NSWMA Comments on GHG Reporting and Blood-Borne Pathogen Rules

The National Solid Wastes Management Association (NSWMA) recently submitted comments regarding proposed rules by the U.S. Environmental Protection Agency (EPA) and the U.S. Occupational Safety and Health Administration (OSHA).

NSWMA’s Landfill Institute questioned EPA’s proposed rule regarding amendments to the mandatory reporting of greenhouse gases, suggesting that it will substantially change the requirements for municipal solid waste landfills, imposing substantial new data collection requirements in the midst of a reporting year. 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. In its comments, NSWMA requested that EPA not retroactively impose these requirements for 2010 reports and that the agency provide an opportunity for formal public comment.

“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,” said NSWMA President and CEO Bruce J. Parker in a press release.

Meanwhile, NSWMA’s Healthcare Waste Institute voiced support for OSHA’s current blood-borne pathogens standard as a means of protecting healthcare workers and urged that it be updated to address changes in the healthcare industry.

“The current standard ensures a level playing field for companies that should provide health and safety protection for their employees,” said Parker in the press release. “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.”