PO Box 1232 Freeport, IL 61032

A Different Kind Of Training

A Different Kind Of Training

A Different Kind Of Training

Arizona Department of Environmental Quality

Free Hazardous Waste Workshops in April by the Arizona DEQ

Arizona Department of Environmental QualityADEQ’s free hazardous waste workshops will consist of two presentations. Session 1 is, “An Overview of Hazardous Waste Management,” which will provide an overview of the Resource Conservation and Recovery Act (RCRA) and Arizona’s hazardous waste regulations. This presentation is intended for those that are new to hazardous waste management, new to Arizona, or anyone interested in a refresher of the regulations.

Session 2 is the, “Achieving RCRA Compliance” presentation which will provide a more in-depth discussion of topics including waste determination, treatment, storage and disposal (TSD), waste handling and management, emergency prevention and preparedness and contingency plans. This presentation is intended for those with basic RCRA knowledge who are looking to understand the regulations in more detail.

Workshops will also include presentations from the Pollution Prevention Program (Phoenix sessions only), and on how to correctly fill out and submit manifests (Phoenix and Tucson sessions).

2015 Workshops
April 7 State of Arizona Regional Office Complex (Tucson) Click for Registration
April 14 Arizona Department of Environmental Quality Click for Registration
April 29 Arizona Department of Environmental Quality Click for Registration

If you can’t make these workshops but are still interested in the Arizona hazardous waste regulations, please contact me.  I’m happy to answer any questions you may have.

February 2015 – Rules & Regulations, Proposed Rules, and Notices Regarding the Management of Hazardous Waste and the Transportation of Hazardous Materials

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Federal Register logo
The Federal Register is the tool used by the US Government to communicate with interested parties

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA), Federal Railroad Administration (FRA), and the Federal Aviation Administration (FAA) of the US DOT on the subject of Transportation of Hazardous Materials.

The Federal Register is a great way to look down the road and see potential changes to the regulations long before they are put into effect (sometimes The Rulemaking Process takes years before a final rule is issued, if ever).  Knowledge of these potential changes provides you with several advantages:

  • Additional time to modify your business operations to comply.
  • Awareness of on what topics the regulatory agencies intend to focus their efforts.
  • The ability to register your concerns, complaints, suggestions, etc. in order to modify the proposed rule before a final rule is issued.  It can be done, really!
  • Make changes to your training program to account for changes that become effective before the next training cycle.
  • Alert you to the need to re-train your employees prior to their next scheduled training cycle, if necessary.
  • Keep you abreast of changes to the regulations that affect your business and/or your industry group.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance.

 February 1, 2015 through February 28, 2015

Logo for US Environmental Protection AgencyUSEPA – US Environmental Protection Agency:

Publications not related to the management of hazardous waste, solid waste, universal waste, or used oil are not included here.

Rules and Regulations:

Approval of Other Solid Waste Incineration Units State Plan for Designated Facilities and Pollutants: Indiana Pages 10357 – 10359 [FR DOC # 2015-03792] PDF | Text | More

Proposed Rules:

Approval of Other Solid Waste Incinerator Units State Plan for Designated Facilities and Pollutants: Indiana Pages 10441 – 10442 [FR DOC # 2015-03790] PDF | Text | More

Contact me with any questions you may have about the management of hazardous waste

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

 

Notices:

Agency Information Collection Activities; Proposed Collection; Comment Request; Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System Pages 8306 – 8307 [FR DOC # 2015-03153] PDF | Text | More

The Hazardous Waste Electronic Manifest System Advisory Board: Request for Nominations Pages 8643 – 8645 [FR DOC # 2015-03300] PDF | Text | More

Underground Injection Control Program; Hazardous Waste Injection Restrictions; Petition for Exemption Reissuance-Class I Hazardous Waste Injection; Lucite International, Inc. Beaumont Site, Nederland, TX Pages 9267 – 9267 [FR DOC # 2015-03463] PDF | Text | More

