A question. May 11, 2018: Mr. Stoehr, My name is <<Redacted>>, and let me start by telling you that I have been enjoying your blogs and various compliance articles for years now. I stumbled across your page years ago searching…
Q&A: Are placards required for the transport of this two-part resin system?
A question from someone who had recently attended one of my USDOT/PHMSA HazMat Employee Training Webinars (05.17.18): Hi Daniel! We have a product in totes (Product Name part A, ###A) which is a DOT HazMat class 9 (UN: NA3082, PG…
USEPA Final Rule: Aerosol Cans as Universal Waste
Effective February 07, 2020, the U.S. Environmental Protection Agency (USEPA) is adding hazardous waste aerosol cans to the universal waste program. The Final Rule includes the following: Defines an aerosol can. Includes aerosol cans with existing management standards for other…
Q&A: Is DOT registration required for a SQG?
Question (April 13, 2018): Hi Daniel, I had a quick question about the DOT Registration requirement (Subpart G). If a SQG of HW ships their waste (e.g. 3 drums >1001 lbs -needs placard) with Safety Kleen, the SQG needs to…
FAQ: What is an aerosol can?
Aerosol cans are widely used for dispensing a broad range of products including paints, solvents, pesticides, food and personal care products, and many others. the Household and Commercial Products Association estimates that 3.75 billion aerosol cans were filled in the…
Q&A: Which are required to be displayed on IBCs: placards or labels?
A question from a repeat customer on June 8, 2017. (I’m frequently contacted by customers in the interim between their periodic training to answer questions). Hi Dan, I hope this finds you doing well. During the training session back in…
Q&A: What must a carrier know before transporting “empty” drums?
Question (05.02.18): I am in the State of <<REDACTED>> and need to know the regulations regarding picking up and hauling empty drums. I work for an Oil Company that delivers and picks up drums. When picking up drums we sometimes…
Preparedness, Prevention, and Emergency Procedures for Large Quantity Generator of Hazardous Waste
Both large quantity generators (LQG) and small quantity generators (SQG) of hazardous waste are required by federal regulations of the United States Environmental Protection Agency (USEPA) to take certain measures and have available certain equipment in order to prevent hazardous…
The Requirements of 40 CFR 262.256 Arrangements with Local Authorities 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…
Preparedness, Prevention, and Emergency Procedures for Small Quantity Generator of Hazardous Waste
Both large quantity generators (LQG) and small quantity generators (SQG) of hazardous waste are required by federal regulations of the United States Environmental Protection Agency (USEPA) to take certain measures and have available certain equipment in order to prevent hazardous…