Category: Ask the Expert

Q&A: Anhydrous Ammonia Leaks

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?

Is Paint a Hazardous Waste?

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?

Q&A: Electronic Recordkeeping Rule

Recently, we received the following question from a subscriber about OSHA’s new Electronic Recordkeeping rule: What is the new OSHA tracking rule all about, and when will it go into effect? This was our response:

Q&A: Flammable Liquids in Spray Bottles

Recently, one of our subscribers asked the following question: We have a lacquer thinner solution, a Category 2 flammable liquid, and plan to dispense it from an ordinary quart-sized spray bottle. The solution will be used as a cleaning solution; spray on and wipe off. Will this be a violation of any sort, NFPA or […]

SPCC: Trucking Terminal

Q. Does a trucking terminal need an SPCC plan? A. Although the SPCC regulations are geared to non-transportation-related facilities, in the transportation sector, SPCC rules also apply to many terminals and maintenance facilities, depending on their location and the amount of oil stored on site. A trucking terminal is subject to the rule if it […]

SPCC: Secondary Containment

Q. In an automobile dealership service department, can the floor (inside of a building) or oil/water separator drains be counted as secondary containment for containers ranging from 55 gallons (gals) to 500 gals?

Used Oil Management

Q. As long as the used oil’s flash point is => 140°F, can my spent acetone (used as a degreaser) be disposed of in my onsite oily wastewater treatment facility that has two 30,000 gallon used oil tanks holding used oil sold as on-spec oil?

Reusing Drums for Transport

Q. Can we reuse drums with UN rating code Y1.5/100 to transport two hazardous wastes with the DOT UN numbers of UN1263 and NA3077?

CESQG Status

Q. Can we keep our CESQG status if we ship more than 220 lb (e.g. 400 lb) of waste accumulated over an extended period?

Boiler MACT

Q. Will a source having four large gas fired boilers with fuel oil back up trigger the Boiler Maximum Achievable Control Technology Standards (MACT) if it burns oil to avoid high natural gas prices?