Practical EHS Tips, News & Advice. Updated Daily.
Q. We generate F006 filter cake that we ship to a recycling facility that recycles 100% of the waste. As a small quantity generator, must we include this hazardous waste toward our 1,000 kg allowed per month or is this exempt because it’s recycled?
Q. The wrong feedstock was placed in Tank A which holds a different one. The resulting mixed ignitable material (D001) is not usable. We intend to move this mixture out of Tank A quickly. Is Tank A subject to RCRA, or is it still a product tank?
Q. What is considered “oil?” I have had some conversations with the EPA that the Coast Guard’s list of regulated oils is broad, including automotive gas, hexane, mineral spirits, jet fuel, etc.
Q. Are there compliance issues that would prevent our installation of a compressor on a concrete slab on which our (now clean-closed) RCRA-permitted hazardous waste boiler sat? Our Closure Plan states that we will close the slab when the facility closes.
Q. If there is a spill of 50 gallons during delivery, do we need to add that in the spill history in the Spill Prevention, Control, and Countermeasure (SPCC) Plan?
Recently, one of our subscribers asked the following question: Are there any regulations regarding the storage of DEF fuel additives? This was our answer:
Recently, one of our subscribers asked the following question: Is there anywhere specific an eyewash station needs to be placed in a facility? This was our answer:
Q. What states require broken fluorescent bulbs to managed as hazardous waste, instead of Universal Waste?
Recently, we received the following question from a subscriber: What does OSHA say about initial entry into an area with a suspected gas leak of anhydrous ammonia of unknown quantity and the use of an SCBA?
Q. We spray paint small items such as pumps and motors and puncture the empty paint cans to capture the remaining teaspoon or so of paint that is placed in a drum. Is this remaining paint a hazardous material, and if so, how should we label the drum?