FAA – Federal Aviation Administration:Federal Aviation Administratino

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

None

Proposed Rules:

None

Notices:

None

The FMCSA sets the minimum standards for Commercial Driver's Licenses
The FMCSA sets the minimum standards for Commercial Driver’s Licenses
FMCSA – Federal Motor Carrier Safety Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

None

Proposed Rules:

Minimum Training Requirements for Entry-Level Drivers of Commercial Motor Vehicles: Negotiated Rulemaking Committee Membership and First Meeting Pages 7814 – 7815 [FR DOC # 2015-02967] PDF | Text | More

Notices:

None
FRA – Federal Railroad Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

None

Proposed Rules:

None

Notices:

None

Logo for the Pipeline and Hazardous Materials Safety Administration (PHMSA)PHMSA – Pipeline and Hazardous Materials Safety Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

Hazardous Materials: Transportation of Lithium Batteries Pages 9217 – 9218 [FR DOC # 2015-03500] PDF | Text | More

Proposed Rules:

None

Notices:

International Standards on the Transport of Radioactive Material Pages 6567 – 6568 [FR DOC # 2015-02222] PDF | Text | More

Hazardous Materials: Information Collection Activities Pages 8133 – 8135 [FR DOC # 2015-03049] PDF | Text | More

Actions on Special Permit Applications Pages 9307 – 9308 [FR DOC # 2015-02984] PDF | Text | More

Notice of Application for Special Permits Pages 9308 – 9310 [FR DOC # 2015-02977] PDF | Text | More

Research and Development Program Forum Pages 9306 – 9307 [FR DOC # 2015-03488] PDF | Text | More

Information can be helpful but it’s useless if you are not able to make sense of it.  You must be able to determine how any changes to the rules and regulations (final or proposed) will affect your operations, and communicate the necessary information to your personnel.  I can help you to do that.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

Please contact me for a free training consultation to determine your regulatory requirements and how training can help you to attain and maintain compliance with the regulations of the US Environmental Protection Agency (and your state) and the PHMSA, FAA, FRA, & FMCSA of the US Department Of Transportation.

Q&A: Is a Shipping Paper Required for the Transport of Diesel Fuel in a 1,000 Gallon Cargo Tank?

HERE IS A QUESTION I RECEIVED THROUGH THE CONTACT ME PAGE OF MY WEBSITE.

Names and references to locations and companies have been changed to preserve anonymity.  Other minor editing changes have been made as well.

Subject: Help
Message: Hi Daniel,
My name is <<John Smith>> and I work for a construction company in a <<U.S. State>>. I drive a fuel/lube truck with a 1000 gallon diesel tank. I also haul engine, transmission, coolant, slop oil, and grease that are 100 gallons or less. I fuel off road construction equipment to our sites. My company does not or should I say certain individuals in the company do not know about HazMat DOT regulations.
What kind of shipping paper do I need? Would I need a permanent for diesel only or do I need to have the other chemicals listed as well?
I am personally getting the items I need from a well known company in this field. I purchased the orange book, placards 1993, and another HazMat book. I believe the company needs to have the HazMat Registration Permit also right. Please help. It seems I am alone with people who don’t know or don’t care. Call me, ###-###-####, so we can discuss this and perhaps if the price is right I would take one of your courses.
Respectfully for the cause,

AND HERE IS MY RESPONSE:

Thanks for contacting me. I’ll do my best to answer your questions.

