Blog

24 Sep
BioForward Wisconsin: Profile on KTL

BioForward Wisconsin recently reached out to KTL to tell more of our story and to highlight how our company is helping to support the rapidly growing biotech/biohealth industry. Read our recent interview to learn more about KTL’s work with BioForward, its member companies, and the industry overall.

24 Sep
Staff Spotlight on Andy Smith

Get to know our KTL team! This month, we are catching up with KTL Senior Consultant and Partner Andy Smith.  Andy has over 10 years of experience providing project oversight, technical support, and IT solutions on a variety of EHS and engineering projects for a wide range of clients and industries. Andy is based out of our Madison, WI office.

Tell us a little bit about your background—what are your areas of expertise?

I started working at KTL in 2011, mainly to support a large data gathering and management project. From there, I managed to prove myself useful in other areas and stuck around. Since joining KTL, I’ve worked on a wide variety of projects and developed plenty of IT skills, including SharePoint development, GIS, statistics/data analysis, etc. My primary areas of expertise these days would be leveraging those IT skills on projects involving asset retirement obligations (AROs), EHS and regulatory compliance, and general project management.

What types of clients do you work with? What are the biggest issues you see them facing right now?

Most of my client work has been focused on the private sector, with the bulk of my current time spent with chemical manufacturing companies. However, I have also worked extensively with transportation and manufacturing companies.

Overall, the most common issue the clients I work with face is managing regulatory, environmental, and workplace safety risks while balancing the need to maintain and manage a productive company.

What would you say is a highlight of your job?

I enjoy working on a wide variety of projects and continuously improving the work KTL performs. Sometimes this will show up in doing a task more efficiently than we had in the past. Other times it might mean leveraging an IT platform like SharePoint or management system approach to make the work considerably more repeatable and manageable.

What do you like to do in your free time?

I bike a fair amount and play semi-convincing soccer regularly. Beyond that, my free time is consumed by books, random stuff, and hanging out with the cat.

Read Andy’s full bio.

23 Sep
Food Safety Consortium: KTL Presentation on How to Respond to Recalls

The Food Safety Consortium Fall Edition is kicking off this October with five weekly sessions featuring critical thinking topics that have been developed for both industry veterans and knowledgeable newcomers. KTL will be a featured presenter during the Recalls: Trends and Analysis episode on Thursday, October 14:

How to Respond to Recalls
Thursday, October 14
1:10 pm – 1:55 pm ET (includes Q&A)
Presented by KTL Senior Consultant Roberto Bellavia

22 Sep
Creating Sustainable Impacts Part 3: Sustainable Food Management

Wasted food makes up the largest percentage—over 20%—of any one material sent to landfills and incinerators each year in the U.S. This large volume of disposed food is a main contributor to total U.S. methane emissions, a greenhouse gas (GHG) with 21 times the warming potential of carbon dioxide. Financially, wasted food costs America more than $100 billion annually from disposal costs of municipal waste management, over-purchasing costs, and cost of lost energy. And all this wasted food is happening when nearly 40 million Americans are food insecure.

In short, wasting food impacts the sustainability of our economy, our society, and the environment—also known as the triple bottom line of sustainability. But through sustainable food management, it is possible to help businesses and consumers save money, create outlets for those in our communities who do not have enough to eat, and conserve resources for future generations.

 

Wasted Food and Food Loss

The U.S. Environmental Protection Agency (EPA) uses the term wasted food instead of food waste to describe food that is not used for its intended purpose. This terminology conveys the notion that a valuable resource is being squandered. The U.S. Department of Agriculture’s (USDA) Economic Research Service (ERS) further defines food loss as the “edible amount of food, postharvest, that is available for human consumption but is not consumed for any reason.”

Food loss occurs at every stage of the supply chain—from farm to table. How that loss is managed plays a vital role in how it impacts our society. That is where sustainable food management comes to play.

 

What Is Sustainable Food Management?

According to EPA, sustainable management of food is “a systematic approach that seeks to reduce wasted food and its associated impacts over the entire lifecycle, starting with the use of natural resources, manufacturing, sales, and consumption, and ending with decisions on recovery of final disposal.”

Sustainable food management is essentially a subset of sustainable materials management (SMM). As with SMM, the best approach to reducing food loss and waste is to not create it in the first place. Source reduction is the most effective way of reducing the environmental and financial impacts of wasted food and packaging because it prevents unneeded materials from ever being created. To do so is a process that involves performing a food waste assessment—much like an SMM lifecycle analysis (LCA)—to identify what and how much food (and food packaging) is being wasted.

