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HAZWOPER applies to employers involved in three general categories of work operations: Hazardous waste site cleanup operations (e.g., Superfund, voluntary cleanups, and corrective actions under RCRA) Operations involving hazardous waste at TSDFs (e.g., a landfill that accepts hazardous waste), and Emergency response operations for releases of, or the threat of release of, hazardous substances at […]
As a generator of HSM, you ultimately decide whether the material is safely managed. The decision to send your HSMs to an off-site recycling business should be followed by a careful review of the qualifications of available recyclers. Improper management can increase liability of the originating company (remember RCRA’s “cradle-to-grave” mandate). Environmental managers investigating recycling […]
New Definition of ‘Sham Recycling’ Sham recycling refers to claims by a hazardous waste generator that the waste is being recycled when it is in fact being discarded. A new definition at 40 CFR 261.2(g) codifies EPA’s concept of sham recycling: “A hazardous secondary material found to be sham recycled is considered discarded and a […]
In the June 11, 2014, Federal Register (FR), the EPA published an Information Collection Request (updated in the October 14, 2014, FR) asking for public comment concerning the hazardous waste generator rules under the Resource Conservation and Recovery Act (RCRA). Specifically, the Agency asked that the comments address the following components of the generator rules: […]
Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). Note: It is critical to remember that most states have been delegated the authority to run […]
FAQs About the Definition of Solid Waste (DSW) Rule—Part 2 Q: Does the 2014 DSW rule help to ensure that hazardous materials are actually legitimately recycled and not disposed of illegally? A: In addition to the changes to permitting and variances, the 2014 DSW rule “establishes a clear, uniform legitimate recycling standard for all hazardous […]
FAQs About the Definition of Solid Waste (DSW) Rule—Part 1 Q: What was the impetus for the DSW final rule? A: According to the EPA, the 2014 DSW final rule addresses “significant regulatory gaps in the 2008 rule” that could result in negative impacts on “communities adjacent to third-party recyclers, including disproportionately impacting minority and […]
Hazardous Waste FAQs for Construction, Demolition, and Renovation Projects by CESQGs Q: Do CESQGs have to comply with any recordkeeping and reporting requirements related to hazardous waste in C&D debris? A: As long as a generator remains a CESQG and is in compliance with the CESQG hazardous waste requirements of 40 CFR 261.5, it is […]
General Hazardous Waste FAQs for Construction, Demolition, and Renovation Q: Which regulations—federal or state—apply to C&D debris containing hazardous wastes? A: Hazardous wastes are regulated under the Resource Conservation and Recovery Act (RCRA), and most states are authorized to implement their own RCRA programs. These programs must be at least as stringent as the federal […]
Environmental Cleanups—A Changing Landscape In the United States, according to the EPA, 51 percent of the population live within three miles of one of the 156 million sites involved in cleanup under control of the Office of Solid Waste and Emergency Response (OSWER). Of these, 30% (or 91 million) are brownfields, 35% (or 106 million) […]