First of all, diesel in the quantity and bulk packaging you describe is a hazardous material subject to the regulations of the USDOT when transported in commerce. Therefore, the following is required (at a minimum):

  • A shipping paper that describes the hazardous material (diesel) and any others you transport. A permanent diesel shipping paper would work as long as it is handled properly.
  • Placards on all four sides of the vehicle.
  • Markings on all fours sides of the vehicle: 1993, “Diesel”, or “Combustible”.
  • Emergency response information immediately available to the driver. The 2012 ERG is good for this. You must also have a 24 hour emergency response phone number.
  • The vehicle is a Commercial Motor Vehicle, subject to regulations for its operation on the highway. Depending on its weight, the driver may require a Commercial Driver’s License and be subject to hours-of-operation limits, &etc.
  • A placarded quantity of HazMat requires registration with the USDOT and payment of the fee.
  • Anyone involved in the transportation of the HazMat (not just the driver) must receive initial and triennial (every 3 years) HazMat Employee Training. Drivers require an additional component to HazMat Employee Training to include operation of the vehicle.

The other materials you mention may not be hazardous materials (or they might!). It is up to the Shipper to determine if a material is hazardous or not and therefore subject to the regulations.

You are right to be concerned about compliance issues at your company. I’d be happy to answer any other questions you may have.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

Transport Dangerous Goods Canada

Transport Dangerous Goods Canada Newsletter for 2014/2015

Anyone who transports dangerous goods (aka: hazardous materials or HazMat in the U.S.) must be aware of the latest news from the Canadian government’s Transport Canada.  One way to do this is to subscribe to the Transport Dangerous Goods Newsletter.

Transport Dangerous Goods CanadaBefore you subscribe you might be interested in checking out the TDG Newsletter for the first quarter of 2015.  I honestly don’t know how often they publish this thing, it doesn’t seem regular at all – unlike my monthly newsletter which appears every month predictable as a gas bill.  It’s not quarterly or anything.  I think they just publish it when they feel they have enough stuff to justify a newsletter.

Curious about what you’ll find inside?

  • Word from the Director General
  • Recent Changes in the TDG Directorate
  • Spring 2013 TDG Newsletter Survey – Thank you for participating!
  • Transportation of Dangerous Goods Research – What’s New?
  • Implementing Lean Management in the Transport Dangerous Goods Directorate
  • Association Québécoise du Propane – Annual Training for Emergency Response Advisors
  • Protective Directions Issued by the Transport Dangerous Goods Directorate
  • Lithium Batteries Are Dangerous Goods
  • Transport Canada’s Chemical, Biological, Radiological, Nuclear and Explosive Response Program Update
  • Petroleum Crude Oil Transloading Facilities in Western Canada
  • Dealing with sodium chlorate at a derailment site
  • Reportable Accidents across Canada in 2012 and 2013
  • CANUTEC Communication System – Canada’s New Safety Hotline for the Transportation of Dangerous Goods
  • Raising CANUTEC Awareness in Salmon Arm, British Columbia
  • Two amendments to the Transportation of Dangerous Goods Regulations
  • Contacts

Are the regulations of TDG Canada that different from PHMSA/USDOT?  Not really.  As a matter of fact, our two great nations have a reciprocal compliance agreement for the transportation of dangerous goods between the U.S. and Canada by highway or rail.  In short, compliance with the regulations of one country is accepted as compliance with the regulations of the other (with a few exceptions).  Read here for more:  Transportation of Dangerous Goods Between U.S. and Canada.

If you ship, receive, or transport dangerous goods from, to, or within Canada, then you must provide training for your employees engaged in regulated functions, e.g. preparing shipping papers; filling, closing, or loading (and unloading) packages; applying labels, markings, or placards; supervising employees engaged in these functions; and more!  Contact me for the training you need to remain compliant.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail.  International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

Q&A: PCBs and DEHP in Lighting Ballast

On February 12, 2015 a person who I assume to be a demolition contractor – not a customer of mine – asked a question through the Contact Me page of my website.

light fixture ballastI am working on a demolition project removing a coal fed power plant. The demolition crew is in the process of removing universal waste and as they remove the light ballasts we are checking for PCB/No PCB’s to determine how to dispose of them. Now reading further into the disposal process I came across DEHP. I did a little research on this DEHP and on your website it says that DEHP is a hazardous waste if it’s pure, but once used in a ballast it will no longer meet the description of a U-listed hazardous waste. My interpretation of that is it is no longer a hazardous waste and can be disposed of as construction debris as long as is not exhibiting leakage. Please respond. Thank You.

