Practical EHS Tips, News & Advice. Updated Daily.
By Elizabeth Dickinson, J.D. BLR Legal Editor Referred to by the U.S. Environmental Protection Agency (EPA) as the Hazardous Waste Report (EPA Form 8700-13 A/B), and by those in the environmental management field as the Biennial Report, the report must be submitted by March 1 of every even-numbered year with information of the facility’s hazardous […]
Step 6: Create Procedures for Managing Broken Lamps The easiest way to do this is to protect lamps from breakage. Remove lamps carefully and store used lamps in a location and manner that will prevent breakage. Step 7: Decide How You’re Going to Get the Lamps to the Recycler There are several options to consider […]
Step 1: Assess Your Facility To do this, ask the following questions: How many fluorescent lamps are in the facility? Where are they located? How often do you change your fluorescent lamps? How many fluorescent lamps are you disposing of each month and year? How are you handling and storing the used lamps? Do all […]
Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]
One way, called the contained-in policy, attempted to smooth over the pre-existing position held by the Agency that contaminated soil that either contained a listed hazardous waste or exhibited a hazardous waste characteristic must be managed and disposed of according to all regulations governing hazardous waste (RCRA Subtitle C). Also, soil that contained listed hazardous […]
Are You a LQG? If you generate 1,000 kg (about 2,200 pounds) or more of hazardous waste or more than 1 kg of acutely hazardous waste in any calendar month, you are a large quantity generator (LQG). LQGs must comply with all of EPA’s hazardous waste management rules although a partial exemption from some rules […]
Containers & Tanks There’s a lot of confusion around whether a management unit is a container or a tank. Here’s the difference—you know you’re dealing with a hazardous waste container if it’s portable. A tank will always remain stationary. The RCRA hazardous waste regulations define a container as “any portable device in which a material […]
After the decision is made to vent propane from a cylinder, up until it is vented onsite, does a propane cylinder need to be managed as D001 hazardous waste? Because the container of D001 hazardous waste does not yet meet the “RCRA empty standard” (as explained at 40 CFR 261.7) the container must be managed […]
Here’s a quick checklist of the paperwork you should have for your RCRA, hazardous waste exporting, and land ban requirements. RCRA Have you kept the following hazardous waste records for specified periods of time (if applicable)? Copies of a small quantity generator’s “reclamation agreement” for at least 3 years after the agreement’s termination or expiration […]
Here are a few of the most common container violations you should be aware of: Not keeping containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. No accumulation start date is marked on the container. If you are a generator accumulating […]