March 2020 has been a challenging month for many of us, adapting our business and personal lives to changing circumstances. Brown and Caldwell continues to work with industry, municipalities and regulators to determine what compliance deadlines may be changing due to the COVID-19 pandemic, or where appropriate variances can be received to balance risk to human health and the environment.

We are sharing three articles from our BLR resource, focusing on safety in the workplace during the COVID-19 pandemic, as well as updates to refrigerant management regulations and complying with hazardous waste determination requirements.

Preparing for COVID-19
The Occupational Safety and Health Administration (OSHA) issued guidance on preparing workplaces for a COVID-19 outbreak. OSHA’s recommendations, similar to those released by the Centers for Disease Control and Prevention (CDC), urges employers to prepare immediately and provides suggested steps and procedures to address potential health risks from the coronavirus in their workplaces.

Cooling of HFC Refrigerant Requirements
The EPA issued a final rule rescinding the leak-repair requirements of a 2016 rule issued for refrigerants used to replace Class I or II ozone-depleting substances. Other 2016 provisions will remain related to prohibiting and knowing releases of these refrigerants in the course of specific activities.

Determining the best method of hazardous waste determination
Facilities that generate more than 100 kilograms of hazardous waste per month are subject to a suite of requirements under Subpart C of the federal Resource Conservation and Recovery Act (RCRA). A characteristic hazardous waste determination can be made through either generator knowledge or testing. Information from the EPA’s Solvents in the Workplace: How to Determine If They Are Hazardous Waste provides important guidance on making the correct choice for how the determination is made.

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