RCRA Training Checklist All Generators Can Use

(This checklist includes requirements for small quantity generators of hazardous waste, which are not covered under 40 CFR 264.16 and 40 CFR 265.16.) Do you generate RCRA hazardous waste? If yes, are you a conditionally exempt small quantity generator (CESQG) (under federal definition, the generator of 100 kilograms (kg) or less per month of nonacute […]

2011 Hazardous Waste Report Due March 1

By Elizabeth Dickinson, J.D. BLR Legal Editor Referred to by the U.S. Environmental Protection Agency (EPA) as the Hazardous Waste Report (EPA Form 8700-13 A/B), and by those in the environmental management field as the Biennial Report, the report must be submitted by March 1 of every even-numbered year with information of the facility’s hazardous […]

RCRA Training: Who Needs It?

All Facilities Applicants for a permit to operate a hazardous waste facility must include in the permit application a written outline of both the introductory and continuing training programs by owners or operators to prepare persons to operate or maintain the facility safely. Large Quantity Generators (LQGs) LQGs that accumulate hazardous waste on-site for 90 […]

Key Elements of EPA’s Academic Lab Rule

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 […]

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 […]