U.S. EPA’s Updated 2024 Interim Guidance on the Destruction and Disposal of PFAS

On April 8, 2024, the U.S. Environmental Protection Agency (U.S. EPA) issued an updated interim guidance for public comment on the destruction and disposal of per and polyfluoroalkyl substances (PFAS) and PFAS-containing materials.

U.S. EPA published the first edition of this guidance in December 2020 as required by the National Defense Authorization Act for Fiscal Year 2020 (FY20 NDAA), which was previously covered by ALL4. The FY20 NDAA directed U.S. EPA to address the destruction and disposal of PFAS and specific PFAS-containing materials and requires U.S. EPA to review and update the guidance as appropriate, but no less frequently than every three years. The six PFAS-containing materials covered under this guidance are:

1 ) Aqueous film-forming foam (AFFF)

2) Soil and biosolids

3) Textiles, other than consumer goods, treated with PFAS

4) Spent filters, membranes, resins, granular carbon, and waste from water treatment

5) Landfill leachate containing PFAS

6) Solid, liquid, or gas waste streams containing PFAS from facilities manufacturing or using PFAS

The guidance includes destruction and disposal technologies from both existing, publicly available information, as well as research and development that is currently in progress. You can read the full 2024 updated interim guidance document here, but an overview of updates is below. Consistent with the 2020 guidance document, it is important to note that this guidance does not represent an enforceable rule or policy.

Interim Storage with Controls

U.S. EPA identified interim storage (two to five years) as an option in the 2020 guidance document for scenarios where immediate destruction or disposal is not imperative. In the 2024 guidance document, interim storage is still provided as a short-term option, however U.S. EPA has added that proper controls must be in place to reduce release and recommends that this option only be utilized for low volumes of containerized or high-concentration materials. Interim storage is not a suitable option for continuously generated materials.

Underground Injection – Permitted Class I non-hazardous industrial or hazardous waste injection wells

Underground injection was identified as a long-standing, well-regulated disposal technology in the 2020 guidance document which is suitable for liquid PFAS wastes. This has not changed with the 2024 guidance document, and underground injection is identified as having a lower potential for environmental release when compared to other destruction and disposal options as these wells may help ensure that injected fluids are confined and cannot enter underground sources of drinking water.

However, a downside identified in 2020, which still exists in 2024, is the lack of commercial hazardous waste injection wells in the United States. The limited number of wells currently receiving off-site PFAS and waste transportation logistics may significantly limit the type and quantity of PFAS-containing fluids appropriate for underground injection, and result in higher costs.

Approximately 17 percent of Class I wells are hazardous waste disposal wells. Most Class I hazardous waste wells are located at industrial facilities and dispose of waste generated onsite. These wells are operated in 10 states with the majority in Texas and Louisiana. Only a few commercial Class I wells accept hazardous waste generated offsite. The Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA) added significant restrictions on the disposal of hazardous waste. Under these amendments, land disposal of hazardous wastes, which includes Class I hazardous waste injection wells, is prohibited unless the:

• Waste has been treated to become non-hazardous or;
• Disposer can demonstrate that the waste will remain where it has been placed for as long as it remains hazardous, which has been defined as 10,000 years by regulation.

Landfills

A key concern when considering landfills for PFAS disposal is the ability to minimize or mitigate PFAS migration, either through leachate or volatilization in landfill gas. This is especially a challenge given the variability in control requirements different landfills are subject to (e.g., hazardous waste landfills vs. municipal solid waste landfills). The 2024 guidance document provides more information regarding specific scenarios and landfill types that U.S. EPA recommends. For example, U.S. EPA recommends Subtitle C landfills when PFAS levels of the waste are relatively high, those of which lead to a hazardous waste leachate PFAS concentration range of up to 377,000 ng/L. This is because RCRA Subtitle C hazardous waste landfills have the most protective landfill engineering controls and practices for the containment of PFAS waste and would be more effective at minimizing PFAS release into the environment than other landfill types. Hazardous waste landfills also typically have relatively low quantities of landfill leachate, which also reduces risks of release.

Similarly, U.S. EPA states that non-RCRA Subtitle C landfills are only appropriate when disposing of stable polymeric PFAS, such as polytetrafluoroethylene (PTFE), because they are not susceptible to hydrolysis or oxidation, and they are neither volatile nor water soluble. Therefore, the risk of release through leachate or landfill gas is low, even if the landfill does not have the same level of controls as a hazardous waste landfill.

However, for all landfill types, current information demonstrates landfilling could have higher PFAS releases to the environment than previously thought in 2020, especially for soluble PFAS that are prone to migration.

