Tag: Waste

8 BMPs for Hazardous Waste Containers

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 […]

6 Tips for SQGs for Inspecting Hazardous Waste Tanks

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 […]

Do You Know the Training Requirements for Hazardous Waste Manifests?

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.” […]

Problems You May Encounter with e-Manifests

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” […]

Calculating Your Monthly Hazardous Waste Generation

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 […]

8 Tips for Reporting Your P2 Activities

While it is our contention that in this day and age most facilities are engaged in some sort of P2 to reduce chemical use and waste production, as we reported in yesterday’s Advisor, only 16% of all TRI facilities reported their P2 activities for reporting year 2013. The EPA would like to up that percentage […]

HAZWOPER—Who You Gonna Train?

HAZWOPER applies to employers involved in three general categories of work operations: Hazardous waste site cleanup operations (e.g., Superfund, voluntary cleanups, and corrective actions under RCRA) Operations involving hazardous waste at TSDFs (e.g., a landfill that accepts hazardous waste), and Emergency response operations for releases of, or the threat of release of, hazardous substances at […]

4 Extra Chemical Reporting Tips for Waste Facilities

The EPA claims that there are sufficient regulatory reasons for TSDFs to be in contact with local authorities concerning emergency procedures. The Agency points to 40 CFR 264.30 to 264.37 and 40 CFR 265.30 to 265.37, the requirements that TSDFs develop preparedness and prevention plans, and specifically 40 CFR 264.37 and 40 CFR 265.37, where […]

“In the Field and on the Floor”: 3 Steps to Ensure the Effectiveness of Your Employee Training Program

Step 1: Know Which Agency Rules Apply The U.S. Environmental Protection Agency (EPA), OSHA, and the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) each have separate training rules, but there is often overlap among the various training requirements. For example, an employer may have workers managing hazardous waste and have the […]