Ohio Environmental Consultant

April 3, 2010

Inert Pesticide Ingredient - Proposed Rulemakng

The U.S. Environmental Protection Agency is requesting public comment on options for disclosing inert ingredients in pesticides. In this anticipated rulemaking, EPA is seeking ideas for greater disclosure of inert ingredient identities. Inert ingredients are part of the end use product formulation and are not active ingredients. Pesticide manufacturers usually disclose their inert ingredients only to EPA. Currently, EPA evaluates the safety of all ingredients in a product’s formulation when determining whether the pesticide should be registered.

On October 1, 2009, EPA responded to two petitions to designate more than 350 inert pesticide ingredients as hazardous. The petitioners asked EPA to require that these ingredients be identified on the labels of products that include them in their formulations.

EPA is accepting comments on the advance notice of proposed rulemaking for 60 days after it has been published in the Federal Register.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

March 23, 2010

Great Lakes Initiative Action Plan

U.S. Environmental Protection Agency (EPA) , in collaboration with 15 other federal agencies, have made restoring the Great Lakes a national priority and is proposing a budget of $475 million for a Great Lakes Restoration Initiative (Initiative). The EPA Action Plan, recently released, describes how the Initiative will be executed from 2010 through 2014.

The Plan builds on the Great Lakes Regional Collaboration Strategy (GLRC Strategy). The GLRC Strategy provides a framework for the Action Plan. The Action Plan has five major focus areas:

1. Toxic Substances and Areas of Concern, including pollution prevention and cleanup of the most polluted areas in the Great Lakes
2. Invasive Species, including efforts to institute a “zero tolerance policy” toward new invasions, including the establishment of self-sustaining populations of invasive species, such as Asian Carp
3. Nearshore Health and Nonpoint Source Pollution, including a targeted geographic focus on high priority watersheds and reducing polluted runoff from urban, suburban and, agricultural sources
4. Habitat and Wildlife Protection and Restoration, including bringing wetlands and other habitat back to life, and the first-ever comprehensive assessment of the entire 530,000 acres of Great Lakes coastal wetlands for the purpose of strategically targeting restoration and protection efforts in a science-based manner
5. Accountability, Education, Monitoring, Evaluation, Communication and Partnerships, including the implementation of goal- and results-based accountability measures, learning initiatives, outreach and strategic partnerships

The Action Plan identifies goals, objectives, measurable ecological targets, and specific actions for each of the five focus areas identified above. The Action Plan will be used by federal agencies in the development of the federal budget for Great Lakes restoration in fiscal years 2011 and beyond. As such, it will serve as guidance for collaborative restoration work with participants to advance restoration. EPA believes that the Plan will also help advance the Great Lakes Water Quality Agreement with Canada.

Caltha Water Quality and Water Standards Website

March 18, 2010

Greenhouse Gas Emission Guidance From CEQ

The Council on Environmental Quality (CEQ), has issued three draft guidance documents related to the implementation of the National Environmental Policy Act (NEPA),. The new guidance, issued in draft for public comment, directs how federal agencies are to:

Consider the effects of climate change and greenhouse gas emissions (GHGs) in agency decision-making;
Use mitigation to reduce or avoid impacts, and monitoring their effectiveness; and
Establish and apply categorical exclusions.

Public comments on the proposed GHG and mitigation guidance documents will be accepted for 90 days after they are printed in the Federal Register, and comments on the categorical exclusion guidance will be accepted for 45 days.

NEPA requires federal agencies to publicly disclose and consider the environmental consequences of their actions and of private actions requiring federal permits or approvals. It is a process-oriented statute and is not prescriptive in nature. NEPA does not mandate specific environmental results and grants federal agencies broad discretion to determine the extent of environmental protection required for proposed actions.

In the draft GHG guidance, CEQ proposes a framework on when and how to evaluate GHG emissions, and how to evaluate the effect of climate change on the project. The GHG guidance indicates that as part of the initial scoping process, agencies should determine whether a project requiring federal approval will result in “meaningful” GHG emissions, and suggests that emissions greater than 25,000 metric tons may meet this test. Emissions above this level would warrant at least some qualitative or quantitative discussion in NEPA documents.

The GHG guidance also recognizes that there are no existing federal protocols for estimating emissions associated with land use and land management decisions. It also recognizes that determining the reasonably foreseeable impacts of land management decisions on GHG emissions may be difficult.

November 30, 2009

Environmental Review Compared to Environmental Site Assessment

Is Environmental Review the same as a “Phase I” or “Phase 1 Environmental Site Assessment”?

No; a Phase I ESA is not the same as “Environmental Review”. Environmental Review is usually much broader in scope. However, there can be some overlap – some environmental reviews might include some of the same inquiries and document reviews that would be included in a Phase I ESA.

Click here for more information on Environmental Review & Environmental Impact Assessment

Click here if you need more information on Phase I Environmental Assessment
Or click here if you need information on Small Business Administration (SBA) or HUD Phase I ESA requirements

October 11, 2009

Cleveland Airport Targeted for Discharge Regulation

U.S. Environmental Protection Agency has proposed regulations requiring airports to collect at least some of the deicing fluid after it is used on aircrafts with a goal of cutting chemical discharge by 22%. The regulations would require six of the 14 major U.S. airports that are the biggest users of deicing fluid to install deicing pads or other collection systems to capture 60% of fluid sprayed and to install deicing pads or other collection systems. Some of the targeted airports include:

New York's John F. Kennedy and LaGuardia airports,
Chicago's O'Hare,
Boston Logan International,
Cleveland-Hopkins International, and
New Jersey's Newark Liberty International

It would then be the airports' responsibility to ensure that the collected fluid was treated and handled in accordance with requirements. Some 200 smaller facilities around the US would have to collect 20 percent of the fluid by using technologies such as a glycol recovery vehicle, while airports with fewer than 1,000 yearly jet departures would not be impacted.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

October 6, 2009

SBA Environmental Assessment Requirements - Records Search With Risk Assessment

The Small Business Administration (SBA) procedures under SOP 50-10(5) Lender and Development Company Loan Programs under certain circumstances requires Lenders to conduct a Records Search with Risk Assessment (RSRA) in order to evaluate the likelihood of contamination at the Subject Property and neighboring properties. If the RSRA concludes that there exists a high risk for contamination, additional environmental investigation may be required.

Caltha LLP provides cost-effective Records Search with Risk Assessment (RSRA) services to SBA Lenders across Ohio.

To request a quote for a Records Search with Risk Assessment (RSRA), go to:

SBA Records Search with Risk Assessment Services

MSDS Requirements - Hazard Communication Changes

OSHA has proposed to modify its existing Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The proposed modifications to the standard include:

revised criteria for classification of chemical hazards;
revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements;
a specified format for safety data sheets; and
related revisions to definitions of terms used in the standard, requirements for employee training on labels and safety data sheets.

OSHA is also proposing to modify provisions of a number of other standards, including standards for flammable and combustible liquids, process safety management (PSM), and most substance-specific health standards, to ensure consistency with the modified HCS requirements. Written comments are due by December 29, 2009.

For more information on Caltha's services relating to chemical hazard assessment and product stewardship, go to:

Chemical Hazard Assessment, Product Stewardship & Product Compliance Services