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What is a hazardous substance?

OSHA developed the HAZWOPER Standard to protect emergency responders, site cleanup workers, and others who may be exposed to "hazardous substances." In the HAZWOPER regulations, OSHA defines "hazardous substances" to include four categories:

"CERCLA Hazardous Substances"
(Listed in 40 CFR 302.4)

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) authorizes US EPA to maintain a list of substances that can damage the environment if released. The list of CERCLA hazardous substances includes hundreds of substances, from acetone and ammonia to xylene and zinc.

"Hazardous Materials"
(As defined by 49 CFR 171.8)

The US Department of Transportation (DOT) defines a “hazardous material” as any substance or material that meets one or more of the criteria of a Hazard Class or Division described in 49 CFR 173, or any material that does not meet those criteria but DOT deems a hazardous material (e.g., Class 9).

"Hazardous Waste"
(As defined by 40 CFR 261.3)

Under the Resource Conservation and Recovery Act (RCRA), a hazardous waste is a waste that either:

Exhibits one or more hazardous waste characteristics (ignitability, corrosivity, reactivity, or toxicity), or
Is described on one of the lists of hazardous wastes in the RCRA regulations (F, K, P & U).

"Biological agents"
and "other disease-causing agents"

Agents "...which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person...will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions, or physical deformation..."

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I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

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Use this guide to spot which tanks and substances are regulated under EPA's Underground Storage Tank program, and which are excluded as of October 2018.

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