Thermal Treatment

The technologies evaluated under thermal treatment are hazardous waste combustors, such as commercial incinerators, cement kilns, lightweight aggregate kilns, and thermal oxidizers, as well as granular activated carbon (GAC) reactivation units with off-gas incineration and gas scrubbing units. In general, due to the lack of limited research and full-scale test data, there is still uncertainty regarding the effectiveness of this technology and the formation of alternate forms of PFAS as products of incomplete combustion. However, U.S. EPA believes that operation at higher temperatures (>1,100°C), well mixed combustion environments, and longer residence times may be more conducive to destroying PFAS and controlling related products of incomplete combustion. Thermal treatment is still considered a viable option for PFAS destruction, but more testing is required.

Emerging Technologies

U.S. EPA conducted a study of the effectiveness of four emerging technologies for PFAS destruction:

1) Mechanochemical degradation

2) Electrochemical oxidation

3) Gasification and pyrolysis

4) Supercritical water oxidation

Although the 2024 guidance document notes that the evaluation of these emerging technologies should not be considered an endorsement or recommendation by U.S. EPA, these technologies all showed promise during the conducted pilot studies as they each exhibited PFAS destruction, minimal to no hazardous residuals or byproducts, commercially available, and can be cost-effective. Pilot studies were conducted using contaminated soil/sand, biosolids, and AFFF.

While there are still many unknowns regarding disposal and destruction techniques for PFAS, it is becoming more difficult to find locations willing and able to manage the waste. U.S. EPA did not contemplate additional demand to send PFAS off to Hazardous Waste facilities for disposal. The capacity assessment in 2019 said there is adequate capacity nationwide through 2044, and a new assessment is currently underway to incorporate new information and extend the time horizon. ALL4 is available to assist in the evaluation and strategy for disposing or treating of PFAS-containing materials at your site. If you have any questions, please contact me at xaguilar@all4inc.com or reach out to one of our project managers.

Proposed Amendments to Air Toxics Standards for NESHAP EEE – Hazardous Waste Combustors

The U.S. Environmental Protection Agency (U.S. EPA) proposed revisions to the National Emission Standards for Hazardous Air Pollutants (NESHAP) from Hazardous Waste Combustors (HWC) (40 CFR Part 63, Subpart EEE) in the Federal Register on July 3, 2024. The HWC NESHAP regulates Hazardous Air Pollution (HAP) emissions from hazardous waste burning incinerators, cement kilns, lightweight aggregate kilns, industrial/commercial/institutional boilers and process heaters, and hydrochloric acid production furnaces.

The proposed changes to the rule include:

• Removal of emissions standards exemptions for periods of malfunction (as described in existing startup, shutdown, and malfunction (SSM) plans),
• Removal of the Emergency Safety Vent (ESV) Plan from NESHAP 40 CFR Part 63, Subpart EEE (Subpart EEE) requirements,
• Requirement of electronic submittal of certain reports (within 90 days of rule becoming final), and
• Other minor revisions.

Note that this is the first of two regulatory actions we’re expecting from U.S. EPA on this rule. The second will be their proposed technology review of Subpart EEE, which is overdue, that will address whether alternate standards during periods of startup and shutdown are needed.

Revised NESHAP EEE

The most significant proposed change to the NESHAP is the removal of exemptions for malfunctions and emergency safety valve (ESV) releases as described under a facility’s SSMP and ESV operating plan. Facilities will be required to revise their SSMP to remove the malfunction exemptions from the plan. The proposed rule removes the language that states that automatic waste feed cutoff requirements continue to apply during a malfunction as long as corrective measures are taken as per the SSMP. Therefore, any malfunction that occurs outside of startup or shutdown periods would no longer be excused from being a violation of the standards in the rule. The requirement to develop and implement an ESV operating plan has been removed. An ESV event already requires an investigation to be conducted on the ESV event to determine whether any exceedances of emissions standards occurred. As written, an exceedance of the emissions standards monitored by a continuous emissions monitoring systems (CEMS) or COMS is not a violation of the NESHAP if corrective actions are taken as described in the SSM plan. The proposed rule removes “malfunctions” from these allowances; therefore, all exceedances due to malfunctions would be violations of the rule. U.S. EPA is proposing to add a “general duty” clause to Subpart EEE that reflects the general duty to minimize emissions while eliminating the reference to periods covered by a malfunction exemption.

With the elimination of the exemption for periods of malfunction, units would be subject to an emissions standard during openings of ESV that occur outside of periods of startup and shutdown. U.S. EPA states that the intent of this change is to ensure that sources have ample incentive to plan for and achieve compliance and thus ESV operating plans are no longer necessary. The contents of the report required when a source fails to meet an applicable standard are also proposed to be updated so the agency can determine the extent of the failure and how a source met the general duty clause.

