Practical EHS Tips, News & Advice. Updated Daily.
In order to manage the wastes safely and properly, your workers at sites that handle them must be trained in waste management techniques and how to respond appropriately to releases that occur. But your training efforts are wasted if you can prove that workers completed it. Keeping good training records is not only good practice, […]
While there are no federal limits on formaldehyde in clothing, a recent report by the Government Accountability Office (GAO) may cause Congress and advocacy groups to put pressure on the Consumer Product Safety Commission (CPSC) to revisit the feasibility of imposing such limits. Formaldehyde is a heavily regulated substance and one of a handful of […]
The problem is so prevalent at colleges and universities that EPA developed a regulatory option (new RCRA Subpart K), intended to encourage officials in charge of thousands of academic labs to periodically collect old, unneeded, or expired chemicals (legacy chemicals), determine whether these chemicals are hazardous, and properly manage their disposal. If you are an […]
Note that the rule is not regarded by EPA as more stringent than existing regulations. This means that states authorized to run the federal RCRA program are not required to adopt the rule. In fact, while some states have adopted it since promulgation, others have expressed their opposition to it, and the rule may not […]
Waste management is included under the TRI definition of toxic chemicals that are otherwise used, which refers to activities that are not manufacturing or processing. TRI requires that subject facilities report releases and other waste management of listed chemicals. Facilities must also report transfers of toxic chemicals for waste management to off-site locations. Waste management […]
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 […]
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 […]
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 […]
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 […]
Here’s a quick checklist of the paperwork you should have for your RCRA, hazardous waste exporting, and land ban requirements. RCRA Have you kept the following hazardous waste records for specified periods of time (if applicable)? Copies of a small quantity generator’s “reclamation agreement” for at least 3 years after the agreement’s termination or expiration […]