Category: Q&A

Wastewater Exemption

We treat our compressor condensate prior to discharge using this a crude oil water separator in a 55 gallon drum that has a 24 gallon oil storage compartment. Does the wastewater exemption apply? We are assuming that you are regulated under the federal Spill Prevention, Control and Countermeasure (SPCC) regulations, and that your facility meets […]

Q&A: HazCom at multiemployer worksites

Recently, we received the following question from a subscriber: I need to include wording in my hazard communication program to comply with 29 CFR 1910.1200(e)(2)(iii). Do you have any suggestions?

Q&A: Recording Injuries on Multiemployer Worksites

Recently, we received the following question from a subscriber: On a multiemployer worksite, under the direction and control of a primary controlling contractor (C), one of the subcontracted employees (A) was struck by a vehicle and injured by another subcontractor (B). Whose OSHA 300 log should the injury be recorded on? The subcontractor (B) who […]

Managing Universal Waste

Q. If I’m a large quantity generator, can I take advantage of managing my universal waste rechargeable batteries and compact fluorescent bulbs at hardware retailer locations?

Exclusions to RCRA

Q. Does the addition of a spent material to wastewater treatment qualify for an exclusion to RCRA’s hazardous waste regulation?

ATE: Lead in Drinking Water

Q. Regarding the Reduction of Lead in Drinking Water Act: In the FAQ guidance from EPA, I cannot find any mention of water meters. Are they exempt?

Q&A: Vial and Syringe Disposal

Recently, we received the following question from a customer: How should we dispose of our vials and syringes? Should they be discarded separately from wastes contaminated with blood or OPIM?