U.S. EPA is also proposing that facilities submit electronic copies of the required notices of intent to comply (NIC), notifications of compliance (NOC), notifications of changes that may adversely affect compliance, compliance progress reports, excessive emissions and continuous monitoring system performance reports and summary reports, performance test reports, performance evaluation reports, and periodic SSM reports through the U.S. EPA’s Central Data Exchange (CDX) using the Compliance and Emissions Data Reporting Interface (CEDRI). Additionally, the proposed rule requires the owner or operator to submit performance evaluation results of CEMS measuring relative accuracy test audit (RATA) pollutants that are supported by the ERT at the time of the test in the format generated through the use of the ERT or an electronic file consistent with the xml schema on the ERT website, and it requires that the owner or operator submit other performance evaluation results in PDF using the attachment module of the ERT.

Additionally, U.S. EPA is proposing a technical correction to the NESHAP to remove the requirement to receive Administrator approval to use EPA Method 23 in compliance demonstrations for dioxins and furans.

Timing and Impacts

Comments on the proposed rule must be received before September 24, 2024. U.S. EPA has identified 177 HWCs subject to this NESHAP. They do not expect any impact to air quality from these proposed rule changes and the estimated costs to comply are minimal. The addition of electronic reporting provisions, amendments to the ESV provisions, and correction of inadvertent errors do not affect the stringency of the standards in Subpart EEE but will make data more accessible to U.S. EPA and the public. U.S. EPA is proposing to allow 180 days from the date of the final rule for compliance with all requirements except for the requirement to submit performance test reports and performance evaluation reports electronically (90 days) and the technical correction (effective immediately upon promulgation of the final rule).

Summary

The proposed revisions to Subpart EEE will increase compliance burden to the affected facilities with no expected benefit to the environment. The electronic reporting requirements are intended to streamline reporting procedures but can have a steep learning curve and can be cumbersome to utilize properly. The removal of malfunction exemptions from the rule will complicate monitoring, recordkeeping, and general compliance for facilities. If you have questions on the revised rules or need assistance with planning for and implementing these new requirements, ALL4 can help you develop and implement a compliance strategy, design a stack testing program, and collect and submit data and reports. Reach out to either your ALL4 Project Manager or Brian Goldman at bgoldman@all4inc.com for assistance with these new requirements.

Pennsylvania “SPEED” Permitting

Businesses in Pennsylvania have long lamented about the time it takes to receive permits from the Pennsylvania Department of Environmental Protection (PADEP). Over the years, different administrations have attempted to address this issue. For example, several years ago PADEP launched a Permit Decision Guarantee Program with mixed results.

The newest attempt at “Permit Modernization” is being launched by Governor Josh Shapiro. This program is called the Streamlining Permits for Economic Expansion and Development (SPEED). For the first time in many years PADEP intends to use “DEP-verified qualified contractors” to review certain permit applications and to provide recommendations to PADEP for action on those applications. Details on exactly how the program will work will be posted soon. Importantly, SPEED will only be for these specific types of permit applications:

• Air quality plan approvals at State-only facilities
• Earth disturbance permits (PADEP has started a pilot program in 10 counties)
• Individual water obstruction and encroachment permits
• Dam safety permits

Along with SPEED, PADEP will continue to follow the current money back guarantee program known as PAback. This program is designed to return application fees if PADEP fails to issue the permit within the prescribed PAback timelines. Of course, getting a refund on the application fee is often little solace to industry if the permit is not issued in a timely manner and delays capital projects.

The Governor’s program also includes investments to update the Commonwealth’s information technology infrastructure, including PADEP’s electronic application submittal systems and its general website. There is also mention of “improved transparency” regarding permitting for members of the community, which could include online posting of permit applications that are under review for the general public to view. Currently, there is little detail on how this will work. Lastly, PADEP has launched a Permit Application Consulting Tool that is designed to collect information that will be useful for a pre-application conference.

ALL4 has extensive experience with environmental permitting in Pennsylvania and stands ready to assist clients with navigating the labyrinth of permitting requirements. Please contact John Slade or Bob Kuklentz for your PA air permitting needs.

Louisiana Carbon Capture and Storage Updates

Before closing the 2024 regular session, the Louisiana Legislature passed five Carbon Capture & Storage (CCS) house bills (HB): HB 966, HB 492, HB 937, HB 516, and HB 934, though HB 934 was subsequently vetoed by Governor Jeff Landry. Effective on August 1^st, 2024, the remaining 4 bills clarify the legal framework regarding CCS projects. This includes procedures for acquiring eminent domain of land, authority for unitization of CCS reservoirs, and establishing liability of property owners over CCS reservoirs. Additionally, the bills include procedures for revenue sharing for CCS projects and establish responsibility for the facilities to make plans in the case of an emergency. The changes are as follows:

HB 966-Energy/Conservation: Authorizes unitization for carbon dioxide sequestration

HB 966 provides the authority for unitization of CCS reservoirs, in which operators may combine or pool separately owned tracts of land to create geologic storage for CCS reservoirs. After the application of a CCS operator, the Commissioner of Conservation will ensure that the proposed reservoir meets the requirements of present law, has a defined area that is reasonable, and at least three-fourths of the landowners of interest (in proportion to land ownership) have consented in writing to unitization of their property. Additionally, HB 966 requires operators to provide equitable compensation to all landowners affected by unitization, including those who did not consent in writing to geologic storage. The basis for equal sharing of benefits, or compensation, is to be determined by the commissioner but may be based on the impact on the land, the scope of the damage to the land, and the cost of the unit operation. Unitization allows for larger tracks of geologic storage for carbon capture with little to no impact to the landowner. HB 966 marks an important step in Louisiana law towards curbing greenhouse gas emissions and mitigating climate change through CCS projects.