A thorough food and packaging assessment serves as the foundation for reduction efforts. Having this general understanding can help identify appropriate strategies to avoid waste, cut down on disposal costs, reduce over-purchasing and labor costs, reduce water and energy use associated with food production, and reduce GHG emissions.

Based on the outcomes of the food waste assessment, EPA suggests some common strategies for reducing wasted food and packaging, which may include the following:

 

  • Adjusting food purchasing policies to reduce excess food purchasing (i.e., use just-in-time purchasing, purchase items in bulkfood-recovery-hierarchy to reduce packaging).
  • Storing and organizing food properly to reduce spoilage.
  • Repurposing leftover food following food safety guidelines.
  • Reducing to-go/takeout item packaging and using compostable/recyclable packaging.
  • Reducing portion size of regularly wasted items.
  • Using a system to identify over-purchased food items and to track wasted food.
  • Continuously training staff on basic steps to minimize food waste (e.g., cooking and food preparing to reduce wasted food, plating practices).

If excess food is unavoidable—and sometimes it is—reusing leftover food is possible as long as food safety guidelines are followed. The food can also be recovered to donate to hunger relief organizations to feed people in need. Even inedible food can be recycled into other products such as animal feed, compost and worm castings, bioenergy, bioplastics, and clothing. EPA’s Food Recovery Hierarchy identifies and prioritizes the actions organizations can take to prevent and divert wasted food. The top levels of the hierarchy are the most desirable alternatives because they create the most benefits for the environment, society, and the economy.

Part 4 of KTL’s series on Creating Sustainable Impacts will dive into some of the incentives and drivers for participating in sustainable food management.

 

21 Sep
Amendments to SQF V9: Effective October 4, 2021

In October 2020, the Safe Quality Food Institute (SQFI) published SQF Codes Edition 9 (SQF V9) as the most recent edition of the SQF Food Safety Codes. SQF V9 is comprised of 13 industry-specific codes that provide step-by-step instruction for production and manufacturing sites to become SQF certified. This certification is recognized by the Global Food Safety Initiative (GFSI) and showcases certified sites’ commitment to a culture of food safety and operational excellence in food safety management. Implementation of SQF V9 is effective as of May 24, 2021.

In August 2021, SQFI introduced four code amendments to this most recent edition. These amendments are required to be implemented along with applicable SQF V9 codes by October 4, 2021, and will be audited accordingly. A summary of the amendments is included below:

AreaDescriptionApplicability
Medical ScreeningRequires a medical screening procedure for all employees, visitors, and contractors who handle exposed product or food contact surfaces.Personnel Hygiene and Welfare, 3.3.1.1; 9.3.1.1; 10.4.1.1; 11.3.1.1; 12.4.1.1; 13.3.1.1; 17.3.1.1
Approved SuppliersRequires all approved and emergency suppliers to be registered and all registers to be complete, including supplier contact details.2.3.3 in the Primary Food Safety codes; 2.3.4 in all other codes except Storage and Distribution
Multi-site ProgramRequires sub-sites within an SQF multi-site program to operate in only the following food sector categories: 1, 2, 3, 4, 5 (primary) and 26 (storage and distribution).Appendix 4
Application of Agricultural ChemicalsRequires the code apply to the person applying chemicals, as well as the person making decisions on chemical application.7.7.3.2, 5.7.3.2, 8.7.3.2, 18.8.4.2

SQFI has a number of resources and guidance documents available to help ensure compliance with these amendments and the other requirements of SQF V9.

01 Sep
Preventing Lithium-ion Battery Fires

Lithium-ion batteries (LIBs) are powerful, relatively inexpensive, and lightweight energy sources that are used to power a vast assortment of electronics and portable tools. Given this, it is not surprising that the number of LIBs in circulation is continuing to increase at a near exponential rate with technology advances. Subsequently, the number of fires caused by LIBs in the waste management process is also on the rise.

The Risks of LIBs

Many in industry know firsthand the risks associated with LIBs in waste/recycling. LIBs have high energy density and are made from materials that make them more prone to combustion or explosion when they are damaged. This is attributed to “thermal runaway”, a reaction in which the battery unexpectedly releases its energy and begins self-heating. This reaction can produce enough heat to ignite materials near the battery, even if the battery itself does not ignite.

The Environmental Protection Agency (EPA) is really taking notice. In a recent report, An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling, EPA provides an evaluation of areas of risk associated with LIBs, as well as some excellent data and case studies of events that have occurred. The report discusses that physical damage to the LIB is one of the most common causes of thermal reaction and that much damage can occur at many different steps of the waste management system.

This information serves as a good reminder of just how risky and prevalent these batteries are—and how important it is to manage them appropriately. 

