Submodule 7A, Introduction, p.1

Introduction

Learning Goals:
  Be able to distinguish the three main federal agencies that are involved with the administration and transportation of hazardous waste and materials.
  Determine the principal charge of those agencies.
  Know the principal laws they administer

You eliminate some (at least a little) of the confusing mass of regulation of hazardous and toxic wastes by understanding the principal charge of the agencies that administer them.

Agencies	Acronym	CFR Title	Charge
Occupational Safety and Health Administration	OSHA	29 CFR	Obligations of employers for worker safety
Department of Transportation	DOT	49 CFR	Transportation
Environmental Protection Agency	EPA	40 CFR	Discharges to the environment Some manufacturing
State			Administers certain federal laws, varies with the state. Solid (non-hazardous) waste is usually state.
Local			Varies, usually fire protection and emergency response.

(You can look at those links briefly, to get an idea of the scope of the agencies work, as well as the volume of regulations, each book volume is about 400 pages.)

So if you picture a truckload of hazardous waste driving down a highway:

OSHA is concerned with the driver. Did she have proper training, know what the truck carries, have PPE?
DOT is concerned with avoiding crashes, fires and explosions. Is the vehicle properly maintained, driver competent, load strapped or contained to avoid fire?
EPA is concerned with discharges to the environment. Is the waste going to a proper disposal site, is it labeled such that people at the destination know what to do with it, is proper spill containment and cleanup gear available?
Local fire departments are concerned with what is being transported. In case of a crash, what is in the truck, what precautions do we need to take?
State agencies might administer any of the four above.

You can see some overlap in responsibilities. For example both DOT and OSHA are involved in training. DOT wants to be sure the driver can handle a 20 ton rig, knows the proper rules of the road. OSHA wants to be sure the driver knows what she is carrying, proper precautions during loading and unloading, the proper safety procedures in case there is a spill. Both want to be sure the driver is aware of fire and explosion hazards involved with the load.

Consider a barrel of hazardous goo inside a plant. Both OSHA and EPA are interested in how the barrel is labeled. OSHA, as part of its Hazard Communication standard, requires the employer to inform the employees of the hazards of chemicals. The EPA wants to be sure that a hazardous waste is clearly labeled, so it does not wind up in the common trash, or disappear in Junior Soprano's yard.

The other two submodules will examine fine points: Submodule 7B with issues "inside the plant" and 7C with transportation.

Submodule 7B

Module 07 Index

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