Community Right to Know: New Hazard Codes

The Environmental Protection Agency’s (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA) was passed in 1986 in order to require applicable facilities to report through the Community Right-to-Know (cRTK) Survey the storage and use of hazardous and toxic chemicals and to make their use more aware to the public and state and local agencies. The cRTK program also provides emergency planners and first responders with information about chemicals on-site in order to better assess and respond should a hazardous chemical release occur. This regulation stemmed from concerns from the 1984 pesticide plant disaster in Bhopal, India where a highly toxic substance was released, a half a milli

OSHA Violations

A wholesale merchant in Moonachie, NJ was recently cited for willful violations relating to exits and electrical regulations and fined over $181,000. The U.S. Postal Service sorting facility in E. Rutherford, NJ is facing more than $251,000 in fines for repeat violations of OSHA standards covering electrical systems and equipment and emergency exits and exit routes. A small arms manufacturer located in Bloomfield, NY was cited for violations relating to lockout/tagout, machine guarding, noise and confined spaces in a recent inspection. The facility is facing more than $244,000 in penalties as a result of the inspection that occurred earlier in 2017. An air conditioning company in Virginia w

NJDEP Electronic Netting Analysis Tool (eNAT)

Certain New Jersey Department of Environmental Protection (NJDEP) air permit applications pursuant to N.J.A.C. 7:27-22 require facilities to submit a netting analysis (N.J.A.C. 7:27-18.7). This must be conducted for all operating permit modifications that will require an emission increase and all general operating permit registrations. A netting analysis is conducted in order to calculate if the maximum allowable emissions stated in a permit application would result in a net emission increase or significant net emission increase, emissions equal to or greater than the increase levels below, at the facility for any of the following air contaminants: Air Contaminant Significant Net Emission

Clean Air Act Enforcement Violations

A natural gas and oil company has violated several air pollution regulatory requirements, including New Source Performance Standards (NSPS) that require facilities to minimize emissions during operations and National Emissions Standards for Hazardous Air Pollutants (NESHAPs) that requires control devices to be installed in facilities to prevent emissions of Hazardous Air Pollutants (HAPs) from exceeding thresholds. As a result of failure to comply with the above requirements, the facility will install air pollution control devices and conduct monitoring. The company will pay approximately $2.5 million dollars for violating the Clean Air Act requirements. A sand and gravel company will pay ap

NJDEP Basic Industrial Stormwater Permit (5G2) Renewal

The New Jersey Department of Environmental Protection (NJDEP) offers a Basic Industrial General Stormwater Permit (5G2) for industrial facilities that are able to eliminate exposure of source materials to stormwater. The former General Permit became effective on February 1, 2013 and expired on January 31, 2018. The renewed permit has been available from February 1, 2018 and is set to expire January 31, 2023. The final permit is available on the NJDEP’s website: The NJDEP, Division of Water Quality, Bureau of Nonpoint Pollution Control has released a Fact Sheet ( that highlights the permit cha

Final Rule Issued to Improve Tracking of Workplace Injuries (Updated 11/29/2017)

OSHA updated its recordkeeping rule requiring employers to electronically submit injury and illness data. The new rule, which took effect on January 1, 2017, requires certain employers to electronically submit injury and illness data, which they already are required to record on their onsite OSHA Injury and illness forms. Analysis of this data will enable OSHA to use its enforcement and compliance assistance resources more efficiently. This regulation will improve the accuracy of this data be ensuring that workers will not fear retaliation for reporting injuries or illnesses. So how will electronic submission work? OSHA has provided a secure website that offers three options for data submiss

SPCC Underground Storage Tank Applicability Requirements

The applicability of U.S. EPA's Spill Prevention, Control and Countermeasures (SPCC) rule, found at 40 CFR 112, is based upon two criteria: 1. The first criterion is the determination of whether a discharge of oil, in harmful quantities, can potentially occur into or upon navigable waters of the United States. Navigable waters are broadly defined to include waterways, swamps, lowlands, intermittent ditches, and storm and sanitary sewers. 2. The second criterion is the determination of whether the specified oil storage capacity volumes are exceeded. These volumes are as follows: a. Greater than 42,000 gallons underground oil storage capacity; or b. Greater than 1,320 gallons combined abovegro

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776 Mountain Blvd, Watchung, NJ 07069

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