Hello everyone,
The purpose of this newsletter is to inform our valued clients and business friends of regulatory updates, industry trends, and CES news. We hope you find the newsletter informative, helpful, and a worthwhile read.
Summer Doldrums? – Summer is a great time to proactively address projects related to your environmental program when things might be a bit slower than other times of year. Reporting season is behind us, and the yearend rush is still down the road. The weather is also better now for addressing outside projects. If you have some environmental items that should be addressed such as industrial cleanings, lab packs, or other similar projects, now might be the best time to get them from your to-do list to your done list. If we can be of assistance to you, please let us know.
As we continue to grow, we are dedicated to being proactive and keeping communication as efficient as possible. Please see the updates below and make sure your appropriate team members are aware of the updates. You can always continue to contact your regular account manager as well.
Regulatory Review
Aerosols as Universal Waste
On July 1st, 2025, Wisconsin approved managing aerosol cans as universal waste. Universal waste is a subset of hazardous waste, where the waste does contain hazardous properties, but the items are so common in industry and residential settings there are reduced regulations in managing them. Common universal wastes include spent bulbs, spent batteries, mercury containing devices, and now aerosol cans. Wisconsin is the most recent state to adopt managing aerosol cans as universal waste. States like Illinois and Minnesota have already been managing aerosol cans as universal waste.
We have been receiving a lot of questions on how this new revision will impact the management of aerosol cans. In summary, if you are puncturing your aerosol cans, the removed waste will be a hazardous waste and the empty cannisters could be recycled. If you do not puncture the aerosol cans, they can now be managed as a universal waste. The spent aerosol cans still need to be properly containerized, labeled as universal waste, and shipped offsite at least annually. As far as pricing and where the aerosol cans can be shipped, that has not changed. The same facilities set up to process waste aerosols will continue to receive them and process them at the same price points regardless of if the aerosols are technically hazardous waste or universal waste.
The biggest impact of this revised regulation will be to companies that generate a lot of aerosol can waste, or companies that generate just enough aerosol can waste it impacts their generator status. If you do not generate much aerosol can waste, this new revision will have little to no impact on your overall program.
Industry Trends
Earlier this year OSHA released data on the top violations in 2024 and, while the types of top violations are consistent year after year, the general trend is down compared to 2023.
Top 10 OSHA Violations for 2024
- Fall Protection – General Requirements (1926.501) – 6,307 violations (decrease from 2023)
- Hazard Communication – (1910.1200) – 2,888 violations (decrease from 2023)
- Ladders – (1926.1053) – 2,573 violations (decrease from 2023)
- Respiratory Protection – (1910.134) – 2,470 violations (decrease from 2023)
- Lockout/Tagout – (1910.147) – 2,443 violations (decrease from 2023)
- Powered Industrial Trucks – (1910.178) – 2,248 violations (decrease from 2023)
- Fall Protection – Training Requirements (1926.503) – 2,050 violations (decrease from 2023)
- Scaffolding – (1926.451) – 1,873 violations (decrease from 2023)
- Personal Protective & Lifesaving Equipment – Eye & Face Protection (1926.102) – 1,814 violations (decrease from 2023)
- Machine Guarding – (1910.212) – 1,541 violations (decrease from 2023)
Many of these regulatory standards are applicable and common for a wide range of our clients. If your program needs review to help ensure you are meeting regulatory requirements, now is a great time to review these most common violations.
CES News
2025 has been another very good year for CES. We have continued to grow as a company and have added more members to our expanding team. A few months ago we added Nick Cataldo to our team as our newest Business Development Manager. Nick comes to us with several years of experience in industrial sales and he has done a great job for us. Nick will be working with new and existing clients to help ensure we are providing the best value and services possible. Nick is another valuable resource to help provide efficient and cost-effective solutions for our clients. Services Nick will be promoting include:
- hazardous waste recycling and disposal
- non-hazardous waste recycling and disposal
- lab pack solutions
- industrial cleaning project solutions
- healthcare related waste recycling and disposal
- food manufacturing related waste recycling and disposal
- sustainable spill prevention and absorbent solutions
- and many other EH&S related services
In future newsletters we will continue to introduce new team members as we continue to add talented individuals to our team. We will also share exciting information as our resources continue to expand providing ever more comprehensive solutions.