News and Analysis
According to Ohio EPA: “Life Cycle Assessment (LCA) is a tool to assign a value to the environmental impact of a product, process or activity through its entire life cycle. Organizations can use it to help label their products or services and educate consumers about their environmental impacts. LCA can also help organizations strategically plan and design products with less environmental impact.
“LCA analyzes the impact of the product from cradle to grave or until it becomes a feedstock for another product. It reviews a product or service, including the energy and material inputs and outputs, accounting for material wastes, recycling and reuse. Even completing a partial LCA can provide a company insight on opportunities to improve a product or service.”
Read more here. 12/18/2017
On December, 8, 2017 Ohio EPA adopted Ohio-specific universal waste rules allowing hazardous non-empty aerosol containers, hazardous antifreeze, hazardous paint and hazardous paint-related wastes to be classified and managed as universal waste.
The OMA successfully led the effort for this major change. The rules become effective on December 21, 2017. A final copy of the rules are posted on the Division of Environmental Response and Revitalization website.
The new Ohio-specific universal wastes will be subject to provisions that are tailored to address the risks the wastes may pose. The requirements include: labeling, tank and container standards, limited treatment provisions, accumulation time limits, employee training, emergency response and transportation according to U.S. Department of Transportation rules.
Also, universal wastes do not count towards a generator’s monthly hazardous waste accumulation rate and they are not required to be manifested as a hazardous waste in Ohio or reported on the generator’s hazardous waste biennial report.
Congratulations to the OMA members who led this successful effort! 12/14/2017
Just prior to the Thanksgiving holiday, the Ohio Lake Erie Commission announced it had completed its revision of the Ohio Domestic Action Plan (DAP) 1.0 to reduce phosphorus entering Lake Erie under the binational Great Lakes Water Quality Agreement with a goal of reducing phosphorus loading to Lake Erie by 40% by 2025.
This version of the Ohio DAP will be submitted to U.S. EPA for review and comment and to serve as Ohio’s part of the U.S. Domestic Action Plan, the final version of which is due in Feb. 2018.
The OMA had met with top leaders of Ohio EPA to oppose the agency’s decision to confine – through legislative mandate – all permitted water dischargers to a 1.0 mg/L monthly average phosphorus limit.
In the revised DAP 1.0 the language has been changed to “Ohio EPA will evaluate possible legislation that will limit all treatment works discharging waste water containing phosphorus to achieve at least a monthly average effluent concentration of 1 mg/L phosphorus unless alternative limits or conditions are deemed appropriate by the Director.”
While not totally eliminating the possibility of legislative action, the change in tone is good news for manufacturers that would be impacted either directly or indirectly through new regulation. 11/30/2017
According to Donald Elswick, CIH, CSP, CHMM, CET, an Ohio safety professional who consults to manufacturers: “The new U.S. OSHA Final Rule on Respirable Crystalline Silica sets a lower permissible exposure level (PEL) of 50 μg/m3 for all industries covered by the rule, adopts the more conservative ISO/CEN criteria of a 4-um cut-point for respirable dust samplers, and allows any sampler conforming to ISO 7708/CEN criteria to be used.”
In this short whitepaper, Elswick discusses the utility of Parallel Particle Impactor (PPI) respirable dust samplers in providing objective data to measure the new action level of 25 μg/m3, calculated as an 8-hour total weight average (TWA).
Exposures at or above the action level will trigger requirements for exposure assessment, should the rule take effect as scheduled on June 23, 2018. 11/30/2017
The Ohio EPA’s Materials Marketplace is a free online platform allowing businesses and organizations to connect and find reuse and recycling solutions for waste and by-product materials.
New materials are being added all the time.
Here’s a short webinar about the marketplace. 11/13/2017
This week a large group of OMA member companies met with leaders of Ohio EPA including Assistant Director, Laura Factor, Deputy Director for Water Resources, Karl Gebhardt, and Division of Surface Water Chief, Tiffani Kavalec, to discuss the agency’s Draft Action Plan for Lake Erie.
A primary concern of manufacturers is the agency’s decision to confine – through legislative mandate – all permitted water dischargers to a 1.0 mg/L monthly average phosphorus limit. Not only will this proposal have a negative impact on Ohio’s direct discharging manufacturers, but it will also negatively impact indirect manufacturer dischargers who may be penalized by their local publicly owned treatment works which must also follow this proposed mandate.
OMA previously submitted comments on the Draft Action Plan and will continue to work with members and allies to amend the proposal’s onerous phosphorus limit. If you are interested in engaging on the issue or learning more, contact OMA’s Rob Brundrett. 11/9/2018
Together with dozens of organizations, OMA signed a letter to Senate Majority Leader Mitch McConnell and Senate Democratic Leader Chuck Schumer urging the Senate to fill vacancies in U.S. EPA leadership.
The groups wrote: “… more than nine months into the new Administration, the EPA lacks Senate-confirmed Deputy and Assistant Administrators to carry out this mission. The EPA’s activities have a significant impact on each of our industries, the products we make or the services we provide, and the tens of millions of workers we represent. It is therefore of significant importance to our groups that EPA is appropriately and fully staffed. This holds especially true for individuals in key leadership positions.”
Here is the letter; it contains the slate of nominees the groups ask the Senate to confirm. 11/9/2017
This week, OMA member ArcelorMittal hosted the OMA Environment Committee at its Cleveland facility.
Members heard updates about U.S. EPA activity through the first nine months of the Trump Administration from Ross Eisenberg, Vice President, Energy and Resources Policy, The National Association of Manufacturers, and John Rego, Partner, Jones Day.
Other topics included Ohio’s new beneficial use program, Storm Water General Permit provisions dealing with benchmark exceedances, and Lake Erie Commission’s Ohio Domestic Action Plan 2018.
Following the meeting, members were treated to a tour of the facility, which is one of the most productive integrated steel making facilities in the world.
Members have requested more OMA regional meetings, and this was an effort towards that end. Join the OMA Environment Committee here; use your My OMA login.10/26/2017
In response to members’ requests for meetings to be held around the state, the OMA Environment Committee will meet in Cleveland on October 26.
The meeting will be held at the ArcelorMittal Media Center, from 10:00 a.m. to 1:00 p.m., and includes lunch.
Following the meeting there will be a tour of the facility. Tour spots are limited to 30 so please register as soon as possible. This facility is home to one of the most productive integrated steel making facilities in the world.
The committee will cover:
- Updates on Ohio’s new beneficial use program
- Fall 2017 legislative and regulatory overview
- An update on the Storm Water General Permit provisions dealing with benchmark exceedances and how these might impact your operations
- Lake Erie Commissions Ohio Domestic Action Plan 2018: impacts on Ohio manufacturing
All members are welcome. Register here. 10/12/2017
Ohio EPA has issued an Early Stakeholder Outreach (ESO) concerning the potential to develop an Ohio-specific rule to conditionally exclude hazardous waste contaminated textile products that are not currently excluded under the solvent wipe rule. It would include gloves, aprons, smocks and uniforms that are laundered and returned to service.
Comments are due by November 3, 2017. Please contact OMA’s Rob Brundrett with questions or comments. 10/12/2017