Classification of a Material Having More Than one Hazard – 49 CFR 173.2a

As a Shipper you are required to classify a hazardous material prior to offering it for transportation; to do this you must be familiar with the definition of a hazardous material at 49 CFR 171.8. Hazardous material means a substance or…

Changes to the International Maritime Dangerous Goods Code – 2014 Edition

The International Maritime Organization (IMO) publishes a new edition of its International Maritime Dangerous Goods Code (IMDG Code) every two years, with the current edition (2012, incorporating amendment 36-12) published in the Fall of 2012.  Each new edition of the…

The OMP Spring House Conditional Exclusion From Hazardous Waste for Low-Level Mixed Waste 40 CFR 261.4(b)(17)

Even though it expired in June of 2010, you may be interested in learning about this conditional exclusion from regulation as a hazardous waste that occupies 40 CFR 261.4(b)(17) to this day.    

Categories of Waste to Consider When Determining a RCRA Recycling Exclusion From Solid Waste

The definition of a solid waste at 40 CFR 261.2(a)(1) includes any discarded material that is not excluded from regulation by: The conditional exclusions for certain solid waste at §261.4(a). A variance granted under §260.30 and §260.31. A non-waste determination under…

Be Safe When Using Propane Cylinders

Like all hazardous material packagings, propane cylinders must be designed, manufactured, and tested to meet the specifications codified at 49 CFR 178.  Propane cylinders must also be requalified at periodic intervals to ensure they remain safe for use.  Unfortunately, all…

What Counts When Counting Hazardous Waste?

If you discard anything from your home, business, or government office you are a generator of a solid waste.  As a generator of solid waste you are required to conduct a Hazardous Waste Determination to determine if your solid waste…

Household Hazardous Waste Collection in St. Louis

After completing the Annual RCRA Refresher Training for a client in St. Louis, I had some time to drive around before heading to the airport to continue journey for the week.  I stumbled upon a site that all St. Louis…

What is a Product and What is a Waste?

When you look around your facility it’s important for you to know when you are looking at a product – and therefore not subject to RCRA – and when you are looking at a waste – and therefore subject to…

Notification of a Hazardous Waste Emergency in Missouri

The regulations of the USEPA at 40 CFR 264 and 265 are applicable primarily to Treatment, Storage, and Disposal Facilities (TSDFs) that are required to operate under the conditions of a RCRA subpart C permit due to their handling of…

What’s the Difference Between Parts 264 and 265 of 40 CFR?

Anyone who reads the regulations applicable to generators of hazardous waste, either the Federal USEPA or those of your state (if it has an authorized hazardous waste program), will notice frequent references to Parts 264 and 265 to Title 40.…