the success of the system, a new clause has been added that assigns specific responsibilities for those in leadership roles to promote environmental management within the organization.

The expectation on organizations has been expanded to commit to proactive initiatives to protect the environment from harm and degradation, consistent with the context of the organization. The revised text does not define ‘protect the environment’ but it notes that it can include prevention of pollution, sustainable resource use, climate change mitigation and adaptation, protection of biodiversity and ecosystems, etc. i.e. environmental performance.

There is a shift in emphasis with regard to continual improvement, from improving the management system to improving environmental performance to be consistent with the organization’s policy commitments.  In addition to the current requirement to manage environmental aspects associated with procured goods and service, organizations will need to extend its control and influence to the environmental impacts associated with product design and development to address each stage of the life cycle, i.e. acquisition of raw materials, design, production, transportation/delivery, use, end-of-life treatment and final disposal.

Main Changes in ISO 9001-2015 QMS

Major Differences in Terminology between ISO 9001- 2008 & ISO 9001-2015

 

ISO 9001-2008 ISO 9001-2015
Products Products and service
Exclusions Not used

(See Clause A.5 for clarification of applicability)
Management Representative Not used (Similar responsibilities and authorities are assigned but no requirement for a single management represented)
Documentation, quality manual, documented records Documented information
Work environment Environment for the operation of processes
Monitoring and measuring equipment Monitoring and measuring resources
Purchased product Externally provided product and services
Supplier External provider

 Documented Information has replaced the ISO 9001-2008 version need for the quality manuals and some procedures to define the documented QMS. Documented Information includes instructions, records of process performances, external provider’s performance, internal audits and management reviews etc.

As part of the continual improvement process risk base thinking was added to the revised standard. The concept of risk has always been implicit in ISO 9001 as preventive action. The 2015 revision makes it more explicit and builds it into the total QMS.

Marion Student Leaves Center, Makes Impact

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(Above) Sabrina Mazyck, right, gathers field data with fellow student intern with National Park Service.

Outstanding students at Ohio State Marion have unique stories. Sabrina Mazyck, born and raised in Ohio, already had a Bachelor of Arts degree in Political Science when she came to Ohio State Marion Campus. Now, she is pursuing a degree in Environmental Engineering and has completed as much of her coursework at the Marion campus before she transitions to the Columbus campus this summer.  We were fortunate to benefit from her skills as a dedicated student employee in the Alber Enterprise Center this past year, and pleased that Sabrina will remain a Buckeye.

“I was fortunate to be able to take courses at Ohio State Marion since the tuition is so affordable. Financial aid is not available to students working on a second bachelor’s degree – only student loans,” Sabrina said. Cost of higher education has been a challenge, but Sabrina is hard-working, creative and persistent.

This student is a real go-getter, with past experience working as an Intern for Senator Mazie K. Hirono, D-Hawaii, on issues related to environmental policy.  She wrote about environmental impacts, attended briefings and visited government agencies, and became enamored with everything related to studying and improving the environment. “I feel that I had a tiny hand in the decision-making process around environmental policies (with the Senator’s office),” she said, adding, “But environmental engineers are involved in both policy work and the science behind it all, which means I could make a bigger impact.”

Another interesting internship Sabrina completed was with the National Park Service, where she worked on the Cuyahoga River as a Bioscience Tech Intern. “The Cuyahoga River has caught fire a total of 13 times, dating back to the 1800’s,” she said. Sabrina was part of team who waded in the water looking for zebra mussels and other invasive species, along with conducting organism surveys and recording the data. The group removed invasive species and propagated native plants near the river. “I carried a 50-pound backpack of herbicide and sprayed certain kinds of plants (identified as invasive), adding: “People in environmental work are some of the most kind-hearted I’ve ever met.”

After graduation from Ohio State, Sabrina is considering a Master’s in Ecology or Environmental Engineering. While her diverse experiences and initiative could take her anywhere, she would like to return to Hawaii after graduation from Ohio State in May, 2019.  With a cousin there, Sabrina was able to visit each of the Hawaiian Islands while interning for the senator. She said that the natives’ love of the land (meaning of Hawaii) is real…they are very environmentally-conscious. “The sea turtles are sacred – it is illegal to touch them. The people are so welcoming…I just loved it there!” said Sabrina.

Suffice it to say, Sabrina Mazyck is one student whom we would love to follow along to see where life takes her next. The sky really is the limit.