Q&A: Hazardous Waste (Aerosol Cans) in an Office Environment

First contact March 15, 2016: Daniel, Do empty aerosol cans that are generated in an office environment have to be treated the same as if they were generated in a manufacturing environment? We generate empty aerosol cans in our manufacturing…

12 Ways for Hazardous Waste Generators to Avoid Compliance Problems and Minimize Liability

OK,  full disclosure:  The following list borrows heavily from The Hazardous Waste Generator’s Handbook created by the Kansas Department of Health and Environment (KDHE).  I highly recommend it to any Kansas business that requires an introduction to the state regulations…

The Specification Packaging Marking Requirements of 49 CFR 178.3

Most packagings intended for the transportation in commerce of a hazardous material must be designed, manufactured, and tested to meet either a DOT specification or a UN standard, which is then known as a specification packaging (Don’t confuse “specification packaging”…

What’s Wrong with this Picture? Marking on a Hazardous Waste Container per 40 CFR 262.32(b)

It’s quite simple, really.  USEPA regulations at 40 CFR 262, subpart C require the generator of a hazardous waste to prepare it for off-site transportation according to both USEPA and USDOT/PHMSA regulations. Read all about it here:  USEPA Requirements for…

Q&A: Transporting Lead Acid Batteries for Reclamation as a Material of Trade

A former coworker contacted me with a question on January 29, 2016: I have a quick question for you Dan.  If a facility has 5 – 6 consumer (car type) lead-acid batteries that they want to take to a salvage…

Conditional Exclusion at 40 CFR 261.4(a)(20) for Zinc-Bearing Hazardous Secondary Materials Used to Make Zinc Fertilizer

Though a small part of overall fertilizer production in the U.S., the reclamation of zinc from what would otherwise be discarded as a solid waste – if done correctly – can result in a substantial benefit to the environment.  Below…