Practical EHS Tips, News & Advice. Updated Daily.
A generator’s hazardous waste status is based on the quantity of hazardous waste generated each month. So do all your generated hazardous wastes need to be counted? Yes, but no. The federal regulation at 40 CFR 261.5(c) and (d) sets forth a list of wastes that are exempt from being counted in connection with ascertaining […]
In a Federal Register (FR) notice, the EPA is informing affected businesses that they can assert confidentiality claims relevant to documents or data included in information submitted to the Agency to track the import/export of Resource Conservation and Recovery Act (RCRA)-regulated waste available to other parties under the Freedom of Information Act (FOIA).
In a recent webinar titled “Hazardous Waste Recycling: Uncover Cost-Effective and Legally Compliant Strategies for Your Organization’s Program,” speaker Philip Comella, Esq., head of the Environmental, Safety and Toxic Torts Group in the Chicago office of Seyfarth Shaw LLP, voiced what many have suspected: that the Resource Conservation and Recovery Act (RCRA) hazardous waste recycling […]
The EPA published its proposed Hazardous Waste Generator Improvement rule on September 25, 2015, that it says addresses problems the Agency identified with the current generator regulations:
Large quantity generators (LQGs) of hazardous waste and hazardous waste treatment, storage, and disposal facilities (TSDFs) are required to submit hazardous waste reports (aka, biennial reports) by March 1 this year. Today we will review some details of just who is required to submit this report and common hazardous wastes that are subject to reporting. […]
Are you a large quantity generator (LQG) of hazardous waste? If so, you and hazardous waste treatment, storage, and disposal facilities (TSDFs) are required to submit hazardous waste reports (aka, biennial reports) by March 1 this year. Do you even know if you are an LQG? In the newest biennial report form, released by the […]
If you have hazardous waste at your facility, you are a generator of hazardous waste. If you decide to manage some of it as universal waste, you are automatically a universal waste handler by virtue of being a generator of universal waste. Generated universal waste is not counted in a generator’s hazardous waste quantity if […]
Problem # 1: Have you crossed the line to hazmat offeror? You’re a hazardous waste generator and you have hired a hazardous waste transporter to pick up your waste and haul it off. You’ve checked everything off your Resource Conservation and Recovery Act (RCRA) checklist and you’re ready for the waste to be out of […]
Note. These BMPs reflect certain federal standards for hazardous waste container management. They do not address all the requirements for containers. Also, your state may have stricter hazardous waste container management requirements that are not reflected in theses BMPs. Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it […]
Violations of container management standards are very common and cited often by agency inspectors as the most common of regulatory violations, particularly by hazardous waste generators. Anyone who handles hazardous waste should be aware that many inspectors go to hazardous waste accumulation or storage areas first when conducting an inspection. A recent example of an […]