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Compliance Topics - Hazardous Waste

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...

8/17/2011

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...

8/2/2011

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...

7/26/2011

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...

7/26/2011

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...

7/6/2011

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...

6/30/2011

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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