Daniels Training Services

hazardous waste

Retail Store Chain to pay $375,000 Civil Penalty for Hazardous Waste Violations

The Bullet: A major retailer reached a settlement with USEPA regarding violations of the Federal hazardous waste regulations.  In addition to correcting the violations the retailer must pay a civil penalty of $375,000. Read the EPA news release:  EPA Announces…

Q&A: Does the new identification number package mark height requirement apply to hazardous waste lab packs?

A question from the regulated community (01.26.17): Hello, Do the new labeling requirements impact lab packs? Are they considered ‘non-bulk’ and thus must conform to the new UN size? Thanks, My reply, buying time: That’s a good question! Let me…

Marking and Labeling of Hazardous Waste Accumulation Units Under the Generator Improvements Rule

The Generator Improvements Rule (effective 05.30.17 in the regulations of the U.S. Environmental Protection Agency and states without an authorized hazardous waste program) will make many changes to the regulations applicable to a generator of hazardous waste. Read here for…

Proper Disposal of a Hazardous Material: Is it a Hazardous Waste?

On February 2, 2015 an EHS Professional who had attended one of my Training Seminars contacted me with a question: Dan, I attended your HazMat Employee & Hazardous Waste Training class last <<MONTH>> in <<CITY, STATE>>. I am hoping that you could…

Reuse of HazMat Packaging for the Shipment of Hazardous Waste

The reuse, reconditioning, and remanufacture of hazardous material packagings (both bulk and non-bulk) is addressed at 49 CFR 173.28 of the PHMSA/USDOT Hazardous Material Regulations.  In general packagings and receptacles (bulk and non-bulk) used more than once must be in…

Pennsylvania Company Guilty Plea and $1.2 Million Fine for Improper Storage of Explosive Hazardous Waste

The Bullet: The generator of a hazardous waste violated basic requirements of the hazardous waste regulations.  And, as a consequence, also violated the Hazardous Material Regulations of the PHMSA/USDOT.  These avoidable violations have resulted in significant criminal violations for this…

The Satellite Accumulation of Hazardous Waste in Missouri

In an earlier article I explained the basic requirements of the USEPAs Federal regulations for the accumulation of hazardous waste in a Satellite Accumulation Area [40 CFR 262.34(c)].  Most states with an authorized hazardous waste program incorporate the Federal regulations for…

Episodic Generation of Hazardous Waste

The RCRA regulations identify three status of hazardous waste generators determined by the amount of hazardous waste generated in a calendar month: Large Quantity Generator (LQG) – Generates ≥1,000 kg of hazardous waste or >1 kg of acute hazardous waste…

RCRA Training is the Solution for South Carolina Company Facing EPA Fines for Hazardous Waste Violations

Sumter Coatings, Inc. (SCI) in Sumter, SC must pay a $55,000 civil penalty as part of a settlement with the US Environmental Protection Agency for violations of the Resource Conservation and Recovery Act (RCRA) regulations discovered at its facility during…

Generator Determination of P- & U- Listed Hazardous Waste

A company I am familiar with is a Large Quantity Generator (LQG) of hazardous waste, largely due to the generation of what it has determined to be U-listed hazardous waste.  The point of generation for the waste is an air…