Tag: HazWaste

Hazardous waste, chemical inventory, e-manifest, warehouse

Your Options Under the HazWaste e-Manifest Program

Effective October 1, 2019, through September 30, 2021, the EPA will apply new user fees in its hazardous waste (hazwaste) e-Manifest Program. Publication of the Agency’s fee memo provides an opportunity to review the different types of manifests regulated parties may use to meet their legal obligations.

Most Common RCRA Hazwaste Violations Concern Containers

  Failure to keep containers closed.  Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. Failure to mark the accumulation start date on the container.  Generators accumulating hazardous waste on-site without a permit must be sure to clearly mark the date on which […]

Hazmat Training Checklist for Compliance

Are you a “hazmat employer,” i.e., anyone who: Uses one or more workers to transport hazardous materials in commerce? Transports hazardous materials in commerce or causes hazardous materials to be transported or shipped in commerce? Manages packaging that is qualified for transporting hazardous materials (e.g., designs, manufactures, fabricates, inspects, marks, certifies, sells, reconditions, repairs, or […]

Compliance Tip: Delisting Your Waste

So, for example, a waste generated at your facility may meet a listing description even though the process uses raw materials different from those  EPA assumed were used when listing the waste—as such, the waste may not contain the contaminants for which it was listed. Similarly, after treatment of a listed waste, the residues may […]

Taking the Confusion Out of ‘Closed Containers’

Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]

The Controversial Contained-In Policy

One way, called the contained-in policy, attempted to smooth over the pre-existing position held by the Agency that contaminated soil that either contained a listed hazardous waste or exhibited a hazardous waste characteristic must be managed and disposed of according to all regulations governing hazardous waste (RCRA Subtitle C). Also, soil that contained listed hazardous […]

Determining Your Generator Status

Are You a LQG? If you generate 1,000 kg (about 2,200 pounds) or more of hazardous waste or more than 1 kg of acutely hazardous waste in any calendar month, you are a large quantity generator (LQG). LQGs must comply with all of EPA’s hazardous waste management rules although a partial exemption from some rules […]

Hazardous Waste Container Definitions that Stump Everyone

Containers & Tanks There’s a lot of confusion around whether a management unit is a container or a tank. Here’s the difference—you know you’re dealing with a hazardous waste container if it’s portable. A tank will always remain stationary. The RCRA hazardous waste regulations define a container as “any portable device in which a material […]

Hazardous Waste Generators FAQ Roundup

After the decision is made to vent propane from a cylinder, up until it is vented onsite, does a propane cylinder need to be managed as D001 hazardous waste? Because the container of D001 hazardous waste does not yet meet the “RCRA empty standard” (as explained at 40 CFR 261.7) the container must be managed […]