Environmental Laws
Federal environmental statutes
The CSHM exam expects working knowledge of major laws and reporting triggers:
- Clean Air Act: permits, NSPS/NESHAP, refrigerant rules.
- Clean Water Act: NPDES permits, stormwater pollution prevention, SPCC for oil.
- RCRA: hazardous waste cradle-to-grave - generator status, manifest, storage limits, land disposal restrictions.
- CERCLA: release reporting and cleanup liability.
- EPCRA: emergency planning, Tier II inventory, TRI Form R.
- TSCA: chemical inventory and new-chemical review.
- SDWA and NEPA for drinking water and major federal actions.
Worked example
A 55-gallon drum of solvent leaks; 30 gallons reach a floor drain. The safety manager must stop the release, notify the state and National Response Center if the release exceeds the CERCLA reportable quantity, and make EPCRA emergency notifications. The spill also triggers RCRA cleanup and possibly a hazardous waste determination. Reporting is not deferred because the material stayed onsite.
Traps
Assuming a release is reportable only if it leaves the site; confusing RCRA waste rules with CERCLA release reporting; missing annual Tier II/TRI deadlines; overlooking state and local requirements; and treating a permit as a one-time approval rather than an ongoing obligation.