Tag: Waste

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 […]

Four Factors for Recycling Hazardous Waste Secondary Materials Without Shame—I mean Sham

New Definition of ‘Sham Recycling’ Sham recycling refers to claims by a hazardous waste generator that the waste is being recycled when it is in fact being discarded. A new definition at 40 CFR 261.2(g) codifies EPA’s concept of sham recycling: “A hazardous secondary material found to be sham recycled is considered discarded and a […]

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: […]

Got Hazardous Waste? Can You Avoid Becoming an Episodic Generator?

Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). Note: It is critical to remember that most states have been delegated the authority to run […]

2013 TRI National Analysis—Pollution Prevention and Waste Management

2013 TRI National Analysis—Pollution Prevention and Waste Management One of the biggest challenges for anyone that produces toxic chemical wastes is to find ways to minimize disposal. The generally followed hierarchy of choices begins with source reduction, and moves down to recycling, then energy recovery, treatment, and finally, disposal or other releases. During the past […]

FAQs About the Definition of Solid Waste (DSW) Rule—Part 2

FAQs About the Definition of Solid Waste (DSW) Rule—Part 2 Q: Does the 2014 DSW rule help to ensure that hazardous materials are actually legitimately recycled and not disposed of illegally? A: In addition to the changes to permitting and variances, the 2014 DSW rule “establishes a clear, uniform legitimate recycling standard for all hazardous […]

FAQs About the Definition of Solid Waste (DSW) Rule—Part 1

FAQs About the Definition of Solid Waste (DSW) Rule—Part 1 Q: What was the impetus for the DSW final rule? A: According to the EPA, the 2014 DSW final rule addresses “significant regulatory gaps in the 2008 rule” that could result in negative impacts on “communities adjacent to third-party recyclers, including disproportionately impacting minority and […]