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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...

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12/08/2011

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...

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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...

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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....

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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...

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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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08/23/2011

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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08/17/2011

Question of the Week: 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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download our latest whitepaper

Prepared by hazardous waste training leader Lion Technology Inc., this report covers what’s happened since the new hazardous waste rules took effect.

2018 RCRA Status Report: New Hazardous Waste Rules