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Regulatory (EH&S)

Dr. Howard Marks attending meeting with newly elected Members of Congress.NAPA advocates on behalf of its members before Federal agencies in the area of asphalt pavement manufacturing both at the plant and laydown operations. NAPA monitors potential regulatory issues from federal agencies that could affect the asphalt pavement industry and provides assistance to State Asphalt Pavement Associations on regulations at the state level. NAPA also acts as an information clearinghouse to assist members with specific environmental, health, and safety compliance concerns and questions. NAPA's Environmental Committee and Health and Safety Committee implements NAPA's regulatory policy priorities that affect the industry's day-to-day operations.

 

For the latest news and information about NAPA's regulatory efforts, visit the EH&S Regulatory Blog.

 

Please feel free to contact Dr. Howard Marks, Vice President – Environmental, Health & Safety with any questions or concerns with current or future regulatory issues. Dr. Marks is pictured (right) attending a meeting of newly elected Members of Congress.

 

Click here to access the Federal Reporting Compliance web site for Asphalt Pavement manufacturers on the "member-only" side of the NAPA website. This tracking of key regulatory issues enables members to stay ahead of the curve in a rapidly changing regulatory environment.

 

Spill Prevention, Control and Countermeasure (SPCC)

The U.S. EPA requires certain facilities to prepare a Spill Prevention, Control and Countermeasure (SPCC) plans to document how those facilities will protect surface waters from oil contamination in the event of an oil spill. Regulations that drive this program are found in Title 40 of the Federal Regulations Code, Part 112 (40 CFR 112). An SPCC Plan isn't a permit or approval, but instead is a Federal regulatory requirement for any facility with over 1,320 gallons of petroleum stored in aboveground tanks. Virtually every asphalt plant exceeds this threshold, and therefore needs an SPCC plan. Watch this space for a new NAPA publication on developing a good SPCC tank inspection and integrity testing program.

 

Click here to see a webinar on developing an SPCC plan for asphalt plant facilities.

 

Click here for a copy of NAPA’s new Spill Prevention, Control, & Countermeasures (SPCC) Plan and Stormwater Management Guidance Manual that will assist asphalt plant owners in complying with federal requirements.

 

Waters of the U.S. Definition

NAPA has joined with other trade associations to voice its concerns with a proposal that will have a huge impact on ordinary business activities by dramatically expanding federal authority over water and land uses across the country. Under the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers proposed rulemaking redefining “Waters of the United States” (WOTUS), federal control of land and water resources in the U.S would expand greatly triggering substantial additional permitting and regulatory requirements. NAPA is asking that the Agencies withdraw the proposed rule, and endeavor a more exacting and precise rule making effort that acknowledges the case-specific nature of designating jurisdiction under the Clean Water Act.

 

Community Relations

Communities in which asphalt mixing plants operate often have questions about what is stored onsite, what is emitted from the plant, and the safety of the materials produced. The industry has a long history of working with federal regulatory agencies including EPA and OSHA. Since the early 1990s, EPA has done extensive testing on asphalt plant emissions and in 2002, removed this industrial sector from the “major source” category – identifying that emissions from asphalt plants are not an area of concern. Indeed, these findings were reaffirmed in 2014 by EPA when the agency identified that asphalt plants are not sources of Hazardous Air Pollutants (HAPs). To help set the record straight about EH&S impacts from asphalt plants and products, the following information briefs are available:

 

Environmental Impacts of Asphalt Plants

Stockpile Leachate from RAP

Rap as Clean Fill

Cleaner Water with Asphalt

 

GHS Hazard Communications

OSHA has revised industry hazard communications guidelines to ensure compliance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Asphalt mix producers are required to ensure employees have the training necessary to understand and apply information in GHS-complaint warning labels and saftey data sheets (SDSs). Producers also must assess the need to develop and maintain SDSs for asphalt pavement mixtures. Click here for additional information and guidance.

 

Greenhouse Gas Calculator

NAPA has expanded its online Greenhouse Gas Calculator to help quantify the decrease in greenhouse gas emissions that accompany the increased use of recycled materials and warm-mix asphalt technology. The Greenhouse Gas Calculator complements other environmental life-cycle assessment (LCA) models, and is used by some companies and state departments of transportation to benchmark emissions of carbon dioxide equivalents (CO2e) generated while producing asphalt pavements. The NAPA Greenhouse Gas Calculator can be accessed at www.asphaltpavement.org/ghgc.

 

Work Zone Safety

The safe and efficient flow of traffic through work zones is a major concern for the asphalt pavement industry. That is why NAPA has played a key role in the development of the National Work Zone Safety Information Clearinghouse. The primary purpose of the Clearinghouse is to promote safety for workers, motorists, and facility owners and operators in roadway construction work zones. It is perhaps the largest online repository of work zone information. In addition, NAPA helped fund and develop the Roadway Safety Program, an online instructional program presenting an overview of common hazards in highway and road construction and simple prevention measures that may be taken at the work site. This program is free and available to the public.