HB 492-Property/Expropriation: Provides relative to eminent domain

HB 492 clarifies the rights for landowners as related to eminent domain and establishes a procedure for operators to acquire private land via eminent domain to facilitate pipelines. Eminent domain, or governmental acquisition of private land for public use, may be acquired for the operator through the Louisiana Department of Energy and Natural Resources, Office of Conservation (DENR). This clarification of eminent domain significantly reduces obstacles surrounding carbon dioxide transportation, as eminent domain was unclear and difficult to obtain prior to HB 492. Additionally, HB 492 removes existing eminent domain authority for storage operators and replaces it with unitization as outlined in HB 966.

HB 937-Energy/Conservation: Provides protection from landowner liability for carbon dioxide sequestration

HB 937 establishes that landowners are not to be held liable for any duties or obligations related to CCS projects on their property even if they have agreed to allow the storage operator to use the property for sequestration. Instead, the storage operator is held liable for complying with the regulations of CCS reservoirs. For example, HB 937 changes the responsible party for installation and monitoring equipment from interested persons to the storage operators. HB 937, however, does not supersede the terms of any contractual agreements entered into by a landowner, meaning that landowners may be held liable if a contractual agreement with the operator overrides HB 937. By protecting landowners from duties or obligations surrounding CCS reservoirs, HB 937 aims to ensure that storage operators are held responsible for CCS projects and their potential impacts.

HB 516-Energy/Conservation: Enacts carbon dioxide sequestration emergency response requirements for CCS reservoirs

HB 516 requires operators to issue a semi-annual groundwater monitoring report to protect drinking water for areas surrounding the CCS reservoir. Additionally, HB 516 requires operators to have additional emergency and remedial response plans for the storage facility. This includes requiring operators to have recorded emergency response plans prior to injection and continuing training after injection. Moreover, HB 516 requires the operator to conduct discussion-based exercises on emergency plans in compliance with appropriate emergency preparedness and response agencies. HB 516 aims to protect communities from any possible impacts of CCS reservoirs and enacts response requirements in the case of an emergency, further ensuring the safety of any interested persons.

HB 934-Energy/Conservation: Provides for the dedication of revenue from carbon dioxide sequestration on state lands and water bottoms – Vetoed by Governor Jeff Landry on June 19, 2024

HB 934 would have corrected the interpretation of HB 571 which established revenue sharing on CCS projects that impact state lands. HB 571 was previously interpreted to exclude revenue sharing by local government from CCS projects if the project extended beyond a Parish boundary. HB 934 clarified that 30% of revenue from CCS projects are to be directed towards parishes included in the agreement, including property owned and operated by Louisiana Department of Wildlife and Fisheries. Although HB 934 was vetoed by Governor Landry on procedural grounds: changes in constitutionally dedicated funds cannot be altered by statute in Louisiana, the Governor stated in the veto letter that he is committed to working on similar future legislation to remit revenue to local governments.

Questions?

The various changes in the Louisiana law represent a positive step towards the implementation of CCS technologies and allows the public to be involved in the various steps of the process.

If you have questions or concerns regarding the CCS changes, please contact your ALL4 Project Manager or Andrew Hebert at ahebert@all4inc.com to learn how the changes may affect you or your facility.

Decoding the New PFAS TSCA Reporting Rule: Navigating Compliance and Industry Impact

Update: On May 12, 2025, U.S. EPA announced an interim final rule to further delay the reporting period for this rule. The original reporting window was scheduled to begin on November 12, 2024 and last through May 8, 2025, and was later extended to begin on July 11, 2025 and last through January 22, 2026. However, this new interim rule changes the reporting window to now begin on April 13, 2026 and last through October 13, 2026.”

Understanding the New PFAS TSCA Reporting Rule

The United States Environmental Protection Agency (U.S. EPA) has unveiled a new one-time reporting rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) focused on per- and polyfluoroalkyl substances (PFAS). Finalized in October 2023, this rule mandates that manufacturers and importers of PFAS submit comprehensive reports detailing their PFAS activities since 2011. The reporting period begins in November 2024.

