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WINTER 2017 ISSUENew Mobile App for Chemical Hazard Information (page 1)

Comment on Amendments to the Hazardous Waste Fee Regulation (page 2)

New Resources for Small Quantity Generators Available in Spanish (page 2)

New Process for Submitting Dangerous Waste Annual Reports (page 3)

Automated Tools can Help Companies Avoid Regrettable Chemical Substitutions (page 4)

Consultants not Authorized to Sign Dangerous Waste Annual Reports (page 5)

The National Institute for Occupational Safety and Health (NIOSH) has created a mobile application for quick access to chemical information from your cell phone or tablet (cdc.gov/niosh/npg/mobilepocketguide.html).

You can search more than 600 chemicals by trade name, chemical name, or CAS Registry Number to find information about:Exposure limits.Immediately dangerous to life or health (IDLH) values.Required personal protective equipment (PPE).Exposure symptoms.First aid procedures.The app also has a "favorites" feature

so you can bookmark chemicals you look up often.

NIOSH's app is a digital version of their Pocket Guide to Chemical Hazards, a longstanding industrial hygiene publication. The app works even when offline, so you can still access chemical information in remote locations.

While the app is a helpful best practice guide, note that Washington State Permissible Exposure Limits (PELs) may differ from federal limits. For regulatory purposes, consult Washington State's Safety Standards for Airborne Contaminants (lni.wa.gov/Safety/Topics/AtoZ/ChemicalSafety/ExposureLimits.asp).

New Mobile App for Chemical Hazard Information

Publication #17-04-001A

Saskia van Bergen

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New Resources for Small Quantity Generators Available in Spanish

By Diane Fowler

Comment on Amendments to the Hazardous Waste Fee Regulation

Ecology proposed amendments to Chapter 173-305 WAC, the Hazardous Waste Fee Regulation (app.leg.wa.gov/WAC/default.aspx?cite=173-305). These changes will affect businesses that are required to complete a pollution prevention plan, and pay the Hazardous Waste Planning Fee. Businesses generating more than 2,640 pounds of dangerous waste annually must complete a plan and pay fees.

The amendments align rule language with the agency’s existing fee calculation practices. This rulemaking only pertains to the Hazardous Waste Planning Fee calculation found in WAC 173-305-220. These rule changes would:• Exclude dangerous waste that is treated on-site

by the generator according to WAC 173-303-170(3)(b)and(c).

• Exclude non-recurrent dangerous waste as reported on the Dangerous Waste Annual Report required under WAC 173-303-060(5).

• Clarify language used to calculate inflation as applied to the fee.

The proposed amendments won’t make changes to

the Hazardous Waste Generation Fee. These fees are often confused—read about them both on our website (ecy.wa.gov/programs/hwtr/fees.html).

After the formal public comment period and public hearing, we expect to adopt the new regulations in April 2017.

Public involvementEcology hosted an informal public workshop on August 25, a public webinar on September 8, and a public hearing on January 4.

We accepted informal comments on the draft rules and are now accepting formal comments until January 23, 2017 (ecy.wa.gov/programs/hwtr/laws_rules/HWFee/1606inv.html).

More informationSee our rulemaking website for more information. You can also subscribe to the HW Fee Rule Listserv to receive regular updates about meetings and rulemaking activity (listserv.wa.gov/cgi-bin/wa?SUBED1=HW-FEE-RULE&A=1).

If you have questions, please contact John Ridgway at hwtrrulemaking@ecy.wa.gov or 360-407-6713.

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New Resources for Small Quantity Generators Available in Spanish

New Process for Submitting Dangerous Waste Annual ReportsBy Jeri Brining

Starting January 2017, large quantity generators (LQGs) will submit their Dangerous Waste Annual Report using a new electronic submittal process. This new process meets the federal signature standards of the U.S. Environmental Protection Agency’s Cross-Media Electronic Reporting Rule (CROMERR). If you are an LQG that submits electronically, you must submit your report using CROMERR. Your authorized representative will need to have user credentials for Secure Access Washington (SAW) and CROMERR to submit your site’s Dangerous Waste Annual Report using TurboWaste.

Medium and small quantity generators with active RCRA Site ID Numbers may continue to report as they normally do.

The CROMERR system requires the person who signs and certifies your report is someone who has legal authority to sign contracts for the company. Ecology is required by statute to follow the laws put in place by the federal Environmental Protection Agency (EPA) in 40 CFR Part 270.11, Signatories to permit applications and reports. A signature on any report or notification must be from an authorized representative of the company. “Authorized representative” is defined in 40 CFR Part 260.10 as “the person responsible for the overall operation of a facility or an operational unit (i.e., part of a facility), e.g., the plant manager, superintendent or

person of equivalent responsibility.” Consultants are not authorized representatives of your company.

For more information and access to the user’s guide go to our reporting website (ecy.wa.gov/programs/hwtr/waste-report).

Businesses who need more assistance please call 1-800-874-2022 within Washington. Businesses located outside of Washington please call 360-407-6170.

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We recently published a brochure for Small Quantity Generators called Does my business generate dangerous waste? This visual guide introduces beginners to the topic of dangerous waste. The Spanish version is called ¿Genera mi empresa residuos peligrosos?

