The federal regulations of the U.S. Environmental Protection Agency (USEPA) at 40 CFR 261.7(a)(1) read, “Any hazardous waste remaining in either: an empty container; or an inner liner removed from an empty container, as defined in paragraph (b) of this…
Q&A: Can my customer return empty HazMat packagings to me for reuse?
eMail of May 13, 2020: As discussed on the phone this afternoon, <<Company>> is a specialty chemical company supplying a wide range of Industrial Chemicals, some of which are considered hazardous (most because they contain either caustic or acidic components…
RCRA Training Options & Pricing
As a generator of hazardous waste you are responsible for the cradle-to-grave management of all waste created at your site or by your operations. Part of a generator's cradle-to-grave responsibility is to provide training for Hazardous Waste Personnel; aka: RCRA Training. Daniels…
Q&A: Are my “empty” tanks subject to USDOT regulations?
Here’s a question from September 18, 2017. This guy had done his research (you can tell by his questions) but still required some guidance through the USDOT/PHMSA Hazardous Materials Regulations: Good afternoon, I’ve been doing some digging and I think…
Q&A: What can we do with empty oil drums?
A question from someone in industry about empty oil drums (April 18, 2017): Hello my name is <<Name>> and I work for <<Company>>, I have a simple question we use 55 gallon metal and plastic drums to contain our oil…
Got a Question? Dear Mr. Daniels…The Empty Packaging Exception and the HazMat Endorsement on the CDL
One of the things I love about my business is being able to answer someone’s question about the transportation of hazardous materials or the management of hazardous waste. Some questions have an easy answer, but a complicated explanation, and those…
Shipment of Empty HazMat Packagings and the Need for HazMat Labels, Placards, Markings, & etc.
49 CFR 173.29 contains the PHMSA/USDOT regulations for the transportation of empty packagings that last contained hazardous materials. As a shipper of hazardous materials you must be aware of §173.29(a) which states that an empty packaging with the residue of…
Container Weight in the Calculation of Hazardous Waste Generator Status for RCRA
After the hazardous waste determination, the single most important responsibility of any hazardous waste generator is to determine their hazardous waste generator status. The USEPA identifies three (3) status of hazardous waste generators (note that your state may not recognize…
Management of Empty Containers in Texas
As a state with an authorized hazardous waste program, Texas has its own regulations for the management of hazardous waste enforced by the Texas Commission on Environmental Quality (TCEQ). In addition, Subtitle D of the Resource Conservation and Recovery Act…
Empty Steel Aerosol Cans as a Reactive Hazardous Waste (D003)
Pursuant to 40 CFR 262.11 it is the responsibility of the generator to determine if the waste they generate is hazardous. This responsibility applies to empty steel aerosol cans that are likely generated somewhere within your facility (think: Maintenance). While…