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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...

8/19/2011

PHMSA Proposes to Incorporate Rail Special Permits into the Hazardous Materials Regulations

Yesterday at 76 FR 51324, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed to amend the Hazardous Material Regulations to incorporate certain widely used and long-standing special permits applicable to rail transport of hazmat.
 
The special permits in question are...

8/19/2011

TSA Amends Air Cargo Screening Rules: Eliminates 3rd-Party Certifiers

Yesterday at 76 FR 51848, the Transportation Security Agency (TSA) in response to public comments amended two provisions of the Air Cargo Screening Interim Final Rule (IFR) originally issued on September 16, 2009.
 
In response to public comment, this Final Rule removes all provisions for...

8/17/2011

TSCA Inventory Update Reporting Modifications; Chemical Data Reporting

On August 2, 2011 Lion Members received our Special Bulletin issue of NewsInfo Links in which we provided notice of the pre-publication version of EPA’s final rule regarding the Toxic Substances Control Act rule for Chemical Data Reporting (40 CFR 711)
 
Well, the final rule was published...

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...

8/15/2011

EPA Rule on Carbamate Wastes Now in Effect

On Friday, the EPA finalized a rule that makes revisions to the land disposal restriction (LDR) treatment standards for Carbamate wastes at 40 CFR 268.40. These new standards are likely to impact manufacturers of certain pesticides, herbicides, or fungicides. The standard affect LDRS for the K156 – K159 and K161 process waste along with...

8/11/2011

EPA Proposes Revisions to Tier II Reports

For the first time in over 20 years, the U.S. Environmental Protection Agency (EPA) is proposing changes to the Tier I and Tier II chemical inventory reporting forms.
 
Under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), the U.S. Environmental Protection Agency (EPA) requires all facilities with an inventory of hazardous chemicals to file...

8/10/2011

The EPA’s Cross-State Air Pollution Rule

On August 8, 2011, the Environmental Protection Agency published the final version of the new Cross-State Air Pollution Rule (CSAPR) in the Federal Register(76 FR 48208). The new rule replaces EPA’s 2005 Clean Air Interstate Rule (CAIR).
 
In December of 2008, the U.S. Court of Appeals for the D.C. Circuit ordered EPA to revise...

8/9/2011

Question of the Week: Hazardous Air Pollutants: Part 61 vs. Part 63

Q. What is the difference between the “original” National Emissions Standards for Hazardous Air Pollutants (NESHAPs) of 40 CFR 61 and the “new” NESHAPs of 40 CFR 63?
 
A. Congress, through the Clean Air Act (CAA) of 1970, required the EPA to identify Hazardous Air Pollutants (HAP) and promulgate standards for each HAP. Between 1971 and 1990, the EPA...

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...

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