Kurt Herman has been appointed to the Editorial Advisory Board of Remediation Journal.

Kurt Herman is a licensed Professional Geologist in Washington state.

Technologically enhanced naturally occurring radiological material, or TENORM, has moved onto the regulatory and legislative agendas in multiple states. TENORM is material that contains naturally occurring radioactive elements, such as uranium, thorium, or radium, that have been concentrated or brought into waste streams as a result of human activities.

Although there is no national regulatory framework for handling TENORM, piecemeal regulatory updates by individual states have recently been promulgated as states have become aware of the potential presence of TENORM in waste streams from the energy, paper and pulp, phosphate fertilizer, and sewage treatment sectors. For example, legislative bodies in Pennsylvania and North Dakota have enacted new regulations pertaining to levels of radioactivity for the handling and disposal of certain TENORM wastes. Other states, such as Colorado, Kentucky, Montana, and West Virginia, are either in the process of gathering information or developing new regulations. The evolving regulatory landscape surrounding TENORM could potentially affect multiple stakeholders in various industrial sectors.

Evaluating the impacts of new or proposed regulations requires an understanding of the factors that generate TENORM in different types of waste as well as background levels of radioactivity. TENORM content can vary considerably depending on the waste source (e.g., pipe/tank scale, waste phosphogypsum, or combustion residuals). Moreover, consideration of local background radioactivity levels can be important for interpreting TENORM concentrations in those wastes at specific sites. Gradient has experience providing scientific comments on proposed regulations, evaluating the TENORM content of wastes, assessing radiological risks, and evaluating appropriate remediation alternatives. If you would like to discuss these issues further, please contact one of our scientific experts listed below.

Andrew B. Bittner, M.Eng., P.E.
Principal Scientist
abittner@gradientcorp.com
Thomas Lewandowski, Ph.D., DABT, ERT, ATS
Principal
tlewandowski@gradientcorp.com
Samuel A. Flewelling, Ph.D.
Principal Scientist
sflewelling@gradientcorp.com
Christopher M. Long, Sc.D., DABT
Principal Scientist
clong@gradientcorp.com
Kurt Herman, M.Eng., P.G.
Principal
kherman@gradientcorp.com
Matt Tymchak, M.S.
Senior Hydrologist
mtymchak@gradientcorp.com
 

Gradient is an environmental and risk sciences consulting firm renowned for our specialties in Toxicology, Epidemiology, Risk Assessment, Product Safety, Contaminant Fate and Transport, Industrial Hygiene, Geographic Information Systems, and Environmental/Forensic Chemistry. We employ sound science to assist national and global clients in resolving their complex problems relating to chemicals in the environment, in the workplace, and in consumer products.

Gradient is happy to announce that we are a Third-Party Profiler of EPA’s Safer Choice program, which helps consumers identify products with lower inherent hazard and more sustainable chemical ingredients.  Previously known as EPA’s Design for the Environment (DfE) label, the Safer Choice label may be found on many commercially available products used in households, schools, hotels, offices, and sports venues.  Some examples of Safer Choice-certified products include all-purposes cleaners, car-care products, carpet cleaning products, dish soaps, laundry products, odor removers, pet care products, window cleaners, floor care products, and many others.

If you are interested in displaying the Safer Choice label on your product, contact Gradient for information and a possible evaluation.  Gradient’s Safer Choice Third Party Profiler services contacts:

Kim Reynolds Reid
Principal Scientist
kreid@gradientcorp.com

Joel M. Cohen, Sc.D.
Senior Toxicologist
jcohen@gradientcorp.com

Learn more about the Safer Choice label at EPA’s website.

Gradient is an environmental and risk sciences consulting firm renowned for our specialties in Toxicology, Epidemiology, Risk Assessment, Product Safety, Contaminant Fate and Transport, Industrial Hygiene, Geographic Information Systems, and Environmental/Forensic Chemistry. We employ sound science to assist national and global clients in resolving their complex problems relating to chemicals in the environment, in the workplace, and in consumer products.

www.gradientcorp.com

Introduction

The Globally Harmonized System for Classification and Labeling of Chemicals (GHS) is a hazard identification (classification) and communication (labeling) framework that is currently being implemented around the world.  In the US, the implementation deadline is June 1, 2015 as promulgated in the OSHA Hazcom rule.[1]  Although a key objective of GHS is to “harmonize” hazard communication, it is not a regulation in itself and different countries or jurisdictions have modified and implemented  GHS principles based on their specific needs.  Furthermore, several elements of the GHS framework are subject to scientific interpretation.   It is therefore not uncommon for a chemical to be classified and labeled differently across countries and jurisdiction.  This poses several business challenges, including inconsistent communication of hazards to the consumer, as well as issues related to protecting confidential business information.

Despite these challenges, the GHS implementation offers unique opportunities for companies to build a comprehensive understanding of their chemical and product portfolio.  This can be leveraged into a robust product stewardship program that integrates GHS activities with emerging market demands for “sustainable” products.  Several non-profit organizations have taken this to heart and have developed “green” classification and labeling systems that are based largely on GHS principles.

The objectives of this two-part webinar series are to: (1) provide an overview of the GHS and key technical and business challenges associated with its implementation; and (2) provide an overview of business opportunities associated with the GHS implementation.  Overall, this webinar series is intended to explore the scientific, legal, and business implications brought on by the widespread implementation of GHS principles.

Module 1 – Introduction to the GHS and Challenges Associated With Its Implementation

Module 1 will provide a brief introduction to the GHS and how it is being implemented across various countries and jurisdictions.  Through various “mock” examples, we will illustrate how scientists may use the same data to arrive at different hazard conclusions. When ambiguous data lead to uncertain hazard conclusions, we will explore how a company’s risk philosophy may influence final hazard determinations. Module 1 will also explore the differences in GHS implementation across jurisdictions, as well as the legal and business implications with producing jurisdiction-specific hazards vs. maintaining a consistent hazard profile across all jurisdictions.  In particular, we will focus on how GHS assignments can affect the disclosure of confidential business information.