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06/24/2014

Crushing Mercury Lamps: When Is It Acceptable?

The fluorescent lamps in offices and facilities across the US use mercury vapor for illumination. Under the US EPA’s RCRA regulations, wastes that contain elevated levels of leachable mercury compounds are hazardous waste. [40 CFR 261.24] When you discard the bulb from a tube or compact fluorescent lamp, you are discarding hazardous waste. Because nearly every office and business in the country generates this kind of waste...

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04/29/2014

Managing Universal Waste-State and Federal Rules

In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA), a law authorizing the US EPA to regulate the management of hazardous waste from the point of generation to disposal, or “cradle to grave.” Under RCRA, states can create and administer their own hazardous waste programs, provided the State program is no less protective than the Federal standard. ..

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03/25/2014

Reusing Waste and Avoiding Sham Recycling

To encourage recycling and keep more hazardous waste out of landfills and the ecosystem, the US EPA established the “reuse relief” in its hazardous waste regulations. The relief, found at 40 CFR 261.2(e), excludes certain materials from the definition of solid waste when they are reused in a beneficial way. In general, the exclusion applies when an otherwise hazardous waste is reused in one of three ways...

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02/25/2014

Management Strategies for Using RCRA Exclusions

At first glance, managing hazardous waste in a way that relieves the generator from some RCRA regulations may seem very appealing. In some cases though, these management strategies may not provide as much relief as initially believed and may make subsequent management decisions even more difficult. One scenario that raises this challenge is the EPA’s exclusion for certain de-characterized hazardous wastes...

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01/28/2014

Simplify Your Approach to Waste ID

Identifying hazardous waste and assigning waste codes is one of the most complex responsibilities in waste management. Many factors need to be considered when making this determination, including the waste’s properties, the hazards it poses, and even the industry in which it was generated.
The EPA’s Resource Conservation and Recovery Act (RCRA) regulations provide a complex system of lists that personnel must use to...

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12/31/2013

Top Compliance Articles of 2013

For the annual year-end edition, we’ve collected the most popular articles from 2013, covering the major happenings that may have affected your facility. From new rulemakings and requirements to tips on inspections and help planning for next year, these compliance articles stood above the rest...

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12/30/2013

Plan Ahead for 2014 Biennial RCRA Reports

As the 2013 calendar year winds down, hazardous waste generators begin buttoning up their recordkeeping for the current year and planning for 2014. This process most likely includes confirming that all facility personnel completed their annual training, all manifests are accounted for, all waste and LDR determination records are in order, and their contingency plan is current. In addition to the usual year-end wrap-ups, this year...

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11/26/2013

New RCRA Exclusion for Solvent-contaminated Wipes

On July 31, 2013, at 78 FR 46448, the United States Environmental Protection Agency (EPA) promulgated a new final rule to relax hazardous waste management requirements for solvent-contaminated wipes (i.e., shop towels). Solvent-contaminated wipes that are laundered will be conditionally excluded from regulation as solid waste. Solvent-contaminated wipes that are discarded will be...

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10/29/2013

Scary Stories of Noncompliance

As Halloween approaches, you are probably hearing a lot of scary stories. You may enjoy these tales of terror, but if you are not careful with how you manage your facilities, you may find yourself in a scary story of your own...

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10/22/2013

Cutting Costs With Life Cycle Assessment

Life Cycle Assessment is a critical tool for organizations seeking ways to reduce their environmental impact, manage waste more efficiently, and reduce compliance costs. Also called life cycle analysis or “cradle-to-grave” analysis, a Life Cycle Assessment (LCA) is designed to gauge how a product will impact the environment throughout its life—from the initial sourcing of raw materials to eventual waste disposal...

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