Daniels Training Services

hazardous secondary material

Q&A: Can I store drums of hazardous waste with non-hazardous waste?

An assumption, some research and a question (02.21.17): Hi Daniel, I always thought that RCRA Hazardous waste regulations require hazardous waste drums not be stored with non-hazardous waste drums.  However, I scanned through 40 CFR and don’t see where it…

40 CFR 261.4(a)(23) The Generator-Controlled Exclusion

The 2015 Definition of Solid Waste Final Rule retained this conditional exclusion first created by the 2008 Definition of Solid Waste Rule.  However, not satisfied with the level of environmental protection it provided EPA strengthened its provisions.  In this presentation…

The Verified Recycler Exclusion for Hazardous Secondary Materials at 40 CFR 261.4(a)(24)

The generator of a hazardous secondary material may choose to manage it according to the conditions of 40 CFR 261.4(a)(24) and thereby exclude it from regulation as a solid waste. However, compliance with its conditions is required for all persons…

2015 DSW and the Legitimate Recycling Provision for Hazardous Secondary Materials

The 2015 Definition of Solid Waste Final Rule (2015 DSW) was issued on January 13, 2015 and became effective in the Federal EPA regulations on July 13, 2015. It’s effective date in the individual states depends upon several factors, (read:…