Background on TSCA and PFAS Regulations

The TSCA, established in 1976, empowers U.S. EPA to oversee chemicals and mandate reporting, record keeping, and testing. Over the years, TSCA has evolved to address emerging chemical concerns, notably the regulation of PFAS due to their persistence and potential health risks.

Known for their durability and resistance to water, grease, and stains, PFAS are used in a wide array of products, including firefighting foams, textile coatings, electronics, and even household items like cookware and toys. The new rule under TSCA Section 8(a)(7) is part of a broader effort to build a comprehensive PFAS database to better understand their presence in commerce and address potential exposure and contamination risks.

The One-Time PFAS Reporting Rule

What is the Rule?

The new rule requires any entity that has manufactured or imported PFAS or PFAS-containing articles to report detailed information on those PFAS to U.S. EPA for each year since January 1, 2011. This encompasses chemical identity, production volumes, usage categories, manufacturing byproducts, disposal methods, worker exposure, and potential environmental or health hazards. Importantly, this is a one-time reporting requirement separate from the typical four-year TSCA Chemical Data Reporting (CDR) cycle. Additionally, entities must maintain records for five years following the submission date.

What Substances are Covered?

The rule mandates reporting on each PFAS chemical substance manufactured or imported for commercial use in U.S., including those in mixtures, byproducts, and impurities. However, it excludes materials not classified as “chemical substances” under TSCA Section 3(2)(B). To determine which PFAS are included, the EPA uses a specific structural definition:

• R-(CF₂)-CF(R′)R″, where both the CF₂ and CF moieties are saturated carbons.
• R-CF₂OCF₂-R′, where R and R′ can either be F, O, or saturated carbons.
• CF₃C(CF₃)R′R″, where R′ and R″ can either be F or saturated carbons

According to the current EPA CompTox database, this rule covers an estimated 13,000 unique PFAS chemicals. However, even if a PFAS is not explicitly listed on the EPA CompTox list, it must be reported if it fits the structural definition and has been commercially produced since 2011.

What Industries are Covered?

This rule casts a wide net, affecting all manufacturers and importers of PFAS and PFAS-containing articles across diverse industries, irrespective of their size. This includes sectors such as chemical manufacturing, textiles, electronics, automotive parts, construction, wholesale and retail trade, and waste management and remediation services. Essentially, any industry that produces, imports, or inadvertently creates PFAS as byproducts or impurities falls under this rule.

However, the rule exempts non-commercial research and development activities. Facilities solely involved in processing, distributing, using, or disposing of PFAS, without manufacturing them, are not required to report unless they also engage in commercial manufacturing. Waste management operations that import municipal solid waste for disposal are not covered, but those importing PFAS-containing waste for recycling or non-municipal waste streams must comply.

Are There Any Exemptions?

This reporting rule is comprehensive, offering no exemptions based on production volume, PFAS contained in articles, or other typical criteria. While there are no production volume thresholds, small manufacturers whose reporting duties stem solely from article imports benefit from extended deadlines. Additionally, while article importers are not exempt from this rule, they may be eligible for a streamlined reporting option.

What are the timelines?

The reporting window opens on April 13, 2026 with submissions due by October 13, 2026. Small manufacturers importing articles have until April 13, 2027, to submit their reports.

Navigating the Reporting Process

Data Review

Under TSCA, facilities are required to utilize all data that is “known to or reasonably ascertainable by,” which means all information in a person’s possession or control, plus all information that a reasonable person similarly situated might be expected to possess, control, or know. To fulfill that obligation, facilities that expect or suspect the current or historical usage of PFAS should examine their supply chains and historical records for any PFAS manufacturing or importing activities since 2011. This involves collecting data from purchase records, Safety Data Sheets (SDS), and possibly consulting with suppliers to confirm PFAS content and usage. A comprehensive inquiry within their organization is expected and may require input from external sources as well, such as upstream suppliers or downstream users, to address any information gaps.

Electronic Reporting

All data must be submitted electronically via the Central Data Exchange (CDX) system. Facilities need to register with the CDX and use the specific web-based reporting tool for TSCA Section 8(a)(7).

Key Takeaway

As the regulatory framework continues to expand, even industries not traditionally linked to PFAS may find themselves affected, potentially uncovering trace PFAS due to supplier materials. Identifying applicable regulations and developing a robust compliance strategy can be challenging. The complexity of the One-Time PFAS Reporting Rule lies in the extensive historical data required.  Industries may encounter challenges in data collection, particularly for prior years. For businesses navigating these intricate requirements, partnering with knowledgeable experts can be invaluable. ALL4 can help you with rule familiarization, compliance determination, form completion, and electronic reporting activities to ensure accurate and timely reporting. Additionally, support is available for identifying PFAS rules applicable to your facility and developing a robust compliance strategy. If you want more information or have any questions about the one-time reporting, reach out to Apoorva Goel (agoel@all4inc.com) or one of our project managers Kayla Nuschke (knuschke@all4inc.com).

