Practical EHS Tips, News & Advice. Updated Daily.
So, if you’ve decided that the best option for managing your solvent-contaminated wipes is to see if you can get them exempt from EPA’s definition of solid and/or hazardous waste by complying with either the rule’s solid waste exclusion or therule’s hazardous waste exclusion, you need to know the steps to take to satisfy the […]
So, should you wash, dry, or toss your solvent-contaminated rags? How About Dry? We can tell you right away, don’t hang your solvent-contaminated wipes out to dry. Let’s take that one off the table. Never mind the Resource Conservation and Recovery Act (RCRA) violations you would be facing, you will also have great big headaches […]
Counting Hazardous Waste You know you generate hazardous waste at your facility and you want to keep your disposal costs down. Well, then, you have to keep down the amount of hazardous waste you have on-site each month. If you are a large quantity generator (LQG), your responsibilities and costs will be greater than if […]
As a generator of HSM, you ultimately decide whether the material is safely managed. The decision to send your HSMs to an off-site recycling business should be followed by a careful review of the qualifications of available recyclers. Improper management can increase liability of the originating company (remember RCRA’s “cradle-to-grave” mandate). Environmental managers investigating recycling […]
New Definition of ‘Sham Recycling’ Sham recycling refers to claims by a hazardous waste generator that the waste is being recycled when it is in fact being discarded. A new definition at 40 CFR 261.2(g) codifies EPA’s concept of sham recycling: “A hazardous secondary material found to be sham recycled is considered discarded and a […]
In the June 11, 2014, Federal Register (FR), the EPA published an Information Collection Request (updated in the October 14, 2014, FR) asking for public comment concerning the hazardous waste generator rules under the Resource Conservation and Recovery Act (RCRA). Specifically, the Agency asked that the comments address the following components of the generator rules: […]
Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). Note: It is critical to remember that most states have been delegated the authority to run […]
FAQs About the Definition of Solid Waste (DSW) Rule—Part 2 Q: Does the 2014 DSW rule help to ensure that hazardous materials are actually legitimately recycled and not disposed of illegally? A: In addition to the changes to permitting and variances, the 2014 DSW rule “establishes a clear, uniform legitimate recycling standard for all hazardous […]
FAQs About the Definition of Solid Waste (DSW) Rule—Part 1 Q: What was the impetus for the DSW final rule? A: According to the EPA, the 2014 DSW final rule addresses “significant regulatory gaps in the 2008 rule” that could result in negative impacts on “communities adjacent to third-party recyclers, including disproportionately impacting minority and […]
Hazardous Waste FAQs for Construction, Demolition, and Renovation Projects by CESQGs Q: Do CESQGs have to comply with any recordkeeping and reporting requirements related to hazardous waste in C&D debris? A: As long as a generator remains a CESQG and is in compliance with the CESQG hazardous waste requirements of 40 CFR 261.5, it is […]