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Daniels Training Services Blog

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US EPA Regulations for the Management of Used Oil

The prospect of burning used oil on-site for energy recovery may seem daunting.  You may think that the regulatory burden and related costs would far outstrip any savings on fuel consumption.  I think you may be pleasantly surprised to learn

Hospitals and Hazardous Waste Violations

Most of the attendees at my training events – check my Schedule of Events to see when I’ll be in your area – come from the manufacturing industry.  There are many other commercial activities that are subject to the US DOT

US EPA and US DOT Regulations for the Handling and Transportation of Samples of Hazardous Materials and Hazardous Waste

Q:  I need to ship a small amount of our product (let’s say <1 gallon of a flammable solvent blend) from our distribution facility in Des Moines, IA to our QC lab in Akron, OH.  Our salespeople travel this route

The Universal Waste Option for the Management of Hazardous Waste

Recently, Waste Management LampTracker, Inc. was fined $118,800 for violations at its Kaiser, MO facility where it collects and recycles universal waste lamps, mercury-containing equipment, and batteries (US EPA news release).  Its violations include: Failure to maintain adequate aisle space

The Materials of Trade Exception for the Transportation of Hazardous Materials

As a shipper of hazardous materials, you are likely comfortable with routine HazMat shipments: Offer a hazardous material for transportation to a carrier. Carrier transports HazMat to destination. HazMat received at destination. Sometimes, however, you’re faced with a non-routine situation: 

Use of the Technical Name with the Proper Shipping Name When Shipping HazMat

When determining a proper shipping name for your hazardous materials shipment it is important to select from the Hazardous Materials Table at 49 CFR 172.101 the most specific name that best describes the hazardous material to be shipped.  Proper shipping names should

Selecting a Carrier for Your Shipment of Hazardous Materials

I have the opportunity during my weekly nationwide training events to meet with a variety of HazMat Employers  who usually are also Shippers, since they “offer for shipment” a hazardous material to a Carrier who then transports it in commerce.  For most persons, their experience

When Must an Identification Number Not be Included on a Hazardous Material Placard?

An identification number, though usually displayed on or in association with a placard on a vehicle or bulk container, must be in compliance with the Marking requirements of 49 CFR 172, Subpart D and not the Placarding requirements of Subpart

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

An Extension to the Hazardous Waste On-Site Accumulation Limits for Large Quantity Generators of Hazardous Waste that Generate F006 Wastewater Treatement Sludge from Electroplating Operations

As a Large Quantity Generator (LQG) of hazardous waste, you are aware that hazardous waste may not accumulate at your site for longer than 90 days unless it is managed in a satellite accumulation area pursuant to 40 CFR 262.34(c)(1).  However, did

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