Mitigating Risk

While the EPA information is very good, the report doesn’t offer suggestions in how to improve operations and mitigate this type of risk—and it can be a very challenging risk to try to address.

KTL has staff with strong backgrounds working in recycling facility operations with hands-on experience developing strategies to minimize this risk. Solutions may be as simple as identifying and using special storage containers in designated areas, to as comprehensive as conducting onsite process evaluations to determine the best ways to segregate batteries and safely transfer them for further processing. 

KTL does not see this problem with LIB management going away any time soon—nor does EPA. We continue to explore alternatives and work with companies to mitigate risk to the extent possible. Please contact us if you are facing challenges with LIB recycling and management or would just like a fresh set of eyes to evaluate your current risk level. We can work together to make your company operations safer.

23 Aug
Staff Spotlight on Joseph Kunes

Get to know our KTL team! This month, we are catching up with KTL Consultant Joseph Kunes.  Joseph supports KTL’s information management projects, including Microsoft SharePoint®, dynaQ™, and other database applications. As an educator by training, he excels at guiding clients through technology implementation. Joseph is based out of St. Louis, Missouri. 

Tell us a little bit about your background—what are your areas of expertise?

I started my professional career as a French teacher and taught Middle School French in Milwaukee, Wisconsin before I joined KTL in 2012. My first project at KTL was performing some outreach work with the National Association of Chemical Distributors (NACD). At that time, KTL offered a dynaQ™ assessment/audit tool designed to help our clients establish and/or maintain compliance with NACD’s Responsible Distribution standard.

This initial assignment of providing dynaQ support to KTL’s chemical distribution clients, allowed me to start developing a greater skillset and deeper understanding of KTL’s database tools and the information technology (IT) side of developing them. As my technology skills have grown, my role at KTL has also changed and expanded over time. To this day, however, I continue to work directly to provide IT support on KTL projects (e.g., dynaQ, database applications, and SharePoint tools) and to maintain and grow our client relationships.

What types of clients do you work with? What are the biggest issues you see them facing right now?

I work with public and private clients across a number of sectors—most of which are focused on developing or improving environmental program management. Despite this diverse clientele, I continually see a universal challenge of staying organized enough to grow operational productivity while maintaining the various aspects of regulatory compliance. It is a difficult balance for many organizations to strike, particularly when so many are resource-constrained right now.

What would you say is a highlight of your job?

I take great pride in seeing the fruits of my labor evident in everyday life.  I am currently part of a team tasked with maintaining bridge and rail infrastructure, thus leading to the distribution of goods throughout the nation. In the past, I have worked with organizations to rebuild the electrical grid in the southeast and Puerto Rico after having been devastated by hurricanes. It’s rewarding to play a role on projects like that. I also truly enjoy the client satisfaction and appreciation we often experience once we have restored order to sometimes chaotic systems by setting up custom SharePoint sites with the appropriate tools tailored to suit the client’s needs.

What do you like to do in your free time?

I’m a man of simple pleasures—I enjoy good food and good drink in good company. I am also (and hope to soon be again) an avid traveler and enjoy exploring new places to take in the local fare.  I’m also a big fan of the arts—be it musical, performance, or material—as well as any cultural experiences.

Read Joseph’s full bio.

23 Aug
EPA Enforcement: Ammonia Refrigeration

Over the past several months, we have seen an uptick in Environmental Protection Agency (EPA) enforcement actions and large penalties for violations related to anhydrous ammonia storage, risk management, and chemical accident prevention planning. These include the following recent penalties:

Many of these violations have been uncovered as part of a National Compliance Initiative (NCI), which focuses on reducing risk to human health and the environment by decreasing the likelihood of accidental releases at facilities. According to EPA, there are approximately 150 catastrophic accidents each year at facilities that make, use, or store extremely hazardous substances (EHS). With ammonia refrigeration making up approximately 40% of the facilities with EHS regulated under the EPA’s Risk Management Program, these facilities have become a clear target for EPA.

Chemical Accident Prevention Program

Anhydrous ammonia is classified as an EHS that presents a significant health hazard if accidentally released. Anhydrous ammonia is corrosive to skin, eyes, and lungs. Exposure to 300 ppm is immediately dangerous to life and health. It is also flammable at concentrations of about 15-28% by volume in air.

