Category: Ask the Expert

The Headworks Exemption

Q. Does the headworks exemption at 40 CFR 261.3 (a)(2)(iv)(A) and (B) apply only to those spent solvents identified in the regulation? If you are below the threshold for the identified solvents, can other solvents be considered exempt?

Removing Mold

Q. Is there a single resource, which list by State, whether a licensed contractor is required to remove mold?

Hazardous Waste Manifest

Q. What EPA Hazardous Waste Number should be assigned on the Hazardous Waste Manifest when shipping for disposal un-punctured, aerosol cans with carbon dioxide propellant that are assumed to be empty of the product they were intended to spray (e.g. paint)?

Solvent Contaminated Wipes

Q. Does the solvent contaminated wipes 180-day accumulation limit mean we accumulate and send wipes for disposal within 180 days or accumulate for 180 days and store on site for another amount of time?

Biennial Report

Q. We store Lead Metal Scrap on our property and sell it to recyclers. Would I mark Item 12 “Notification of Hazardous Secondary Material Activity” on the 2015 biennial report as “Yes” or as “No”?

SDS Requirements

Q. Can you provide some guidance on how to satisfy the requirements of the Safety Data Sheet (SDS) information without revealing the names or Chemical Abstracts Service (CAS) numbers of the chemicals we use in our mixtures?

Spill Reporting

Q. Would flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine Spill Prevention, Control, and Countermeasure (SPCC) applicability if they are stored in 55 gallon drums or greater?

TRI Reporting

Q. An EHS chemical, Sulfuric Acid, exceeds 500 pounds. Therefore aggregation of Sulfuric Acid containing compounds is required in TRI reporting. In that aggregation, are lab chemicals included or exempted?

Flammable Substance Threshold

Q. Would the risk management plan (RMP) flammable substance exemption include warehouses? We will store cans of foam containing isobutane. Will the RMP regulations apply?