Requirements for the Management of Hazardous Waste (and Used Oil & Universal Waste) in Wisconsin

Announcements of Proposed Rules, Changes to the Rules, and Final Rules of the US DOT & US EPA – 2nd Half of February 2013

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register. Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the…

RCRA Closure Standards for Generators of Hazardous Waste

A common misconception is that the RCRA closure standards (measures a company must take upon closure to remove existing hazardous waste contamination and eliminate the potential for future contamination caused by past activities) apply solely to Treatment Storage and Disposal…

When is a Product Abandoned? When is a Product Discarded? When is a Product a Waste?

The title of this article contains three questions, but really they are all the same.  If you have a product that has been abandoned, then it has been discarded; and if a product has been discarded, then it is a…

Notice of Probable Violation of the HMR Issued to Charleston, SC Company by the PHMSA – $9,600 Fine Possible

On February 26, 2013 the Office of Chief Counsel of the Pipeline and Hazardous Materials Safety Administration (PHMSA) alleged that Hagemeyer North America of Charleston, SC violated two provisions of the Hazardous Materials Regulations (HMR). On August 23, 2012 a…

Maximum and Minimum Civil Penalties That can be Assessed by PHMSA

The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the US DOT is allowed by Federal law assess fines for what it determines are violations of the Federal Hazardous Materials Transportation Law or the Hazardous Materials Regulations (49 CFR 171-180)…

Discarded Sharps as Biomedical Waste in Florida

Except for a limited time in the past (June 24, 1989 to June 21, 1991) and within a limited range (New York, New Jersey, Connecticut, Rhode Island, and Puerto Rico) the generation, handling, transportation, and disposal of medical waste is…

DOT, Inc of Denver, CO Pays $3,876 Civil Penalty for Violations of the HMR – Including not Providing Training for HazMat Employees

On February 5, 2013 the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the US DOT signed a Compromise Order finding DOT, Inc of Denver, CO had committed three violations of the Hazardous Material Regulations (HMR).  As part of the…

40 CFR 261.4(a)(7) – The RCRA Exclusion From the Definition of Solid Waste for Spent Sulfuric Acid

General Marking Requirements for Non-Bulk Packagings of HazMat

The shipper of a hazardous material (HazMat) must ensure the correct hazard communication methods are used to identify the potential hazards posed by the material offered for transportation.  The four hazard communication methods required by the US DOT when offering…