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Showing posts for tag: hazardous waste

7/2/2012

DOT Training Requirements for Signing a Waste Manifest

“I have an employee that is responsible for signing the manifest for our off site shipments of hazardous waste. I have heard that this employee is subject to DOT training. If this is true, what training must I provide to this employee?”
 
This is a common question that is asked by compliance managers at sites dealing with...

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...

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...

7/19/2011

Question of the Week: DOT Rules for Reusing Drums for Shipping Hazardous Waste

Q. As a small manufacturer, we buy lots of chemicals each month to use as solvents, purifiers, or catalysts. When we’re done, we ship the used chemicals back to the supplier for recycling and, in many cases, eventual reuse.
 
Most of the time, when we return-ship this hazardous waste, we refill the waste material into the...

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...

2/22/2011

Question of the Week: Determining Significant Waste Codes

Q. When I send my hazardous waste to the treatment facility for disposal, they charge me separately for each waste code I report. Since I know some of the treatment standards overlap, is there anyway to avoid the expense and hassle of double-treating my hazardous waste?

A. There are different reasons for recording and communicating waste codes (e.g. manifests, LDRs, etc.) It is likely that you are...

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