 On February 17, 2015 I replied.

Thank you for contacting me with your question.  I apologize for taking so long in getting back to you.

I assume you read my blog article on the disposal of lighting ballast.  I’m glad you were able to use it as guidance.  In sum:

  • The generator of a waste is required to make the hazardous waste determination based on generator knowledge (e.g. “No PCB” written on a ballast and/or its date of manufacture) or analytical (e.g. collecting a sample and submitting it to a lab for analysis).
  • Unless disposed of unused, DEHP is not a listed hazardous waste.
  • A ballast may be a hazardous waste if it exhibits a characteristic (i.e. Ignitability, Corrosivity, Reactivity, Toxcity).  While I don’t think a ballast will exhibit any of these hazardous waste characteristics, it is possible and it is the generator’s responsibility to make this determination.
  • If the ballast does not contain PCBs, is used and therefore not a U-Listed hazardous waste, and does not exhibit a characteristic, then it is not a hazardous waste and can be disposed of in non-hazardous (Subtitle D) landfill.  Whether it is leaking or not should not be an issue.
  • Free liquids cannot go to landfill.
  • The landfill may not wish to accept this waste – or any other – at its own discretion.
  • I am not familiar with construction debris landfills to speak to that issue.
  • Recycling as scrap metal (if approved by the recycler) is preferable to landfill disposal (in my opinion).

I hope this helps.

Dan

 On February 18, 2015 questioner replied.

Thank You for your reply.

Got a question?  Whether your a customer of mine or not I’m glad to help in any way I can.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

January 2015 – Rules & Regulations, Proposed Rules, and Notices Regarding the Management of Hazardous Waste and the Transportation of Hazardous Materials

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Federal Register logo
The Federal Register is the tool used by the US Government to communicate with interested parties

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA), Federal Railroad Administration (FRA), and the Federal Aviation Administration (FAA) of the US DOT on the subject of Transportation of Hazardous Materials.

The Federal Register is a great way to look down the road and see potential changes to the regulations long before they are put into effect (sometimes The Rulemaking Process takes years before a final rule is issued, if ever).  Knowledge of these potential changes provides you with several advantages:

  • Additional time to modify your business operations to comply.
  • Awareness of on what topics the regulatory agencies intend to focus their efforts.
  • The ability to register your concerns, complaints, suggestions, etc. in order to modify the proposed rule before a final rule is issued.  It can be done, really!
  • Make changes to your training program to account for changes that become effective before the next training cycle.
  • Alert you to the need to re-train your employees prior to their next scheduled training cycle, if necessary.
  • Keep you abreast of changes to the regulations that affect your business and/or your industry group.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance.

January 1, 2015 through January 31, 2015

Logo for US Environmental Protection AgencyUSEPA – US Environmental Protection Agency:

Publications not related to the management of hazardous waste, solid waste, universal waste, or used oil are not included here.

Rules and Regulations:

Definition of Solid Waste Pages 1693 – 1814 [FR DOC # 2014-30382] PDF | Text | More

Georgia: Final Authorization of State Hazardous Waste Management Program Revisions Pages 3888 – 3891 [FR DOC # 2015-01040] PDF | Text | More

Proposed Rules:

Lead-Based Paint Programs; Amendment to Jurisdiction-Specific Certification and Accreditation Requirements and Renovator Refresher Training Requirements Pages 1873 – 1880 [FR DOC # 2015-00473] PDF | Text | More

Is the waste generated during lead-based paint removal from a home a hazardous waste? Find out here:  The Household Hazardous Waste Exclusion

Georgia: Final Authorization of State Hazardous Waste Management Program Revisions Pages 3936 – 3936 [FR DOC # 2015-01039] PDF | Text | More

