Category: Hazardous Waste Management

Hazardous waste, chemical inventory, e-manifest, warehouse

Your Options Under the HazWaste e-Manifest Program

Effective October 1, 2019, through September 30, 2021, the EPA will apply new user fees in its hazardous waste (hazwaste) e-Manifest Program. Publication of the Agency’s fee memo provides an opportunity to review the different types of manifests regulated parties may use to meet their legal obligations.

Contaminated wipes, solvents

Contaminated Wipes and the ‘No-Free-Liquids’ Condition

In 2013, the EPA promulgated a final rule that removed solvent-contaminated wipes that are either cleaned and reused or disposed of from regulation under the Resource Conservation and Recovery Act (RCRA). The exclusions come with conditions, meaning the generators of these wipes must conduct certain actions to qualify. One such condition described here is that […]

Oil barrels or chemical drums stacked up

Is Your Waste Hazardous? If You Don’t Know, It Could Be Costly

“Is my waste hazardous?” This is a question common to generators of wastes in all industries. The answer to this question is essential, as it’s at the heart of the Resource Conservation and Recovery Act (RCRA) regulations for handlers of hazardous waste. Generators as well as owners/operators of treatment, storage, and disposal facilities (TSDFs) cannot […]

Avery hazardous waste label (thumb)

Complying with the EPA’s Hazardous Waste Generator Improvements Final Rule

To enhance safety and environmental protection, the EPA’s Hazardous Waste Generator Improvements Final Rule, which became effective federally last year, requires identification including the words “Hazardous Waste,” a description of the container’s hazards, and the date the accumulation started on each container. In short, generators must indicate the hazards of hazardous contents, but have flexibility […]

New Year, New Rule: Management Standards for Hazardous Waste Pharmaceuticals in Healthcare Facilities

Just before the holiday season, EPA issued its final rule for waste pharmaceuticals management. Due to the complex nature of handling waste pharmaceuticals within healthcare facilities, it became clear to EPA that these waste streams could no longer be managed with existing RCRA waste regulations. EPA previously tried to promulgate rules regarding pharmaceutical waste streams […]

Gavel, scales of justice and law books

State Court Jurisdiction Upheld by 7th Circuit in Environmental Case

Two types of jurisdiction were central to a case in which two plaintiff companies deposited hazardous waste generated in Colorado into industrial wells in Illinois. The Illinois Environmental Protection Agency (IEPA) found that the injections were conducted without the required Class I permit and brought charges against the companies before the Illinois Pollution Control Board […]

Under RCRA, What Do ‘More Stringent’ and ‘Broader in Scope’ Mean?

Section 3009 of Subtitle C of the Resource Conservation and Recovery Act (RCRA) allows EPA-authorized states to promulgate hazardous waste regulations that are more stringent (MS) than counterpart federal hazardous waste (hazwaste) rules. If the EPA authorizes the MS provisions, they become part of the federal hazwaste program, which means that the EPA may enforce […]

Should Your Hazardous Waste Be Managed As Universal Waste?

Determining whether you are allowed to, and also whether you should, manage certain generated wastes as universal wastes rather than hazardous wastes is a dilemma that can plague a generator of hazardous waste. The questions the issue brings forth range from knowing what hazardous wastes qualify for universal waste management to identifying the perceivable advantages […]