Compliance Topics - Hazardous Waste
9/24/2018
Beyond the "Grave": Getting LDRs Right
The RCRA hazardous waste rules regulate hazardous wastes from “cradle-to-grave.” But as generators, our responsibilities for compliance actually go beyond the grave. When you send waste off for disposal, it pays to know for sure that you’ve given your treatment, storage, and disposal facility (TSDF) the information they will need to properly lay your waste to rest.
9/24/2018
PHMSA Pre-empts California Meal Breaks for Hazmat Drivers
In California, truck drivers are entitled to a 30-minute meal period after five hours of work and a second 30-minute meal break after ten hours of work. But for truck drivers who haul hazardous materials through the state, those breaks may no longer apply.
9/20/2018
Understanding the RCRA Exclusion for Oil and Gas E&P
When US EPA introduced the Resource Conservation and Recovery Act (RCRA), the hazardous waste management standards included reduced requirements for some large-volume wastes. After studying the hazards of wastes in oil and gas exploration and production (E&P) operations, as directed by the US Congress, EPA determined regulation of these wastes under RCRA was not warranted. Therefore, many oil and gas E&P wastes are excluded from the RCRA Subtitle C hazardous waste management standards...
9/17/2018
EPA Enforcement Roundup: Week of 9/18
In this week's EPA Enforcement Roundup, a wood treatment facility and a city power and water authority will pay for hazardous waste and Clean Water Act violations, respectively. In addition, EPA will collect a civil penalty from a city-owned incinerator in New Hampshire...
8/31/2018
New RCRA Rule: Hazardous Waste Determination Recordkeeping
In some ways, it was the most significant new regulation for hazardous waste in the 21st century. In other ways, all it did was rearrange old stuff into a more convenient, intuitive order. Here we break down one of most subtle, yet impactful, changes for hazardous waste generators in US EPA’s Generator Improvements Rule.
8/13/2018
Is Every RCRA Waste a DOT Hazardous Material?
When you work in EHS, you learn fast that similar words and phrases often have distinct meanings and that understanding these meanings is crucial to staying in compliance. Terms like “hazardous waste,” “hazardous material,” “hazardous substance,” and “hazardous pollutant” look very similar...
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