Contact me with any questions you may have about the management of hazardous waste

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

 

Notices:

None

FAA – Federal Aviation Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

None

Proposed Rules:

None

Notices:

None

FMCSA – Federal Motor Carrier Safety Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

None

Proposed Rules:

None

Notices:

None

FRA – Federal Railroad Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

None

Proposed Rules:

None

Notices:

Petition for Waiver of Compliance Pages 1469 – 1470 [FR DOC # 2015-00114] PDF | Text | More

Logo for the Pipeline and Hazardous Materials Safety Administration (PHMSA)PHMSA – Pipeline and Hazardous Materials Safety Administration:

Publications not related to the transportation of hazardous materials are not included here.

Rules and Regulations:

Hazardous Materials: Harmonization With International Standards (RRR) Pages 1075 – 1169 [FR DOC # 2014-30462] PDF | Text | More

Proposed Rules:

Hazardous Materials: Miscellaneous Amendments (RRR) Pages 3787 – 3838 [FR DOC # 2015-00265] PDF | Text | More

Hazardous Materials: Adoption of Special Permits (MAP-21) (RRR) Pages 5339 – 5449 [FR DOC # 2015-01263] PDF | Text | More

Notices:

Delayed Applications Pages 105 – 106 [FR DOC # 2014-30557] PDF | Text | More

Notice of Application for Special Permits Pages 104 – 105 [FR DOC # 2014-30538] PDF | Text | More

Notice of Application for Modification of Special Permit Pages 275 – 276 [FR DOC # 2014-30550] PDF | Text | More

Actions on Special Permit Applications Pages 920 – 921 [FR DOC # 2014-30546] PDF | Text | More

Delayed Applications Pages 2777 – 2778 [FR DOC # 2015-00707]                PDF | Text | More

Notice of Application for Special Permits Pages 2778 – 2779 [FR DOC # 2015-00706] PDF | Text | More

Notice of Application for Modification of Special Permit Pages 3012 – 3013 [FR DOC # 2015-00705] PDF | Text | More

Actions on Special Permit Applications Pages 3311 – 3312 [FR DOC # 2015-00678] PDF | Text | More

Information can be helpful but it’s useless if you are not able to make sense of it.  You must be able to determine how any changes to the rules and regulations (final or proposed) will affect your operations, and communicate the necessary information to your personnel.  I can help you to do that.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://danielstraining.com/

 

 

Please contact me for a free training consultation to determine your regulatory requirements and how training can help you to attain and maintain compliance with the regulations of the US Environmental Protection Agency (and your state) and the PHMSA, FAA, FRA, & FMCSA of the US Department Of Transportation.

New York Department of Environmental Conservation Seeks Public Comment on Proposed Amendments to Hazardous Waste Management Regulations

The New York State Department of Environmental Conservation (DEC) is providing a Draft for Public Consideration of revised Hazardous Waste Management Regulations for comment by stakeholders.

This rulemaking by DEC will incorporate new Federal rules of the USEPA and changes initiated by New York that affect the hazardous waste regulations in the state.  It will also clarify language and correct errors throughout the state regulations.  A draft of the amendments is being made available on the DEC website.  Stakeholders are to review a draft of the amendments available on the DEC website and provide comment before the draft regulations are formally proposed in 2015.

Thirty-seven (37) Federal rules are proposed to be included in this rule making. These rules were adopted by the USEPA from January 2002 through April 2012. The June 26, 2014 Cathode Ray Tube Export rule is also included in this rule making:  A list of the 37 Federal rules with a brief description.

As a state with an authorized hazardous waste program, New York regulations must be as strict and as broad as those of the USEPA.  The NY DEC may choose not to adopt Federal regulations if their own are more strict.

