Category: Hazardous Waste Management

Determining Your Generator Status

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 […]

Hazardous Waste Container Definitions that Stump Everyone

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 […]

Hazardous Waste Generators FAQ Roundup

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 […]

Hazardous Waste Recordkeeping Checklists for RCRA, Exporters, and Land Bans

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 […]

Regulated Hazardous Waste 101

Is the material a solid waste? Is the waste specifically excluded from RCRA’s hazardous waste regulation? If the waste is a solid waste, is the solid waste “hazardous”? This requires you to determine: Is the waste a “listed” hazardous waste? Does the waste exhibit one or more of the four characteristics of hazardous waste? Is […]