Prior to the Generator Improvements Rule the regulations for generators accumulating hazardous waste in a satellite accumulation area (SAA) required containers accumulating hazardous waste to be kept closed except when necessary to add or remove waste. Under the new rule,…
The USEPA Regulations for “Closed Containers” of Hazardous Waste
Generators of hazardous waste should be aware of the packaging requirements of the U.S. Department of Transportation (USDOT) when shipping their hazardous waste off-site for final treatment and disposal: the packaging must be in good condition, approved by the USDOT…
Weekly Inspections of Hazardous Waste Containers in Central Accumulation Area
The regulations of the U.S. Environmental Protection Agency (USEPA) promulgated under the Resource Conservation and Recovery Act (RCRA) allow generators of hazardous waste to be exempt from many of the requirements applicable to a permitted or interim status treatment, storage,…
Q&A: Is a DOT specification packaging (intermediate bulk container or IBC) required for NA3077 Hazardous waste solid, n.o.s.?
Question (12.08.17): Hi Daniel We have about forty 1,000 pound super sacks that we need to ship for disposal before the end of the year. They will ship as Environmentally hazardous Substance Solid nos UN 3077. Waste codes D007 and…
Specification Packaging Markings on Intermediate Bulk Containers of Hazardous Materials
Like all packagings used for the transportation in commerce of a hazardous material an Intermediate Bulk Container (IBC) must be authorized for the HazMat it is intended to contain. It must also, unless an exception is used, be designed, manufactured, and tested…
Question Regarding Containers for Universal Waste Lamps
From a past attendee of one of my Training Seminars – now defunct – on May 19, 2015: Dan, I seem to recall hearing that the EPA does not like the telescoping boxes for used lamps. I can only assume…
USEPA Requirements for the Packaging, Labeling, and Marking of a Hazardous Waste Container for Off-Site Transportation
Both Large Quantity Generators and Small Quantity Generators of hazardous waste are responsible for the cradle-to-grave management of the hazardous waste they generate. One of their responsibilities is to properly identify containers of hazardous waste when it is accumulated on-site and…
Day Accumulation Containers for Hazardous Waste in Kansas
Just like every other state with an authorized hazardous waste program Kansas allows a generator to accumulate hazardous waste without a permit in what is known as a Satellite Accumulation Container. Most states (Missouri and California being exceptions) will allow…
Weekly Inspections of Hazardous Waste Containers in Satellite Accumulation Areas
Both Large and Small Quantity Generators of hazardous waste (LQG & SQG respectively) are required to conduct weekly inspections of their hazardous waste accumulation areas; typically referred to as Central Accumulation Areas (CAA’s) or 90 (for LQG’s) or 180 (for SQG’s)…
Satellite Accumulation of Hazardous Waste Under the Generator of Improvements Rule
The option to manage hazardous waste in a satellite accumulation area (SAA) in addition to or instead of a central accumulation area (CAA) is available to both the large quantity generator of hazardous waste (LQG) and small quantity generator of…