Category: Hazardous Waste Management

Biennial reports, paperwork

Are You Ready to Submit Your 2019 Biennial Report?

As hazardous waste large quantity generators (LQGs) and hazardous waste treatment, storage, and disposal facilities (TSDFs) know all too well, the Resource Conservation and Recovery Act (RCRA) requires them to report every two years on the quantities, types, and management methods of hazardous wastes generated on-site and hazardous wastes received from off-site sources. Referred to […]

Pill bottles, pharmaceuticals

Considerations for Manifesting Hazardous Waste Pharmaceuticals

In February 2019, the EPA issued a final rule establishing a new set of regulations for the management of hazardous waste pharmaceuticals generated by healthcare facilities. There were several rationales behind the rule. For example, in contrast to staff at industrial facilities, healthcare personnel (e.g., doctors and nurses) are rarely trained to make hazardous waste […]

Montana landscape

The Montana Exceptions and a Hazardous Waste Case

In Montana v. United States (1981), the U.S. Supreme Court found that Indian tribes do not have civil or criminal jurisdiction over nontribal members within a reservation. This opinion has proven to be one of the clearest indications that Indian tribes possess no authority over lands they do not own (called non-Indian fee lands), even […]

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 […]