An Introduction to ECHO

The Enforcement and Compliance History Online (ECHO) is an online tool created by the United States Environmental Protection Agency (U.S. EPA) to view regulatory compliance and enforcement information about regulated facilities. ECHO provides a user-friendly way to view recent regulations, inspections, and violations at a facility level for over one million sites throughout the Unites States.

What Data is available for facilities in ECHO?

ECHO provides data on the location of the facility, any identifying information, the enforcement and compliance history, the facility permits and codes, the environmental conditions, the pollutants on site, and the community surrounding the facility. The facility Quick Search provides information for a facility at a glance, including any current violations, the past 12 quarters (three-month segments) of compliance, the address of the facility, the Facility Registry Service identification (FRS ID), and any environmental justice (EJ) concerns. To see more data, click on “more facility details” which will populate the “detailed facility report”. From this webpage, tabs with the facility summary, characteristics, compliance history, environmental conditions, pollutants on site, and information on EJ concerns can be viewed in more detail. For example, the facility characteristics tab includes information on permits, applicable industrial codes, effluent guidelines, and other facility compliance history information.

How Do I Use ECHO?

To begin, find ECHO’s website at https://echo.epa.gov/. ECHO’s front page contains the Quick Search tool along with other information on ECHO including other search options, data trends, U.S. EPA cases, data services, help, and news. The front page also includes helpful resources for using ECHO such as help videos and tool guides. Facilities can be easily searched using the Quick Search task bar. By entering a city, state, zip code, or facility name/ID, an interactive map of facilities with violations and enforcement action will populate to generate the facility quick search results.

Data can then be filtered to explore enforcement and compliance criteria. To see data about a specific facility, simply click on the tabs of the interactive map. Once viewing a specific facility, more details about the facility can be viewed by clicking “more facility details”.

After clicking to see more details, the detailed facility report will populate with more information about the site.

Where Does ECHO Data come from?

Data from ECHO comes from various U.S EPA and non-U.S. EPA sources including the Integrated Compliance Information System (ICIS), the Greenhouse Gas Reporting Program (GHGRP), and the Facility Registry Service (FRS). To see where the data for a specific facility originates from you can click “view more facility details” for a facility to see where the report originates.

Data for most U.S. EPA source databases are updated in ECHO each week, with the exception of certain databases such as the Safe Drinking Water Information System (SDWIS) which is updated quarterly. ECHO reports the past three years of facility compliance data, the past ten years of compliance and enforcement data, and all years of U.S. EPA formal enforcement.

How Can I Correct the Data?

ECHO contains many data streams from both local and federal governments. Because of the large set of data and the inconsistencies between the data, it may not always be 100% accurate. Although U. S. EPA is working on it, the changes may take time due to the large amount of data in the ECHO system. The best way to correct a data problem is to report the data problem to U.S. EPA using the ECHO website. To correct data, view the detailed facility report and click on the “report data problem” button on the top right of the page.

After clicking “report data error”, yellow error icons will appear next to the information on the detailed facility report.

By selecting an error icon, you will be directed to another page to enter your contact information and relevant information on the data issue.

If a yellow icon is not available for the information you wish to correct, the “report data problem” button may be clicked again to be directed to an error reporting page.

How Can All4 Help?

Because of the potential for erroneous data in ECHO, it is important to ensure that the data included is accurate and up to date. If you notice that your facility information is wrong, it can give the public a mistaken view about your facilities’ enforcement history. ALL4 can help to correct these data issues and ensure the right information about your facility is available.

For any questions regarding ECHO or correcting data problems, please contact your ALL4 Project Manager or Andrew Hebert at ahebert@all4inc.com for more information.

Implementation Best Practices to Increase User Adoption

Digital Solutions can help organizations improve their performance, compliance, and sustainability. However, implementing a new software solution can be a challenging and complex process, especially when it involves changing the way users work and interact with technology. How can you ensure that your implementation project is successful and that your users are happy with the outcome? How can you ensure that your employees, managers, and stakeholders embrace the new technology and use it effectively? In this article, I will share some best practices for increasing user adoption and satisfaction.

Best Practices for Implementing Digital Solutions for Environmental, Health and Safety (EHS)

Implementing digital solutions requires a strategic approach that involves planning, evaluation, and execution. Here are some of the key steps you should follow to ensure a smooth and successful implementation process.