The proposed amendments to the New York hazardous waste program includes major changes to the Federal Rule adopted by the USEPA since 2012.  In this “initial public outreach,” DEC is seeking comments on the proposal to adopt the following EPA rules:

  • Solvent Contaminated Wipes Rule – EPA’s July 31, 2013 rule revises the definition of solid waste to conditionally exclude solvent-contaminated wipes that are cleaned and reused and revises the definition of hazardous waste to conditionally exclude solvent-contaminated wipes that are disposed.
  • Carbon Dioxide Sequestration Rule – EPA’s January 3, 2014 Carbon Dioxide Sequestration Rule provides a conditional exclusion for carbon dioxide (CO2) streams in geological sequestration activities. This rule would conditionally exclude CO2 streams that are hazardous waste from the definition of hazardous waste, if they are captured from emission sources and are injected into Class VI Underground Injection Control wells for geological sequestration, provided that certain requirements are met.
  • Hazardous Waste Electronic Manifest (e-Manifest) Rule – EPA’s e-Manifest Rule provides the legal and policy framework to authorize the use of electronic manifests. The e-Manifest system will go into effect through out the United States at the same time, whether or not authorized states have amended their regulations.
  • EPA’s 2008 Definition of Solid Waste Rule – As amended in January 2015 redefines “hazardous secondary materials.” It streamlines regulation of hazardous secondary material to encourage beneficial recycling and help conserve resources. By removing unnecessary regulatory controls, it is expected to make it easier and more cost-effective to safely recycle hazardous secondary materials. EPA published substantial revisions to this rule on January 13, 2015. As amended, the rule provides greater safeguards from mismanagement. Certain parts of the 2015 Final Rule are more stringent than current DEC regulations. DEC must adopt these provisions, which include a revised definition of “legitimate recycling,” a prohibition on sham recycling, and new recordkeeping requirements related to speculative accumulation provisions.
  • Amendments to DEC’s Used Oil Management Regulations (6 NYCRR Subpart 374-2). DEC is considering whether or not to continue to require Petroleum Bulk Storage (PBS) registration for certain small used oil tanks for which PBS registration is not otherwise required; whether to amend the used oil collection center requirements to allow entities collecting used oil in small volumes to obtain a Part 360 registration and more closely follow EPA requirements in lieu of obtaining a Part 360 permit; and whether to replace the current vehicle-to-vehicle exemption and 10-day exemption with a Part 360 registration requirement. Changes in time requirements for record retentions to more closely follow EPA requirements are also being considered.

The draft express terms; lists of federal and state changes; information on an upcoming webinar and public meeting; and how to submit comments are available on DEC’s website:  Hazardous Waste Management, Draft Regulations for Consideration.

Interested in the regulations of the USEPA, NYDEC, and the USDOT for the management of hazardous waste and/or hazardous materials in transportation?  Do you need the training that is required for personnel who work with hazardous waste or hazardous materials in transportation?

Contact Information for Daniels Training Services

Example Scenarios that Demonstrate the Potential to Threaten Human Health and the Environment

USEPA regulations at 40 CFR 265, Subpart D require a large quantity generator of hazardous waste to have a Contingency Plan and to implement emergency procedures to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water.  40 CFR 265.56(d) mandates that a facility’s emergency coordinator notify both State and Federal authorities if he determines that the facility has had a release, fire, or explosion which could threaten human health, or the environment, outside the facility.  The purpose of this article is to provide some examples of scenarios that demonstrate the potential to threaten human health and the environment. (more…)

Proper Disposal of a Hazardous Material: Is it a Hazardous Waste?

On February 2, 2015 an EHS Professional who had attended one of my Training Seminars contacted me with a question:

Dan, I attended your HazMat Employee & Hazardous Waste Training class last <<MONTH>> in <<CITY, STATE>>. I am hoping that you could help me out by advising me what to do with a 4 oz bottle of lacto phenol cotton blue stain that we just discovered hidden in a drawer in our laboratory.