To help refrigeration facilities comply with Clean Air Act (CAA) requirements and prevent accidents that could result in these significant hazards, EPA’s NCI is working to enforce the following regulatory aspects of the CAA’s Chemical Accident Prevention Program:

  • Risk Management Plan (RMP) regulations (40 CFR Part 68)
  • General Duty Clause (GDC) (CAA Section 112(r))
  • Emergency Planning and Community Right-to-Know Act (EPCRA) (CAA Section 312)
  • Process Safety Management (PSM) regulations (29 CFR 1910.119)

Risk Management Plan (RMP)

EPA’s RMP regulations require facilities that have more than a threshold quantity of certain regulated chemicals in a process (e.g., use or storage) to develop a Risk Management Program. CAA designates anhydrous ammonia as a regulated substance under RMP with a threshold quantity of 10,000 lbs.

Recent cases have demonstrated that refrigeration facilities may not be fully implementing RMPs, despite requirements. Facilities subject to RMP must:

  • Analyze the worst-case release scenario to determine the potential effects of a release.
  • Implement a prevention program that includes safety precautions, as well as maintenance, monitoring, and employee training.
  • Complete a five-year accident history.
  • Coordinate response actions with the local emergency response agencies through an Emergency Response Program.
  • Submit to EPA a written RMP that summarizes the Risk Management Program.

General Duty Clause (GDC)

The GDC requires that owners and operators of facilities with regulated substances and other EHS in any quantity ensure those chemicals are managed safely. Unlike RMP, GDC applies to many chemicals and applies facility-wide, regardless of the amount of chemical stored. Facilities are responsible for:

  • Identifying the hazards posed by chemicals and assessing impacts of possible releases.
  • Designing and maintaining a safe facility to prevent accidental release.
  • Minimizing the consequences of accidental releases that do occur.

The EPA NCI focuses specifically on the “identifying hazards” component of GDC, particularly at ammonia refrigeration facilities using 1,000 lbs. to 10,000 lbs. of anhydrous ammonia (i.e., those that fall below the RMP threshold).

Emergency Planning and Community Right-to-Know (EPCRA)

Section 312 of EPCRA requires facilities to report the presence of certain chemicals, including anhydrous ammonia, to Local Emergency Planning Committees (LEPCs) and response agencies. The purpose is to ensure emergency responders know what chemicals are onsite should they need to respond to an incident.

Any facility that is required to maintain Safety Data Sheets (SDS) for hazardous chemicals stored or used onsite must submit an annual Tier II inventory report for those chemicals. Tier II forms require basic facility identification information, employee contact information (emergency and non-emergency), information about chemicals stored/used at the facility, and additional data elements that would be useful to LEPCs and first responders.

Process Safety Management (PSM)

PSM regulations require facilities to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. While PSM is not an EPA regulation, the Occupational Health and Safety Administration’s (OSHA) program is closely related to EPA’s RMP program. RMP is intended to protect the environment and the community; PSM is an occupational health program intended to protect workers. Applicability thresholds differ for RMP and PSM for some chemicals; however, the PSM and RMP thresholds for anhydrous ammonia are the same—10,000 lbs.

PSM establishes a comprehensive management program made up of 14 elements. The process hazard analysis is the key provision of the standard, as it is intended to identify, evaluate, and control the hazards involved in the process.

Additional Enforcement Focused on Process Startup

In February 2021, EPA issued a new Enforcement Alert, “Risk of Chemical Accidents During Process Startup.” According to the alert, the U.S. Chemical Safety and Hazard Investigation Board (CSB) has noted that a disproportionate number of accidents occur during startup or other nonroutine operations.

Given this recent Alert, EPA cites that the following provisions of the RMP regulations are particularly important to prevent accidents during process startup:

  • Operating procedures that provide clear instructions for safely conducting activities involved in each covered process.
  • Training so each employee involved in operating a process is familiar with operating procedures, safety and health hazards, emergency operations, and safe work practices.
  • Pre-startup review to ensure construction and equipment is functioning according to design specifications and that safety, operating, maintenance, and emergency procedures are in and place and adequate.

Avoiding Enforcement: Hazard Analysis

As part of the NCI, EPA has been sending Information Requests to select facilities that it believes may be out of compliance with GDC. Again, the primary focus of those Information Requests includes those facilities with 1,000 lbs. to 10,000 lbs. of anhydrous ammonia onsite. Facilities are required to answer four questions about their ammonia refrigeration systems, including whether they have performed a process hazard review.

EPA is focusing heavily on the first duty of the GDC (i.e., hazard review) as it evaluates facilities for violations. An EPA Enforcement Alert on anhydrous ammonia at refrigeration facilities from February 2015 reinforces that identifying the hazards of a facility’s refrigeration systems is crucial to accident prevention and compliance. This involves identifying and inventorying every chemical onsite, understanding the associated hazards of each chemical, and making sure employees and local responders know what to do in case of an accident. Part of this analysis should also include addressing potential gaps between new industry codes and standards and the standards to which the facility was built (e.g., facility upgrades).

