CLS Regulatory Compliance & Legal Framework 3 — Questions and Answers
Question 1: Under ISO 14001, what is the primary purpose of an environmental aspect register in a lubrication management program?
- To list all lubricant brands approved for use
- To identify and evaluate environmental impacts associated with lubrication activities (Correct answer)
- To record employee environmental training completions
- To document lubricant purchase orders and costs
Correct answer: To identify and evaluate environmental impacts associated with lubrication activities
ISO 14001 requires organizations to identify environmental aspects and assess their significance so that significant aspects receive appropriate operational controls.
Question 2: The NSF H1 registration category for lubricants is specifically required for incidental food contact applications. What concentration limit applies?
- 1 ppm maximum in the finished food product
- 10 ppm maximum in the finished food product (Correct answer)
- 25 ppm maximum in the finished food product
- 100 ppm maximum in the finished food product
Correct answer: 10 ppm maximum in the finished food product
NSF H1 lubricants are formulated to be acceptable for incidental food contact at concentrations not exceeding 10 ppm in the finished food product.
Question 3: A facility generates 220 pounds of hazardous waste per month. Under RCRA, this facility is classified as a:
- Large Quantity Generator (LQG)
- Small Quantity Generator (SQG) (Correct answer)
- Very Small Quantity Generator (VSQG)
- Conditionally Exempt Small Quantity Generator
Correct answer: Small Quantity Generator (SQG)
Facilities generating between 100 and 1,000 kg (220–2,200 lbs) of hazardous waste per month are classified as Small Quantity Generators under RCRA.
Question 4: Which regulation requires lubricant suppliers to provide a Safety Data Sheet (SDS) to downstream users before or at the time of first product delivery?
- TSCA Section 8(e)
- OSHA HazCom Standard 29 CFR 1910.1200 (Correct answer)
- EPA EPCRA Section 311
- RCRA Subtitle C
Correct answer: OSHA HazCom Standard 29 CFR 1910.1200
OSHA's Hazard Communication Standard (HazCom / Right-to-Know) at 29 CFR 1910.1200 mandates that chemical manufacturers and distributors provide SDS documents to employers.
Question 5: When a new lubricant additive is introduced to the U.S. market, what must the manufacturer submit to the EPA before commencing manufacture?
- Product registration certificate
- Pre-Manufacture Notice (PMN) under TSCA (Correct answer)
- Material safety data sheet to OSHA
- New source performance standard application
Correct answer: Pre-Manufacture Notice (PMN) under TSCA
TSCA Section 5 requires a Pre-Manufacture Notice (PMN) to be submitted to the EPA at least 90 days before manufacturing or importing a new chemical substance.
Question 6: Which of the following best describes the 'Boiler and Industrial Furnace' (BIF) rule's impact on used oil management?
- It prohibits burning used oil as fuel in any industrial setting
- It sets emission standards for burning used oil in industrial furnaces and boilers (Correct answer)
- It classifies all used oil burned for energy as hazardous waste
- It requires used oil to be re-refined before energy recovery
Correct answer: It sets emission standards for burning used oil in industrial furnaces and boilers
The BIF rule (40 CFR Parts 266 and 63) establishes air emission standards for burning hazardous waste, including off-specification used oil, in boilers and industrial furnaces.
Question 7: A company's lubricant storage area releases 100 lbs of a listed CERCLA hazardous substance in a single incident. What immediate action is required?
- File an annual report with the EPA within 90 days
- Notify the National Response Center (NRC) immediately (Correct answer)
- Submit a Tier II report to state emergency planning authorities
- Post a public notice in the local newspaper within 24 hours
Correct answer: Notify the National Response Center (NRC) immediately
Releases of CERCLA hazardous substances at or above the reportable quantity (RQ) require immediate notification to the National Response Center (1-800-424-8802).
CLS Regulatory Compliance & Legal Framework 3
Under ISO 14001, what is the primary purpose of an environmental aspect register in a lubrication management program?