A question from a recent attendee of one of my RCRA Training Webinars (01.19.18): Thank you so much for the training this morning! Very useful information. Does a facility that has a written “No Smoking” policy (and possibly signs at…
The Requirements of 40 CFR 262.260 Purpose and Implementation of Contingency Plan for Large Quantity Generator of Hazardous Waste
Federal regulations of the U.S. Environmental Protection Agency (USEPA) at 40 CFR 262.17(a)(6) require a large quantity generator of hazardous waste (LQG) to comply with the preparedness, prevention, and emergency procedure standards of 40 CFR 262, subpart M. This article…
Q&A: Is my WWT sludge (human waste) a hazardous waste? A hazardous material?
A question (01.03.18): Daniel; I was searching Google when a link to your site came up. We are having to transport sludge and scum from an old wastewater plant across town to a newer plant. We are doing this in…
USDOT Notice of Enforcement Discretion for Cylinders
The Bullet: Due to the COVID-19 public health emergency, USDOT/PHMSA issued a notice of enforcement discretion to allow for the filling and transportation of DOT-specification cylinders with Division 2.2 Non-Flammable Gas when overdue for their periodic requalification by no more…
Q&A: Does the person signing for receipt of a hazardous materials delivery require HazMat Employee triaining?
Question (12.12.17): I have a hopefully quick question – a non-hazmat employee can sign for a delivery of a hazmat, correct? They are not unloading, just receiving hazmat to the site and signing for the load. Contact me with any…
Q&A: Is a DOT specification packaging (intermediate bulk container or IBC) required for NA3077 Hazardous waste solid, n.o.s.?
Question (12.08.17): Hi Daniel We have about forty 1,000 pound super sacks that we need to ship for disposal before the end of the year. They will ship as Environmentally hazardous Substance Solid nos UN 3077. Waste codes D007 and…
FAQ: What are Special Provisions in the USDOT/PHMSA Hazardous Materials Regulations?
A person who offers a hazardous material (HazMat) for transportation (aka: the shipper) is required to select the authorized packaging for the HazMat and follow any relevant packing instructions in the Hazardous Materials Regulations (HMR). The authorized packaging and packing…
Q&A: Must I list all overpack codes separately on the Shipper’s Declaration for Dangerous Goods?
Question: Hi, Daniel, we have an IATA question for you. Note: Note: IATA is the International Air Transport Association. It’s Dangerous Goods Regulations – updated annually – contain all of the requirements of the International Civil Aviation Organization’s (ICAO) Technical…
Attendance During Loading and Unloading of Hazardous Materials From a Cargo Tank
A cargo tank is a type of packaging that when combined with a motor vehicle for highway transportation becomes a cargo tank motor vehicle (commonly referred to as a tanker truck). While its operation on a public roadway is the responsibility…
Signing the Hazardous Waste Manifest During COVID-19 Pandemic
Sooner or later most generators of hazardous waste must prepare that waste, and offer it, for transportation to an off-site treatment, storage, and disposal facility (TSDF) for final disposal. The off-site transportation of the hazardous waste must be done in…