If you're a fan of our Dangerous Waste Basics video, it’s now available with Spanish subtitles (youtube.com/watch?v=dL8QIIqM-z4).

Ask us about translated materials at hwtrpubs@ecy.wa.gov.

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When it comes to choosing safer chemicals to use in products and processes, it's crucial to know the potential hazards of chemicals before you select an alternative. Though it seems like an obvious step, it is often overlooked and can lead to a regrettable substitution. This means replacing a toxic chemical with one that has unknown—if not greater—toxic effects.

N-propyl bromide (nPB) is a popular example of a regrettable substitution (osha.gov/dts/hazardalerts/1bromopropane_hazard_alert.html). When federal regulators tightened safety limits on methylene chloride, many adhesive manufacturers moved to nPB as a safer substitute (osha.gov/dts/hazardalerts/methylene_chloride_hazard_alert.html). But the Occupational Safety and Health Administration (OSHA) reports that after even short-term exposure, workers using spray adhesives containing nPB can suffer from leg spasms, numbness of the extremities, and in some cases, painful permanent nerve damage that impairs mobility. Clearly, nPB is no safer to workers

than the chemical it replaced.

How can online databases help avoid regrettable substitutions and inform chemical management?Online chemical hazard databases can identify some of the known impacts chemicals have on human health and the environment and provide a first line of defense against regrettable substitutions.

The Chemical Hazard Data Commons is a free database of more than 34,000 chemicals (commons.healthymaterials.net). The database screens chemicals against 60 hazard and warning lists and categorizes which chemicals to avoid. Simple and easy to use, the Data Commons is an excellent starting place to begin learning more about the potential impacts of chemicals you use.

While the Data Commons won't tell you if a chemical is safe, it can quickly identify hazardous chemicals that you shouldn't choose as substitutes.

The information you find in the Data Commons is also useful when making a new product, assessing the chemicals you currently use, and prioritizing chemicals for replacement.

Training for using online databasesThis spring, Ecology will offer training opportunities for basic chemical hazard assessments and using online databases. A free online training will teach participants the basic principles of chemical hazard assessments and how to use the Data Commons to identify and screen out hazardous chemicals. In-person trainings will give participants hands-on practice using the tool. The trainings will be most helpful for small to medium size businesses that make chemical management decisions or state and local government staff that provide technical assistance to businesses.

For questions about upcoming trainings or assistance in assessing chemical hazards, contact Saskia van Bergen at sava461@ecy.wa.gov or 360-407-6609.

Automated Tools can Help Companies Avoid Regrettable Chemical SubstitutionsBy Saskia van Bergen

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Consultants not Authorized to Sign Dangerous Waste Annual ReportsBy Jeri Brining

Register now for these trainings!

First Line of Defense: A Tool for Chemical Hazard AssessmentLearn the basic principles of chemical hazard assessments, why they are of interest, and basic tools to identify and screen out hazardous chemicals.

Register for this free webinar trainingFebruary 8, 10-11:30 a.m. PT

Reducing Chemical Hazards: the First Move Get hands-on practice using an automated tool that allows companies to easily identify hazard when making chemical management decisions.$49 / $69

March 15 in SeattleJune 6 in PortlandVisit the green chemistry events page to learn more or register (ecy.wa.gov/greenchemistry/events.html).

We’ve learned that some businesses are hiring consulting firms to report their dangerous waste activities. While not an issue for managing and preparing Dangerous Waste Annual Reports and Notifications of Dangerous Waste Activities, consultants aren’t authorized to sign or electronically submit these documents. This includes submitting documents using TurboWaste.

Statute requires Ecology to follow the laws put in place by the federal Environmental Protection Agency (EPA) in 40 CFR Part 270.11, Signatories to permit applications and reports. A signature on any report or notification must be from an authorized representative of the company. “Authorized representative” is defined in 40 CFR Part 260.10 as “the person responsible for the overall operation of a facility or an operational unit (i.e., part of a facility), e.g., the plant manager, superintendent or person of equivalent responsibility.”

If your company uses a consultant to complete this work on your behalf, an authorized representative of your company must review and sign or electronically submit the documents via TurboWaste. Also, keep in mind that consultants cannot be listed as the “Form Contact” or “Site Contact” on the Site ID Form. Going forward, documents signed and/or submitted by consultants will no longer be valid. Ecology will not accept documents submitted electronically by consultants in TurboWaste. To not overburden reporting businesses, Ecology won’t require the correction of already submitted documents.

If you have any questions regarding this matter please contact Jean Rushing at jeru461@ecy.wa.gov or 360-407-6732.

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Accommodation Requests:To request ADA accommodation including materials in a format for the visually impaired, call the Hazardous Waste and Toxics Reduction Program, 360-407-6700. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.

We're always on the lookout for article ideas. What dangerous waste or pollution prevention topics would be helpful to you? Are you a topic expert? Contact us and we could feature you as a guest author in a future issue.

Visit ecy.wa.gov/programs/hwtr/shoptalkonline to see previous issues.

Email shoptalk@ecy.wa.gov. listserv.wa.gov/cgi-bin/wa?SUBED1=SHOPTALK-NEWSLETTER&A=1

What would you like to see here? Let us know!