While the oil spill was contained and caused little environmental damage, our newspaper reported yesterday that the facility was fined for failure to have an Oil SPCC plan. I never heard of this regulation.
I have always struggled to understand the applicability of the OSHA’s Permit-Required Confined Spaces standard and how best to go about properly implementing a program. Please shed some light on an approach someone like myself may follow to make certain we achieve compliance with this standard and protect my employees.
Question:
We are having a "spirited" discussion among our EH&S group whether or not we have to test for all of the eight TCLP metals in order to determine whether or not a material is a RCRA hazardous waste, in this case our wastewater filter press cake from our captive metal finishing operations.
Due to their desire to reduce chromium content of their parts, a number of our customers are asking us to investigate zinc alloy plating of their parts.
