Archive | Environmental Audits and Self-Disclosure RSS feed for this section

OSHA’s new online recordkeeping tool

20 Aug

OSHA, the Occupational Health and Safety Administration, launched a new online tracking tool to help employers better comply with its recordkeeping and reporting requirements. The tool, OSHA Recordkeeping Advisor, is intended to “simulate and employer’s interaction with a Recordkeeping rules expert.” The new tool does not actually keep any records and is completely confidential.

According to the OSHA press release, the new tool is intended to help companies determine: (more…)

The Global Reporting Initiative

9 Aug

The Global Reporting Initiative (GRI) is fast becoming the standard for sustainability reporting. The GRI develops frameworks for reporting non-financial disclosures through a consensus-based process. The main reporting document, which was published in 2006 is available on the GRI’s website and is freely available to the public. This document lays the foundation for the metrics that an organization can use to measure and report on its economic, environmental and social impacts.

The technical guidelines, now in version 3.1, only provide the basic framework for reporting and are generally supplemented by sector supplements. These supplements are available for electric utilities, food processors, mining, and financial services, among others. Sector supplements are in the development process for several sectors including: airports, construction and telecommunications. (more…)

The Carbon Disclosure Project

1 Aug

The Carbon Disclosure Project (CDP) is a not-for-profit company created for collecting data on carbon emissions. The goal is then to have this data available for investors, who can use it when making financial decisions. At this time there are about 3,000 organizations involved in the CDP. Generally, the reports made the DCP are available to the public at the CDP’s website.

The CDP provides a consistent, global reporting framework. The advantages to this program are its comparability and credibility due to the amount of organizations participating. The major disadvantages of the program are its costs and the potential to disclose some of your company’s confidential business information. However, both of these drawbacks can be minimized. (more…)

Stephen Thorn joining Chicago-Kent as adjunct law professor

30 Jul

Stephen Thorn is joining the Chicago-Kent School of Law as an Adjunct Law Professor.  He will be teaching the Advanced Legal Writing: Environmental Law course.

Regulation of Hazardous Waste in Academic Laboratories

21 Jun

In December 2008, the EPA promulgated specific regulations that cover the hazardous waste used by academic laboratories. The regulations can be found at 40 CFR 262 Subpart K. These regulations provide alternative accumulation opportunities for qualifying entities. Specifically, the regulations exempt a qualifying institution from satellite accumulation area generator regulations. Under Subpart K, all wastes must be identified by a trained professional and must be removed every six months. In addition, the institution must create a Laboratory Management Plan, which describes its waste disposal policies.

Subpart K provides many potential advantages over the traditional RCRA scheme. For example, Subpart K provides labs with incentives to “clean-out” stockpiles of old chemicals by exempting these materials from the facility’s total generation of hazardous waste for purposes of determining generator quantity. (more…)

Stephen Thorn appointed to ISBA Environmental Section Council

18 Jun

Stephen Thorn has been appointed to the Environmental Law Section Council of the Illinois State Bar Association.  The Council evaluates and makes recommendations regarding existing and proposed legislation and regulations in the environmental law field.  The Council also monitors developments in the environmental law field and disseminates relevant information to other attorneys and business, industrial, government, and agricultural interests.

If you have any questions regarding the Council, contact us at 773-609-5320 or [email protected], or through our web contact form.

Disclaimer: This article cannot, and does not, create any attorney/client or consultant/client relationship.

Environmental Audits and Self-Disclosure: Two powerful tools to maintain compliance and avoid agency penalties

17 Jun

Too often companies believe they are in compliance with environmental regulations only to find out after an inspection that they had serious compliance problems and are now faced with large penalties and hefty legal bills.  Unfortunately, much like doctors, attorneys and environmental consultants are often consulted after a problem has arisen.  At that point, the primary option is damage control and not preventative maintenance.  Environmental audits, either comprehensive or taken over select statutes, amount to a check-up that is a cost-effective way of preventing environmental releases and government enforcement.


Household Waste Drop-off Points and One-day Collection Events Under the Illinois Environmental Protection Act

12 May

The purpose of 415 ILCS 5/22.55, Household Waste Drop-off Points, is to improve the collection of waste from households by diverting certain wastes from the general household waste stream. The act provides for collection centers that can be located at commercial establishments, as well as allowing for the collection of waste in one-day collection events. Both types of collection are discussed in this post.

The first major section of the act allows retail establishments to collect certain types of household wastes from their customers. A household waste drop-off point is defined as “the portion of a site or facility used solely for the receipt and temporary storage of household waste.” 415 ILCS 5/22.55(b). A drop-off point is limited to accepting “pharmaceutical products, personal care products, batteries other than lead-acid batteries, paints automotive fluids, compact fluorescent lightbulbs, mercury thermometers, and mercury thermostats.” 415 ILCS 5/22.55(c)(1). However, the types of waste collected must be the same as those sold, distributed or dispensed by the facility. 415 ILCS 5/22.55(c)(2). By way of example, (more…)

The Illinois Safe Pharmaceutical Disposal Act

11 May

On August 4, 2009, Illinois Governor Pat Quinn signed the Illinois Safe Pharmaceutical Disposal Act (the Act). The Act became effective on January 1, 2010 and is codified at 21 ILCS 150/ et seq. The act prohibits any healthcare institution from disposing of any unused medication into the public wastewater collection system or sewage system. 210 ILCS 150/10(a). All medical facilities are required to update their protocols for the disposal of unused medication. 210 ILCS 150/15.

Under the Act, “unused medications” is defined as “any unopened, expired, or excess medication that has been dispensed for patient or resident care and that is in a solid form.” 210 ILCS 150/10. These medications can be pills, tablets, capsules, and caplets. Id. Medication that is in fluid form, such as intravenous fluids, syringes or transdermal patches are not covered by the ban. Id. (more…)