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Cradle to Grave Under RCRA and CERCLA
RCRA - the Resource Conservation and Recovery Act - was passed in 1976 to amend the Solid Waste Disposal Act of 1965 and to address a growing national concern over the improper management and disposal of both hazardous and non-hazardous
The Top Six Hazardous Material Transportation Violations
The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the US DOT is tasked with enforcing the nations hazardous materials transportation regulations across all modes of transportation. The unannounced inspections of its agents of the regulated community, ie. shippers, receivers,
D002 Corrosive Hazardous Waste Determination
The characteristic of corrosivity is one step of the hazardous waste determination process that you must complete for every waste stream that you generate. Your waste is a corrosive hazardous waste, with waste code D002, if a representative sample has
The Seven Kinds of Training Providers
If you've been through some type of regulatory training, it's likely you've seen one or more of these... "The Professor" - A dry, technical presentation; packed with information, but assuming a higher level of regulatory awareness than that of the
Inherently Waste-Like
40 CFR 261.2 defines a solid waste as any discarded material not excluded by regulation, variance, or non-waste determination. A discarded material is any material which is: Abandoned, Recycled, Considered inherently waste-like as described in paragraph (d), or A military munition
Exception to the Segregation Restrictions of 49 CFR 177.848 for Lab Packs of Hazardous Waste
49 CFR 173.12 contains many exceptions to full regulation for shipments of hazardous waste in a lab pack. In an earlier blog post I discussed the exception in 173.12(d)that removes the need to include the technical name of a hazardous
Extensions to the 90/180 Day On-Site Accumulation Time Limits for Hazardous Waste Generators
If you are a generator of hazardous waste, one regulatory requirement you are no doubt familiar with are the limits on the number of days you may accumulate hazardous waste on-site without a permit. These limits are: Large Quantity Generator
Understanding the Structure of the Code of Federal Regulations
You may have heard of the Resource Conservation and Recovery Act (RCRA) or the Hazardous Materials Transportation Uniform Safety Act. These Acts passed by Congress and signed by the President typically contain broad outlines of what the government wishes to
US EPA Compliance and Enforcement Annual Report for 2011
You are no doubt aware that the US Environmental Protection Agency is serious about enforcing its regulations in order to live up to its mandate to protect the environment. The Office of Enforcement and Compliance Assurance (OECA) within the US
Hazardous Waste Determination: D001 Ignitable
A person that generates any waste is required to determine if that waste is a hazardous waste pursuant to the method identified in 40 CFR 262.11. The US EPA has identified two different categories of hazardous waste: listed and characteristic. To be listed a