Remote EHS Support During the COVID-19 Crisis

The Baron Environmental teams of environmental, health & safety (EHS) professionals are actively providing the following remote EHS support to New Jersey manufacturers, pharmaceutical firms, life sciences, and others during the COVID-19 pandemic. Live video-based training sessions on regulatory EHS topics such as: PPE – Personal Protective Equipment HazCom – Hazard Communication EAP – Emergency Action Plan Hearing Conservation Blood-borne Pathogen Hazardous Waste SPCC – Spill Prevention, Countermeasure and Control Stormwater DPCC – Discharge Prevention, Countermeasure and Control Respiratory Protection, and Other EHS related topics not mentioned above. Technical Support in sustaining complia

Changes to the 2020 TRI (Toxic Release Inventory) Report

There are several changes coming for the 2020 Toxic Release Inventory (TRI) Report covering activities occurring in calendar 2020 and reported no later than July 1, 2021. The most significant changes are related to the reporting of newly listed per-and polyfluoroalkyl substances (PFAS) starting in with the TRI report due on July 1, 2021. PFAS are substances that are found in a variety of different products and industries including firefighting foams, food packaging, stain/grease repellent products, and health and beauty products. The Environmental Protection Agency (EPA) published its PFAS Action Plan in February 2019 to address the agency’s approach to addressing PFAS. These chemicals have

2019 TRI Reporting Deadline Has Not Changed Due to COVID19

EPA staff spoke extensively about the 2019 TRI deadline at a recent webinar focused on other TRI topics. Baron attended this webinar and is providing the information below as a service to our customers. The annual TRI reporting deadline for 2020 is still July 1, 2020, because it is a statutorily established deadline. EPA cannot extend this deadline without following the statutory process including public comment periods. On the other hand, on March 26, 2020, the EPA’s Assistant Administrator for Enforcement and Compliance Assurance issued a memorandum setting out a temporary policy for how enforcement discretion may be exercised in response to noncompliance that occurs due to COVID-19 issues

NJDEP Air Permitting Introduces the GP-009B for Boilers Combusting Natural Gas

The NJDEP Division of Air Quality announced a new General Permit (GP-009B) for boiler(s) greater than or equal to 10 MMBTU/hr and less than 50 MMBTU/hr. This General Permit replaced the previous GP-009A for boiler(s) and indirect fired process heater(s) greater than or equal to 10 MMBTU/hr and less than 50 MMBTU/hr combusting gaseous fuel. Each Boiler currently registered under GP-009A can continue to operate until: The current General Permit expiration date, before which time the permittee must register for authorization under GP-009B, as applicable, or apply for and receive approval for a source-specific permit and certificate for continued operation of the equipment; or Each Boiler replac

Changes to the 2020 TSCA Chemical Data Report (CDR)

Under the Toxic Substances Control Act (TSCA), there are several important, upcoming changes for the 2020 Chemical Data Report (CDR) which is required for many chemical manufacturers (and importers) every four years. The current reporting cycle covers calendar years 2015 – 2019. EPA has recently published a final version of the CDR Revisions Rule in the Federal Register which can be accessed at: https://www.federalregister.gov/documents/2019/04/25/2019-07716/tsca-chemical-data-reporting-revisions-and-small-manufacturer-definition-update-for-reporting-and The changes to the 2020 CDR focus on several areas including: Exemptions for certain byproducts Changes to claiming confidentiality to ali

NJDEP Updates General Operating Permits GOP-003 and GOP-004

The NJDEP Division of Air Quality recently revised the General Operating Permits (GOP-003) for an Emergency Generator Burning Distillate Fuel Oil and (GOP-004) for an Emergency Generator Burning Gaseous Fuels. These revised General Operating Permits update the definition of "Emergency Generator" and the Facility Specific Requirements (Compliance Plan) section to include Emergency Operation During Construction, Repair and Maintenance activities consistent with the latest State regulations at N.J.A.C. 7:27-22.1 and N.J.A.C. 7:27-19.1. The GOP-003 allows for the construction, installation, and operation of a single emergency generator, 2007 model year or later, having a maximum heat input rate

COVID-19 and EPAs New Enforcement Policy

Baron has reviewed EPA's recent publication of COVID-19 Implications for EPAs Enforcement and Compliance Assurance Program for how it may affect our clients. The EPA is providing flexibility in completing certain tasks such as compliance monitoring, integrity testing, sampling, lab analysis, training and reporting/certification activities if certain requirements are met. This policy began on March 13, 2020 and will continue until 7 days after EPA provides notice that the program is ending. This policy does not cover state actions (i.e. NJDEP or NYDEC) nor criminal violations. Should a facility find that it cannot maintain compliance due to a COVID-19 related shortage or outage, you must:

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Baron Environmental Associates, L.L.C.
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776 Mountain Blvd, Watchung, NJ 07069

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