Common Violations in Hazardous Waste Satellite Accumulation Areas

The US EPA regulations at 40 CFR 262.34(c) – known as the Satellite Accumulation Area (SAA) regulations even though the word “satellite” is not used – are designed to allow a generator of hazardous waste to accumulate a limited amount…

Manufacturers of Hazardous Material Packaging & HazMat Employee Training

The regulations of the US DOT that mandate training of HazMat Employees can be found at 49 CFR 172, Subpart H.  According to §172.702(a), “A HazMat Employer shall ensure that each of its HazMat Employees is trained in accordance with…

Management of Hazardous Waste in Michigan

A short presentation I made at the 2012 Michigan Safety Conference.  If you operate a business in Michigan, you should view this short Power Point to ensure you are not guilty of one of the Michigan DEQ’s “Top Nine Waste…

Selecting Packaging for the Transportation of a Hazardous Material or Hazardous Waste

QUESTION:  “Can a plastic 55-gallon drum – or any plastic container – be used for the transportation of a flammable liquid hazardous waste?” ANSWER:  Yes.  There is nothing in the regulations of the US DOT or US EPA that precludes…

Industrial Wastewater Discharge Exclusion From Regulation as a Solid Waste 40 CFR 261.4(a)(2)

The hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) created and enforced by the US EPA include an exclusion from regulation as a Solid Waste for certain Industrial Wastewater Discharges.

Irrigation Return Flows Exclusion From Regulation as a Solid Waste 40 CFR 261.4(a)(3)

Irrigation Return Flows are excluded from definition as a solid waste under the Resource Conservation and Recovery Act (RCRA) and therefore can not be a hazardous waste. Please don’t hesitate to contact me with any questions.

The Nuclear Waste Exclusion From Regulation as a Solid Waste 40 CFR 261.4(a)(4)

Please view this short Power Point presentation to learn why nuclear waste is not regulated by the Resource Conservation and Recovery Act (RCRA) of the US EPA. Please don’t hesitate to contact me with any questions.

The Scrap Metal Exclusion From Solid Waste 40 CFR 261.4(a)(13)

The regulations of the US EPA include an exclusion from definition as a Solid Waste of Scrap Metal (as defined) being recycled. Interested in site specific training at your site that covers this topic, and more! Ask me about my…

Documenting RCRA Training for Facility Personnel

Documenting RCRA Training for Facility Personnel

Pursuant to USEPA regulations in affect prior to May 30, 2017, at 40 CFR 262.34(a)(4) a large quantity generator of Hazardous Waste (LQG) must, among other things, comply with the training requirements of §265.16.  §265.16 is meant for permitted hazardous waste…

Listed Hazardous Waste and Used Oil at a Conditionally Exempt Small Quantity Generator of Hazardous Waste

In a previous article I discussed the Used Oil Management Standard of the US EPA found at 40 CFR 279.  It allows you to manage a Used Oil according to a reduced regulatory burden even if it has the characteristics…