Category: Hazardous Waste Management

The Hazmat Employee and Training—Most Misunderstood Regs

The issue of responsibility for training comes up frequently because third parties frequently enter the picture.  For example, the hazmat employer may contract an outside firm to provide training to employees. Or the hazmat employer may retain subcontracted employees. Would the training company or the subcontracting company be liable if the training was found to […]

RCRA-Approved BMPs for Your Contaminated Rags

Find a Solvent Alternative Find out if there is an aqueous or semi-aqueous cleaner you can use instead of the solvent. This can eliminate solvent wastes and the toxicity of used shop towels altogether. Consider using solvents that are not chlorinated and have low volatile organic compound emissions; consult material safety data sheet information for […]

To Manifest or Not

Here’s the answer. Manifest procedures for shipments of containers that do not meet the EPA definition of “empty” (as defined in 40 CFR 261.7) are addressed in the federal regulations at 40 CFR 263.21(b) and 40 CFR 264/265.72. Container residues, which are residues that exceed the quantity limitations for an “empty container,” are considered a […]

A Heads Up On the Future of RCRA

They’ve identified forces that might shape a future waste and materials management program and suggested goals and the strategies that might be used to achieve those goals. The stated objective of the work group findings was to stimulate thought and discussion about RCRA’s future without representing any formal federal or state agency policy or promoting […]

What’s Happening with USTs in 2012

Secondary containment requirements for new and replaced tanks and piping Operator training requirements Periodic operation and maintenance requirements for UST systems New release prevention and detection technologies The amendments will also remove certain deferrals; update codes of practice; and update state program approval requirements to incorporate these new changes.

2011 Hazardous Waste Report Due March 1

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 […]

Universal Waste Lamps: Working Out a Recycling Program

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 […]