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Earlier this summer, Congress significantly amended the Toxic Substances Control Act (TSCA).  You can read about the amendments here along with the implementation requirements.  A key implementation requirement and one that has been extensively discussed is the mandate that EPA designated at least 10 chemicals form its Work Plan for risk evaluations.  One of the chemicals or substances that is being touted as one to be reviewed for possible stiffer regulations is asbestos.  Sen. Boxer of California recently sent a letter to EPA asking EPA to consider asbestos in it’s first round of regulated substances (also known as the “Work Plan List”).  Other substances that have been mentioned as possible chemicals that EPA should examine are: PERC, Phthalates, BPA, Chlorinated phosphate fire retardants, TBBPA, Brominated phthalate fire retardants, 1-Bromopropane, DEHA, P-dichlorobenzene (Source: EWG, link).

Interestingly, EPA has been quiet on the Work Plan list.  Although EPA has shown that they are working on their charges under the new rule.  In early August, EPA held public meetings to discuss the risk evaluations required under the new TSCA rule.  Copies of the presentations made at these meetings can be found here.  The presentations focused on the provisions to (1) Prioritize Risk for Substances and (2) Collect Fees.


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August 25, 2016

Local Limits: Review and Detailed Re-Evaluation

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FEATURED PROJECT

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PROBLEM

A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.


SMG'S APPROACH

SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.

SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.


RESULTS

SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.