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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, […]
If you have hazardous waste at your facility, you are a generator of hazardous waste. If you decide to manage some of it as universal waste, you are automatically a universal waste handler by virtue of being a generator of universal waste. Generated universal waste is not counted in a generator’s hazardous waste quantity if […]
Problem # 1: Have you crossed the line to hazmat offeror? You’re a hazardous waste generator and you have hired a hazardous waste transporter to pick up your waste and haul it off. You’ve checked everything off your Resource Conservation and Recovery Act (RCRA) checklist and you’re ready for the waste to be out of […]
Note. These BMPs reflect certain federal standards for hazardous waste container management. They do not address all the requirements for containers. Also, your state may have stricter hazardous waste container management requirements that are not reflected in theses BMPs. Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it […]
Violations of container management standards are very common and cited often by agency inspectors as the most common of regulatory violations, particularly by hazardous waste generators. Anyone who handles hazardous waste should be aware that many inspectors go to hazardous waste accumulation or storage areas first when conducting an inspection. A recent example of an […]
SQGs are those that generate more than 100 kilograms (kg) but less than 1,000 kg of hazardous waste, including no more than 1 kg of acutely hazardous waste a month. Note: 1 kg = 2.2 pounds (lb) 100 kg = 220 lb 1,000 kg = 2,200 lb While SQGs accumulating hazardous waste in tanks are […]
LQGs are those that generate either 1,000 kilograms (kg) or more of hazardous waste or more than 1 kg of acutely hazardous waste a month. Note: 1 kg = 2.2 pounds (lb) 100 kg = 220 lb 1,000 kg = 2,200 lb What’s a Tank? Although the answer may seem fairly obvious, there has been […]
According to the EPA, anyone who ships hazardous wastes off-site needs to comply with both EPA’s training requirements for generators and the U.S. Department of Transportation’s (DOT) requirements for training hazardous materials employees. The generator’s certification language on the manifest is essentially the same certification language that the DOT refers to as the “shipper’s certification.” […]
Note: A hazardous waste manifest is the shipping paper for hazardous waste. The paper manifest travels with the hazardous waste from the point of generation, through transportation, to the final treatment, storage, and disposal facility (TSDF). Each party in the chain of shipping, including the generator, signs and keeps a manifest copy, creating a “cradle-to-grave” […]
Counting Hazardous Waste You know you generate hazardous waste at your facility and you want to keep your disposal costs down. Well, then, you have to keep down the amount of hazardous waste you have on-site each month. If you are a large quantity generator (LQG), your responsibilities and costs will be greater than if […]