If your facility uses anhydrous ammonia and you have not conducted a hazard analysis, you are at significant risk of incurring enforcement actions of fines. It is important you invest the time and resources required to:

  • Understand the hazards posed by chemicals at the facility.
  • Assess the impacts of a potential release.
  • Design and maintain a safe facility to prevent accidental releases.
  • Coordinate with local emergency responders.
  • Minimize the consequences of accidental releases that do occur.

KTL has experience working with a broad cross-section of industries impacted by PSM, RMP, GDC, and EPCRA, particularly chemical and food processing companies. We have created RMP and GDC audit protocols, conducted audits, and implemented investigation/improvement programs following significant release events. In addition, our team provides Tier II and TRI reporting, writes plans for OSHA and Emergency Response, and routinely works with LEPCs to coordinate emergency response efforts and exercises to keep communities informed and safe. Our team has helped many companies keep operations safe and compliant—and avoid EPA enforcement.

 

18 Aug
EPA Guidance on Hazardous Waste Incineration Backlog

Last month, KTL published an article on the national incinerator slowdown many Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) are experiencing firsthand right now. We included some guidance for facilities being adversely impacted by the current backlog on how to proactively manage this situation based on KTL’s conversations with EPA and waste management companies.

On August 10, 2021, the U.S. Environmental Protection Agency (EPA) Office of Resource Conservation and Recovery (ORCR) issued a formal memorandum in response to the national incinerator backlog for containerized hazardous waste. The memo states that as of late July 2021, EPA has heard from over 20 states that they have received requests from hazardous waste generators for extensions to the accumulation time limit (i.e., 90 days for LQGs and 180 days for SQGs*)—and some states have begun receiving requests for second extensions.

The Agency also predicts that this backlog may not fully resolve until the end of the first quarter of 2022 due to a number of factors, including the following:

  • Labor shortages resulting from COVID-19 that are impacting transportation and incinerators.
  • Shutdowns for scheduled and unscheduled maintenance, as well as from winter storms in the southern U.S.
  • Increased manufacturing and resulting hazardous waste generation as the economy recovers from the pandemic.

The EPA memo goes on to explain multiple existing regulatory options for various regulated entities that generate and manage hazardous waste to address the backlog. These options are primarily focused on providing storage extensions for LQGs and SQGs and granting permit authorization for increased storage capacity at RCRA-permitted transportation, storage, and disposal facilities (TSDFs). These are intended to be temporary solutions to help ensure hazardous waste continues to be safely managed during this unusual circumstance.

KTL remains engaged with EPA and numerous hazardous waste disposal vendors to carefully monitor the incinerator backlog situation. We understand the challenges facilities are facing and can help navigate the regulatory environment and implement one of the recommended storage extension strategies to keep facilities in compliance. 

* Or 270 days for SQGs if the waste must be transported 200 miles or more.

17 Aug
Hand Sanitizer Disposal

Early in the COVID-19 pandemic, many of our nation’s distilleries and ethanol plants began producing ethanol-based hand sanitizer to meet global demands. Many of these sanitizers are 60% or greater ethanol content (greater than 24% alcohol), have a flashpoint below 140 F, and must be coded as D001 hazardous waste if disposed. 

Some of these hand sanitizers are going unused due to their odor, over-procurement, and other issues. This excess hand sanitizer has created some concern from various regulatory entities, including the U.S. Department of Agriculture (USDA) and Environmental Protection Agency (EPA), on compliance issues regarding the safe handling and disposal of hand sanitizer.

In response, EPA issued guidance in a June 24, 2021, letter to the USDA addressing considerations and requirements for appropriate hand sanitizer disposal. According to the memo, “…when recycled, hand sanitizer is exempt from hazardous waste regulations and does not have to ship on a Uniform Hazardous Waste Manifest. If not recycled, the disposal of alcohol-based hand sanitizers requires full cradle-to-grave management, including (but not limited to) hazardous waste notification, hazardous waste labeling, manifesting, and waste reporting to the state or the federal government.”

These requirements provide an idea of just how robust the penalties for improper (i.e., “down-the-drain”) disposal would likely be. Facilities may want to try returning the sanitizer to the manufacturer as an easy first step or continue using it for its “intended purpose,” if possible. Alternatively, KTL has the in-house expertise to identify options for hazardous waste management and/or reuse of resources that can help facilities manage excess hand sanitizer or excess hazardous waste. We are currently working to identify alternative end-use destinations for hand sanitizer, including reverse distribution or other entities that may have a use for such products.   

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