Tag: Waste

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 […]

Four Tips for Choosing a Recycler for Your Hazardous Waste Secondary Materials

As a generator of HSM, you ultimately decide whether the material is safely managed. The decision to send your HSMs to an off-site recycling business should be followed by a careful review of the qualifications of available recyclers. Improper management can increase liability of the originating company (remember RCRA’s “cradle-to-grave” mandate). Environmental managers investigating recycling […]

What’s in Store for Hazardous Waste Generators?

In the June 11, 2014, Federal Register (FR), the EPA published an Information Collection Request (updated in the October 14, 2014, FR) asking for public comment concerning the hazardous waste generator rules under the Resource Conservation and Recovery Act (RCRA). Specifically, the Agency asked that the comments address the following components of the generator rules: […]