According to SDS, it is approx. 80% phenol which is hazardous.
My question to you is how would you recommend handling this? I know we are allowed to keep small amounts on site. Would you safely package it up and store on site or would you go ahead and pay the cost of disposing it immediately?
Last year we went through the lab to clean out expired chemicals and did hire a company to dispose of all hazardous material but missed this bottle of stain.

I would greatly appreciate your advice.

My response on February 9, 2014:

I apologize for my delay in responding. I’ve been super busy the past few weeks.

To answer your question you have a few options, I have outlined some of them below along with some suggestions.

  • I would not be in any rush to call it a waste – and therefore a hazardous waste – too quickly. As the generator you have some discretion in deciding when it is a waste (i.e. when it is discarded) as long as it does not appear to be abandoned. As such, you could continue to keep it on the lab shelf with some plans in the near future to use it.
  • Is it possible to use it? If you can find some way to use it as a product in a legitimate manner, then it would not be discarded and would not be a waste. Perhaps your lab personnel could use it in some form of experiment that consumes the material leaving nothing but a RCRA Empty container which can then go in the trash.
  • If it becomes a waste, as the generator you have the option to treat a waste to make it non-hazardous. This can be done if the waste is hazardous due to a characteristic (D001, D002, D003, or D004-D043) but not if it is a listed hazardous waste (F-codes, K-codes, P-codes, U-codes). It sounds like what you have is a characteristic hazardous waste (D001 for Ignitability). You could therefore, mix it with a large amount of non-ignitable waste and make it non-hazardous. Or you could solidify it with absorbants and dispose of it as a non-hazardous waste.
  • If you are a CESQG and it is not a listed hazardous waste (see above) you could add it to your Used Oil and still manage it as a Used Oil.

In sum, you have a lot of options for the management of this material that does not require off-site transportation as a hazardous waste. Though of course that remains an option.

I hope this helps. Please don’t hesitate to contact me with any other questions.

Dan

EHS Professional replied:

Excellent information!  Thank you very much!

Daniels Training Services815.821.1550Info@DanielsTraining.com

https://danielstraining.com/

Emergency Response Telephone Numbers

Canada:
CANUTEC – Provides a 24-hour national bilingual (English & French) emergency response advisory service.
613-996-6666 (collect calls accepted)
*666 (STAR 666) cellular (in Canada only)

United States:

CHEMTREC – A 24-hour emergency response communication service.

1-800-424-9300 (collect calls accepted)
(Toll-free in the U.S., Canada and the U.S. Virgin Islands)
703-527-3887 for calls originating elsewhere

CHEMTEL, INC. – A 24-hour emergency response communication service.

1-888-255-3924 (collect calls accepted)
(Toll-free in the U.S., Canada, Puerto Rico and the U.S. Virgin Islands)
813-248-0585 for calls originating elsewhere

INFOTRAC – A 24-hour emergency response communication service.

1-800-535-5053 (collect calls accepted)

(Toll-free in the U.S. Canada and the U.S. Virgin Islands)

352-323-3500 for calls originating elsewhere

3E COMPANY – A 24-hour emergency response communication service.

1-800-451-8346 (collect calls accepted)

(Toll-free in the U.S., Canada and the U.S. Virgin Islands)

760-602-8703 for calls originating elsewhere

Webpage of WSBT in South Bend, INThe emergency response information services shown above have requested to be listed as providers of emergency response information and have agreed to provide emergency response information to all callers.  they maintain periodically updated lists of state and Federal radiation authorities who provide information and technical assistance on handling incidents involving radioactive materials.

MILITARY SHIPMENTS – For assistance at incidents involving materials being shipped by, for, or to the Department of Defense (DOD), call one of the following numbers (24 hours):

703-697-0218 (collect calls accepted) for explosives/ammunition incidents (U.S. Army Operations Center)

1-800-851-8061 (Toll-free in the U.S.) – All other dangerous goods incidents (Defense Logistics Agency)

NATIONWIDE POISON CONTROL CENTER (United States only)

1-800-222-1222 (Toll-free in the U.S.)

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