• Define your goals and objectives. Before you start your implementation project, you should have a clear vision of what you want to achieve with your digital solution. What are the main pain points you want to address? What are the expected benefits and outcomes? How will you measure your success? Having a clear and realistic goal will help you align your project with your organizational strategy and communicate it to your stakeholders.
• Select the right solution and partner. Choosing the right digital solution is crucial for your implementation success. You should look for a solution that meets your specific needs, requirements, and budget. You should also consider the usability, scalability, and integration capabilities of the solution. Also, you should select a reliable and experienced partner who can provide you with the necessary support, guidance, and expertise throughout the implementation process.
• Engage your users and stakeholders. User adoption is one of the most critical factors for the success of your digital solution. To ensure that your users and stakeholders are on board with your project, you should engage them from the start. You should identify and involve the key stakeholders (e.g., employees, managers, executives, customers, suppliers). By engaging users in the planning, design, testing, and training phases of the implementation, you can ensure that the solution meets their needs and expectations, and that they feel valued and empowered. Be sure to communicate the benefits and value of the solution, solicit feedback, and address any concerns or issues. User involvement also helps build trust, rapport, and buy-in, which are essential for overcoming resistance and fostering change.
• Provide clear and consistent communication. Communication is key for any implementation project, but especially for one that affects how users work and use technology. Users need to know what the project is about, why it is important, how it will benefit them, what they need to do, and when and how they will be supported. Communication should be clear, consistent, frequent, and tailored to different audiences and channels. Communication should also be two-way, allowing users to provide feedback, ask questions, and raise concerns.
• Offer adequate and engaging training. Training is another crucial factor for user adoption, as it helps users to learn how to use the new solution effectively and efficiently. Training should be adequate, meaning that it covers all the relevant features and functions, and that it is delivered at the right time and pace. Training should also be engaging, meaning that it uses a variety of methods and formats, such as hands on classroom training, videos, simulations, and quizzes to keep users interested and motivated. Training should be tailored to the business, meaning it should incorporate your business rules and decisions made throughout the implementation process. Training should also be adaptive, meaning that it adjusts to the different levels and needs of users, and provide opportunities for practice and reinforcement.
• Monitor and evaluate your progress and results. Implementing digital solutions for EHS is not a one-time event, but an ongoing process that requires constant monitoring and evaluation. You should track and measure your progress and results against your predefined goals and objectives. You should also collect and analyze data and feedback from your users and stakeholders, a key element of organization change management. This will help you identify and resolve any issues, challenges, or gaps that may arise during the implementation process. Additionally, you should celebrate and share your successes and achievements, and recognize and reward your users and stakeholders for their contributions and efforts.
• Provide ongoing support and feedback. User adoption does not end when the implementation project is over. Users need ongoing support and feedback to ensure that they are using the new solution correctly and optimally, and that they are satisfied with the results. Support can include help desks, Frequently Asked Questions, manuals, tutorials, webinars, forums, and peer networks. Feedback can include surveys, interviews, focus groups, analytics, and reports. Support and feedback should be timely, responsive, and proactive, and should be used to identify and address any issues, gaps, or opportunities for improvement. Deployed systems should be organic, allowing for the incorporation of user feedback and new vendor functionality over time.

Implementing a new software solution can be a rewarding and transformative experience for both the organization and the users, if done right. By following the best practices outlined in this article, you can increase user adoption and satisfaction and ensure that your implementation project delivers the desired outcomes and benefits. Remember to involve users from the start, communicate clearly and consistently, offer adequate and engaging training, and provide ongoing support and feedback. By doing so, you can implement software solutions that excite and engage users.

Stay tuned for follow-up blog articles in this series that will discuss common pitfalls to avoid in project delivery and the need for training and organizational change management throughout the project lifecycle.

If you have any questions or need assistance with your next Implementation project, please contact Nichole Svezeny at nsvezeny@all4inc.com or 412-314-4995.

Indoor Heat Illness Prevention

Background 

In 2006, California Division of Occupational Safety and Health (Cal OSHA) implemented a heat illness prevention for outdoor workplaces (California Code of Regulations (CCR), Title 8, section 3395).  Less than 10 years later, on June 20, 2024, Cal OSHA approved CCR, Title 8, section 3396 for “Heat Illness Prevention in Indoor Places of Employment” and the new standard became effective on July 23, 2024.  The Indoor Heat Illness Prevention Standard was developed to protect employees at risk for heat illness in indoor work environments in California, such as warehouses and manufacturers, due to record high temperatures in the state.  The new standard applies to workplaces with indoor areas that have temperatures or heat indexes measuring 82°F or higher when employees are present.  Compared to the 2006 standard for outdoor workplaces, this new standard for indoor workplaces includes a requirement for implementing temperature and heat index assessments and control measures.   

According to Centers for Disease Control and Prevention and CCR, Title 8, section 3396, heat illness includes, but is not limited to; heat stroke, heat exhaustion, rhabdomyolysis, heat syncope, heat cramps, and heat rash. Common signs for these illnesses include confusion, light headedness, loss of consciousness, hot or dry skin, profusely sweating, high body temperature, weakness, or muscle aches. 

