The Container Is Empty, but Is It RCRA Empty?
Although it sounds like a trick question, it’s not. A container that seems empty of all its hazardous waste contents may not be empty enough to avoid being managed as a hazardous waste.
Tag: RCRA
What’s EPA Enforcement Like at Other Federal Facilities and Agencies?
The EPA’s enforcement of violations of environmental laws and regulations at federal facilities is a complicated business that has been addressed by the U.S. Supreme Court (Ohio v. United States Department of Energy, 1992, which affirmed federal facility sovereign immunity with respect to the Resource Conservation and Recovery Act (RCRA)), presidential Executive Orders, and by […]
Does Your Shipping/Receiving Clerk Need Hazardous Waste Training?
Question: If our shipping and receiving clerk is the person who receives our compressed gas tanks and they sign the manifest, do they need to be trained in Hazardous Waste Regulations RCRA or is training in just DOT ok?
The EPA, Law Enforcement, and Waste Opioids
The EPA is playing a minor but important role in the federal government’s efforts to control America’s opioid overdose epidemic. In its latest action, the Agency’s Office of Resource Conservation and Recovery (ORCR), which implements the EPA’s solid waste program under the Resource Conservation and Recovery Act (RCRA), issued a memo to encourage law enforcement […]
A Question on Hazardous Waste, GHS Labeling, and Accumulation
Experts at Enviro.BLR.com® were recently asked, “If the hazardous waste is unused and unopened and has GHS labeling on the container from the manufacturer, can you just write hazardous waste on there with the accumulation date and be compliant?” Read on to learn their answer.
EPA’s OIG Says RCRA State Authorizations Are Lagging
State implementation of the federal Resource Conservation and Recovery Act (RCRA) is not happening as Congress intended, according to a July 2018 report by the EPA’s Office of Inspector General (OIG).
A New Enviro Enforcement Roundup
While our September 2018 environmental enforcement roundup isn’t as dramatic as some of our other recent reports, it still provides valuable lessons for organizations that want to avoid becoming the next statistic. It’s also worth noting that a provider of environmental services (which you’d think would know compliance backwards and forwards) made this month’s list, […]
EPA Moves to Implement HSM Orders from D.C. Circuit
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.
Hazardous Waste Generator Rule Changes Finalized
As frequent visitors to EPA’s Resource Conservation and Recovery Act (RCRA) Online database already know, the Agency’s hazardous waste regulations prompt a constant stream of questions from both regulated entities and RCRA-authorized states about applicability, lack of clarity, and regulatory gaps. A small fraction of EPA’s answers and interpretations responding to such questions have now […]
Update to SW-846 Nonregulatory Methods
EPA’s Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, also known as SW-846, is the Agency’s official compendium of methods for use in complying with Resource Conservation and Recovery Act (RCRA) regulations. SW-846 comprises over 200 analytical methods for sampling and analyzing waste and other matrices. Most methods are intended as guidance (i.e., nonregulatory or […]