Practical EHS Tips, News & Advice. Updated Daily.
As frequent visitors to EPA’s Resource Conservation and Recovery Act (RCRA) Online database already know, the Agency’s hazardous waste regulations prompt a constant stream of questions from both regulated entities and RCRA-authorized states about applicability, lack of clarity, and regulatory gaps. A small fraction of EPA’s answers and interpretations responding to such questions have now […]
In a final rule, the EPA has overhauled its regulations governing U.S. import and export of hazardous waste. One intent of the rule is to make EPA’s import/export provisions more consistent with import/export standards followed by members of the Organisation for Economic Co-operation and Development (OECD). The EPA also says the revisions respond to a […]
Whole Foods Market recently found itself on the business end of a U.S. Environmental Protection Agency (EPA) hazardous waste enforcement action that will cost the company over $4 million in penalties and projects. Where did this retail food giant go wrong, and how can you learn from its mistakes? Today we will review the issues […]
Generators of hazardous waste that meet the current Resource Conservation and Recovery Act (RCRA) standards for being conditionally exempt small quantity generators (CESQGs) will be “rebranded” as “very small quantity generators” (VSQGs) when the proposed Hazardous Waste Generator Improvements Rule (Rule) is finalized (most likely this month). Whether such generators are called CESQGs or VSQGs, […]
Q. Our company is a 3rd party warehouse company. We have various customers and each one holds their own EPA ID number at our site. One customer is a Large Quantity Generator (LQG). Are there any regulations that specify that both us and our customer must submit the biennial report?
If you are an environment, health, and safety (EHS) manager in any number of industries, you likely face the ongoing task of dealing with solvents in your workplace. Today we will do a quick review for determining if your used solvents are hazardous waste, and tomorrow we will offer tips for protecting your workers from […]
As a hazardous waste generator, are you prepared in the event of an emergency? Does your facility have a “contingency plan”? Both large quantity generators (LQGs) of hazardous waste and small quantity generators (SQGs) of hazardous waste must comply with certain specific emergency preparedness and prevention procedures. These procedures involve use of response equipment and […]
Q. In doing calculations for the size of containment, can you include the equilibrium volume of the inside of the storage tank as part of the containment volume? How often should a tank have integrity test done?
Q. What is the definitive procedure/test for whether a waste contains a liquid when determining D001 waste code? Must generators use the Pressure Filtration Test to determine if the waste produces a Liquid that might have a flashpoint < 140°F?
The 2012 Hazardous Waste Electronic Manifest Establishment Act (e-Manifest Act) directed the U.S. Environmental Protection Agency (EPA) to establish a hazardous waste e-manifesting system. The EPA recently proposed a system of user fees for e-manifests. Yesterday we looked at how these fees are intended to work and who will actually end up paying for the […]