Indoor Heat Illness Prevention Plan  

Affected employers are expected to prepare an Indoor Heat Illness Prevention Plan (IHIPP).  The plan may be added to the employer’s Injury and Illness Prevention Program or the Outdoor Heat Illness Prevention Plan. The plan must be written in English and the language spoken by the majority of employees. At a minimum, the plan must include procedures for: 

• Providing clean drinking water. 

• Providing cool-down areas. Employers must always have and maintain at least one cool-down area during employee working hours. The designated areas must be less than 82°F. Cool-down areas must be available to be used at all times during working hours. 

• Providing rest periods. Employers must encourage and allow employees to take preventive rest periods in a cool-down area whenever the employee feels the need due to overheating.  

• Assessments and measurements of heat. Employers must measure temperature and heat index measurements and record whichever of the two is higher whenever they reasonably suspect the temperature to be 82°F. 

• Control measures. Employers must use control measures based on the environmental risk factors for heat illness prevention. Control measures can be engineering controls or they can be administrative controls.  

• Emergency response.  

• Acclimatization: New or newly assigned employees to a work area where the temperature or heat index equals to or is greater than 82°F must be closely observed for 14 days of employment by a supervisor or designee and heat illness risks must be assessed. 

• Training: Employees are required to receive effective training on risks of heat illness indoors and outdoors, the contents of the IHIPP, procedures for responding to symptoms and emergency situations. 

 What’s Next? 

Employers are required to develop, implement, and maintain an Indoor Heat Illness Prevention Plan as of July 23, 2024. ALL4 staff are trained and experienced in implementing health and safety regulatory requirements, including developing workplace safety procedures and providing training. If you have any questions or need assistance in preparing an Indoor Heat Illness Prevention Plan, please contact Jessica Malberg at (909)477-7121 or email at jmalberg@all4inc.com or Ayoon Ahmad at aahmad@all4inc.com.  

Extreme Heat: Risk and Resources

ADVANCE Act

On July 9^th, 2024, President Joe Biden signed into law the Accelerating Deployment of Versatile Nuclear for Clean Energy (ADVANCE) Act. Senator Shelley Capito of West Virginia introduced the ADVANCE Act in March of 2023 with the goal to advance nuclear energy and technologies for the United States (U.S.) while strengthening nuclear leadership and improving the regulation of nuclear energy (Congress Bill S. 1111). Through this Bill, the Nuclear Regulatory Commission (NRC) was required to develop a process of timely licensing for nuclear facilities and establish initiatives of licensing advanced nuclear fuels. Below are the main goals and requirements created by the ADVANCE Act:

• It will strengthen and improve American nuclear energy leadership such as the NRC and the Department of Energy (DOE). The NRC will gain authority to spearhead global efforts in crafting rules for advanced nuclear reactors while the DOE is tasked with enhancing its approval process for exporting U.S. technology abroad, ensuring nuclear non-proliferation standards are upheld.
• Leadership will foster innovation in nuclear energy by streamlining regulatory processes, offering incentives for successful deployment of advanced nuclear reactor technologies, and facilitating quicker licensing and deployment at both new and existing energy sites.
• It will aim to preserve existing nuclear energy infrastructure by updating regulations to ensure preservation and modernization.
• Its focus is on bolstering the U.S. nuclear fuel cycle and supply chain in infrastructure by empowering the NRC to qualify and license safer and more economically competitive fuels, and by evaluating advanced manufacturing methods to improve reactor construction efficiency and cost-effectiveness.
• Efforts are underway to enhance the NRC’s capabilities and efficiency by providing the correct tools to enable recruitment of highly skilled personnel for advanced reactor licenses, implementing a structured licensing framework for efficient and timely regulatory reviews, and simplifying the National Environmental Policy Act (NEPA) environmental review process.

By signing the ADVANCE Act into law, the U.S. shows its desire to advance nuclear energy, transition to low-emission energy generation, and achieve cleaner energy goals. This spotlight on nuclear energy will provide this industry with the tools and modernization necessary to impact energy generation throughout the U.S. and internationally.

Today, there are a little over four hundred nuclear reactors world-wide, with the United States, China, and France leading in amount of nuclear power generated. Nuclear energy, as a low-carbon and dependable power source, plays a critical role in reducing greenhouse gas emissions and combating climate change. It not only provides stable and affordable electricity but also stimulates job creation and supports industrial growth. Despite its advantages, public concerns continue regarding safety, radioactive waste, and security. The ADVANCE Act aims to address these issues by equipping nuclear organizations with the necessary resources to enhance research, advance education, and expand opportunities in the sector.

If you have any questions pertaining to the ADVANCE Act or how to become more energy efficient, please reach out to ALL4’s ESG and Sustainability team of experts. You can contact me at lblasius@all4inc.com or (770) 999-0270; or James Giannantonio at jgiannantonio@all4inc.com or (215) 391-4691.