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Compliance Topics - Hazardous Waste

2/28/2012

Hazardous Waste Labels: Industry Standards vs. Regulations

The Hazardous Waste Label: It’s an industry standard, but not actually a Federal rule.
There is no official “EPA Hazardous Waste Label.” Instead, there are a handful of requirements from both the EPA and the DOT for marking and labeling hazardous waste containers before and during shipment. There are also many non-standardized commercial labels that meet some or...

2/14/2012

Federal Register Prints Flexibility Agendas

Yesterday, the Federal Register finally published the Fall 2011 Regulatory Flexibility Agendas, as required by the Regulatory Flexibility Act (5 USC 602). Compared to the Unified Agenda published last month (and discussed ), the Flexibility Agendas only include rules that have a significant economic impact on a substantial number of small entities (SEIOSNOSE) or are otherwise identified as significant rulemakings. Ever since the OMB took the lead on managing the agendas...

1/23/2012

RCRA Biennial Reporting

Large quantity generators and all facilities which treat, store, or dispose of hazardous waste must file a report on their waste handling activities with the EPA (or authorized state agency) by March 1 of each even-numbered year. Small and conditionally exempt generators are excluded from...

12/27/2011

RCRA State Authorization

Did you know that each U.S. state can enforce its own hazardous waste program and that each State program is unique and can vary from Federal standards?
 
When Congress first gave the U.S. EPA authority to regulate hazardous waste in the United States (the Resource Conservation and Recovery Act of 1976), they included provisions for...

12/8/2011

EPA Guidance Document: How Do I Keep My RCRA Waste Containers "Closed"?

Whether it is your 90-day storage area, your 180-day storage area, or your satellite accumulation area, all containers that contain hazardous waste must remain “closed,” except when adding or removing waste [40 CFR 265.173(a)].
 
The word “closed” is...

11/29/2011

Preparing for 2012 Reporting Obligations

Personally, the last month of the year usually means entry into the year–end holiday season. For EHS managers, this should also mean preparing your 2012 compliance calendars. These calendars will likely include various reporting obligations. While many of your reporting obligations and frequencies are site–specific (e.g., NPDES discharge monitoring reports and Clean Air Act Title V certifications), some events...

11/22/2011

Feature Article: Find Out More About Hazardous Waste Regulations

The Resource Conservation Recovery Act Is a Complex Law
The Resource Conservation and Recovery Act is a complex law that serves as the Federal basis for waste management everywhere in the country. Only a small part of the Act (Subtitle C) covers hazardous waste, and then only in broad strokes.
Understanding the law is not enough....

10/26/2011

Feature Article: Waste Minimization Plans: Requirements, Benefits, & Strategies

The Manifest Signature
When you sign a hazardous waste manifest, you are promising two things. One that you have followed all of the Department of Transportation’s regulations for packaging and shipping hazardous materials. And two, that you are minimizing your waste...

9/28/2011

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...

8/23/2011

Question of the Week: CESQG & Waste Disposal

Q. I am a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste. What requirements do I have to meet when disposing of my waste?
 
A. The EPA provides significant relief for CESQGs at 40 CFR 261.5. In order to be exempt from most of the RCRA hazardous waste regulations, most CESQGs need to do three things...

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