Practical EHS Tips, News & Advice. Updated Daily.
An understanding of the Resource Conservation and Recovery Act (RCRA) term speculative accumulation is essential for managers overseeing compliance with regulations governing the generation of both hazardous waste and hazardous secondary materials (HSMs).
Q. I manage our filter cake waste as a hazardous secondary material (HSM) and notified the EPA and state environmental protection agency before managing the waste as a HSM. Are there any other reporting requirements after the initial notification?
In a final rule promulgated without a prior proposal, the EPA is revising regulations associated with the definition of solid waste under the Resource Conservation and Recovery Act (RCRA). The revisions apply specifically to rules the Agency issued in 2008 and 2015, which addressed the conditions under which hazardous secondary materials (HSMs) are legitimately recycled.
Q. We generate F006 filter cake that we ship to a recycling facility that recycles 100% of the waste. As a small quantity generator, must we include this hazardous waste toward our 1,000 kg allowed per month or is this exempt because it’s recycled?
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”?
It’s been over a year since the U.S. Environmental Protection Agency (EPA) published in the Federal Register its long-awaited final rule revising regulations affecting recycling of hazardous materials under the Resource Conservation and Recovery Act (RCRA). Known as the 2015 Definition of Solid Waste rule (2015 DSW rule), this final rule exempts certain hazardous secondary […]
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 […]