I have learned that when it comes to the hazardous waste regulations codified under RCRA, California is different. And here is just one example of it: buried in the California Health and Safety Code at 25160.7 is a requirement for…
HazMat and Hazardous Waste at the Hotel
I spend a lot of time in hotels when I travel in order to provide the training required for businesses subject to the Hazardous Material Regulations of the PHMSA/USDOT and those subject to the hazardous waste regulations (codified from RCRA) of…
Placement of Placards on a Vehicle and 49 CFR 172.516(c)(2)
Pursuant to 49 CFR 172.516(c)(2): Each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device must— (2) Be located clear of appurtenances and devices such as ladders, pipes, doors, and tarpaulins; Notice how the placard holders on…
The New Definition of “Contained” From the 2015 Definition of Solid Waste Final Rule
In the January 13, 2015 Federal Register the USEPA announced its Final Rule for the Definition of Solid Waste (2015 DSW) which revised – and is supposed to correct deficiencies in – the 2008 Definition of Solid Waste Final Rule…
Web-Based RCRA Training: Is it right for you?
I hear it often from potential customers: while they prefer Seminars and Onsite Training, and they may be interested in a Learning Management System, they have little to no interest in Web-Based Training. “They’re dull, uniform, not engaging, too passive,…
What are PHMSA Interpretation Letters?
Sometimes the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) of the PHMSA/USDOT are not enough. If you find yourself in a situation where you cannot find an answer to your HazMat transportation question you have three options: Apply your…
There’s Still Time! Take Part in the PHMSA’s HM-ACCESS Data Collection Effort
Sounds exciting, doesn’t it? The Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) HM-ACCESS (Hazardous Materials-Automated Cargo Communications for Efficient and Safe Shipments) Project, also known as the Paperless Hazard Communications Pilot Program. It just kinda’ rolls of the tongue and…
Common RCRA Violations From the USEPA
You hear from guys like me all the time that the regulations of the Resource Conservation and Recovery Act (RCRA) – both State and Federal – are important. But which ones are the most important? Which of all of the…
Banned From Landfill Disposal in California
Generators of both RCRA hazardous waste and Non-RCRA hazardous waste in California must also be aware of the State’s ban on the landfill disposal of certain wastes. Take a look at the list below. Are any of these wastes in…
Q&A: What are the Shipper’s Responsibilities for the Transport of Diesel Residue in Fuel Tank Trailers?
Question to the Contact Me page of my website on March 7, 2015: Looking for guidance on the shippers responsibilities in reference to DOT hazmat regs when shipping empty 6,000 fuel tank trailers. The tank trailers have been re-built, pump tested,…