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The Institutes of the National Solid Wastes Management Association (NSWMA) recently submitted comments regarding proposed rules by the United States Environmental Protection Agency (EPA) and the U.S. Occupational Safety and Health Administration (OSHA).
NSWMA's Landfill Institute offered comments on EPA's proposed rule regarding amendments to the mandatory reporting of greenhouse gases, and NSWMA's Healthcare Waste Institute recently submitted comments regarding OSHA's blood-borne pathogens standard.
With the comments regarding greenhouse gas reporting, the Landfill Institute argued that the proposed rules substantially change the requirements for municipal solid waste landfills, imposing substantial new data collection requirements mid-reporting year. NSWMA's Landfill Institute believes that EPA should not retroactively impose these requirements for reports that are to be submitted in 2010 and, in some cases, provide an opportunity for formal public comment.
The proposed rule changes include amendments to the definition for construction and demolition landfills; how landfills measure waste quantities; and the methodology, decay rates and values of degradable organic carbon used to estimate greenhouse gas emissions.
Regarding these changes, NSWMA President and CEO Bruce J. Parker stated, "While some of EPA's changes appear to provide a more reasoned approach to account for the amount of water that might infiltrate into a landfill, other changes impose substantial new data collection requirements mid-reporting year without the benefit of adequate public comment."
In the comments regarding the bloodborne pathogens standard, NSWMA's Healthcare Waste Institute stated that the current standard is a necessary part of protecting healthcare workers and should be updated to consider changes in health settings such as medical treatment in non-traditional facilities.
In support of the current regulations, Parker stated, "The current standard ensures a level playing field for companies that should provide health and safety protection for their employees. Without a federal standard, it is less likely that healthcare facilities will be willing to pay for worker protections against bloodborne risks or that they will be willing to cover the costs associated with reducing risks for waste management services."
