Tag: CFR

Getting a Handle on Handling Universal Wastes

The goal of EPA‘s universal waste rule (40 CFR 273) is to reduce the amount of hazardous waste items in the municipal solid waste wastestream and encourage recycling and proper disposal of certain common or widely generated hazardous wastes. Wastes regulated under the universal waste rules include: Batteries Pesticides Thermostats Fluorescent and high-intensity discharge lamps […]

SWPPPs–Most Often Overlooked Points

Industrial stormwater requirements are contained in national pollutant discharge elimination system (NPDES) permits; the critical element in such permits is development and implementation of a stormwater pollution prevention plan (SWPPP). These compliance tips cover key points that are sometimes overlooked in company SWPPPs and related compliance activities. Except in a relatively few cases where individual […]

Stormwater FAQs Roundup

Do I need a NPDES permit if my stormwater exposure is only in the parking lot? It may depend on several factors, including, but not limited to, the proximity of the parking lot to surface waters; the size of the parking lot; and the type of parking lot surface. A possible option that may apply […]

Universal Wastes FAQ Roundup

What are the regulations for taping/protecting the ends of batteries when preparing them for shipment/disposal? There are no requirements under EPA‘s Universal Waste regulations for taping/protecting the ends of batteries when preparing them to be sent offsite as universal waste. However, a handler of universal wastes (which includes the generator) may manage broken or damaged […]

Training Workers on Asbestos Protection

Asbestos training should match employees’ jobs. For companies in general industry, OSHA‘s detailed training requirements related to asbestos exposure (29 CFR 1910.1001(j)(7)) were designed primarily for those that use asbestos in the manufacturing process. But there is an entirely different category of workers–those in custodial or housekeeping-type jobs–who also must receive “asbestos awareness” training even […]

Does DOT Require Universal Waste Handlers to Be Trained?

Large quantity handlers of universal waste (greater than 5,000 kg of accumulated waste at any one time) 40 CFR 273.36: LQHUW must be thoroughly familiar with proper waste handling and emergency procedures relative to individual responsibilities during normal facility operations and emergencies. Some universal wastes are regulated by DOT as hazardous materials because they meet […]

Mobile Refuelers Responsibility Under SPCC

Equipment that met EPA’s definition of a mobile refueler were exempted from the sized-secondary containment requirements applicable to other types of oil-bearing equipment such as bulk storage containers or tank batteries. However, if you are a qualifying mobile refueler, you are still required to meet general secondary containment requirements. A few definitions you should know: […]

How to Tell if You Are Subject to SPCC Rules

Here are several points you should think about to determine if your facility is subject to the SPCC program: First, the program applies to capacity, not the actual amount oil stored. Second, in calculating capacity, count only containers with storage capacity equal to or greater than 55 U.S. gallons. Third, oil-filled equipment also counts in […]

TSCA and the Intent to Manufacture

If you need to determine if a specific carbon nanotube is on the TSCA confidential inventory, you can submit a Bona Fide Intent to Manufacture or Import. The required contents of bona fide intents are listed at 40 CFR 720.25 and are intended to substantiate that a company genuinely intends to manufacture the substance and […]

Why You Should Be Using an Electronic MSDS System

OSHA likes the idea too–as long as employees have immediate access. “Immediate access” means that, in emergencies, the MSDS should be available during the workshift when it was requested. In nonemergencies, it should be available by the next workshift at the latest. Your electronic MSDS system should be: Reliable. Electronic systems must provide reliable access […]