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09/28/2011

Question of the Week: Mixing Used Oil & Hazardous Waste

Q. If I have some used oil and mix it with hazardous waste, can I still manage it as used oil? Or is the whole mixture now a hazardous waste?
 
A. The answer is, it depends. Some mixtures of hazardous waste and used oil must be managed as...

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08/26/2011

EPA Extends Comment Period for Solid Waste Rule

August 26, 2011: At 76 FR 53376, in response to several requests from the regulated community, including the Oklahoma Department of Environmental Quality, Precious Metals Producers, and Institute of Scrap Recycling Industries, Inc., the EPA extended the comment period for the proposed rule on the definition of solid waste published in...

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08/17/2011

Can CESQGs Use the Materials of Trade Rule?

Q. I work in an R&D laboratory doing quality testing for a manufacturing plant at the other end of town. We are a conditionally exempt small quantity generator (CESQG) of hazardous waste, mostly ignitable spent solvents.
 
Our corporate EH&S specialist says we can use the Materials of Trade (MOT) rule to haul our hazardous waste across...

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08/02/2011

Question of the Week: Hazard Communication for CESQGs

Q. We are a conditionally exempt small quantity generator (CESQG). We hold waste on site in a central storage area for up to six months before we ship everything off site, but we don’t follow the actual 180–day rules while we’re storing the waste. We mark the words “Hazardous Waste” on our containers but nothing else. Since some of the waste is flammable, do we need to label the containers with either DOT labels or OSHA hazard communication labels while we’re storing them...

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07/26/2011

New Issues for Hazardous Waste Recycling

The EPA is proposing further amendments to the hazardous waste regulations in order to encourage the recycling of hazardous secondary materials while protecting low-income and minority communities from pollution. This proposal would limit the opportunities for waste generators to exclude hazardous secondary materials intended for recycling from the hazardous waste regulations. This proposal also introduces...

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07/26/2011

EPA Proposes Revised Definition of Solid Waste

Today, the Federal Register published the EPA’s latest attempt to redefine solid waste in a way that safeguards public health and the environment while also promoting the recycling of hazardous materials.
 
Today’s rule proposal was first announced over a week ago when Administrator Jackson signed the proposal just in time to comply with a consent decree between...

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07/19/2011

Question of the Week: DOT Rules for Reusing Drums for Shipping Hazardous Waste

Q. As a small manufacturer, we buy lots of chemicals each month to use as solvents, purifiers, or catalysts. When we’re done, we ship the used chemicals back to the supplier for recycling and, in many cases, eventual reuse.  
Most of the time, when we return-ship this hazardous waste, we refill the waste material into the...

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07/06/2011

EPA Proposes Modifications to 2008 Definition of Solid Waste Rule

Today, the U.S. Environmental Protection Agency announced a proposed rule to modify the 2008 Definition of Solid Waste (DSW) rule. The DSW rule had been intended to promote recycling of “hazardous secondary materials.” The EPA’s proposed modifications are in response to concerns raised by the Sierra Club and other environmental groups through various court actions...

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06/30/2011

Question of the Week: Classifying Aerosol Can Waste

Q. Are aerosol cans considered to be a D003 simply because they are pressurized?
 
A. When it comes to waste identification, it is the responsibility of the generator to make a waste determination based on all aspects of the material (40 CFR 262.11). RCRA programs in some authorized states simplify your waste classification process and declare that each and every aerosol can...

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06/13/2011

EPA Modifies LDRs for Carbamates

Today, the EPA published a direct final rule (76 FR 34147) and proposal (76 FR 34200) on LDRs for “Carbamate” production wastes and commercial chemical products containing carbamates. As existing test methods are inadequate, and it is difficult to determine the concentration of carbamates at the limits specified for land disposal, this rule modifies...

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