One thing about hazardous materials that can’t be denied is that they move among us all the time.  It’s the proximity of hazardous materials in commerce to people that makes adherence to the Hazardous Materials Regulations so important.  Since we find hazardous materials in transportation around us frequently, it behooves us to learn more about them and the hazard communication methods.  Take a look at the photo below and see if you agree with my interpretation of the regulations. (more…)

This article is the seventh in a series that takes a close look at the requirements of 40 CFR 265, Subpart D – Contingency Plan and Emergency Procedures.  This Subpart, along with the remainder of Part 265 is applicable to permitted hazardous waste treatment, storage, and disposal facilities (TSDFs) and to large quantity generators of hazardous waste (LQGs).  A Contingency Plan and the emergency procedures outlined in Subpart D are critical for the safe operation of a hazardous waste facility and to ensure compliance with state and Federal regulations.

The purpose of this article is to read, review, and explain the requirements of 40 CFR 265.55 Emergency Coordinator.

Hold on a minute!  These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule.  If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer).  If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you.  Read: What is the status of the Generator Improvements Rule in my state?

To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:

• Large quantity generator of hazardous waste (LQG)
• Small quantity generator of hazardous waste (SQG)

Read the previous article in this series: 40 CFR 265.54 Amendment of Contingency Plan or read on to learn about 40 CFR 265.55.

To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article.

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The Bullet:

At the request of Freeborn County the Minnesota Pollution Control Agency (MPCA) investigated properties where several tire fires had occurred in the recent past.  The investigation revealed a generator of hazardous waste improperly disposing of both hazardous and non-hazardous waste through illegal storage, disposal, and open burning.

 Who:

Charles D. Borneman, corporate officer for Albert Lea Trailer Inc. in Freeborn County, Minnesota.

The Minnesota Pollution Control Agency (MPCA).

What:

Albert Lea Trailer Inc. has paid a $20,000 penalty and agreed to comply with state rules that prevent noxious smoke from burning materials such as rubber and a variety of other state regulations that mandate the cradle-to-grave management of hazardous waste.

Where:

Freeborn County, Minnesota.

When:

The multiple fires that sparked the investigation took place in March 2012.

The MPCA Press Release is dated May 8, 2014.

Why:

The open burning of waste by a business (homeowners have a few exceptions) is banned by the Resource Conservation and Recovery Act (RCRA) passed as law in 1976.  Read more about the history of RCRA.  It is also against Minnesota law and just a real bad idea since it releases harmful pollutants (like dioxins) into the air.

How:

As a state with an authorized hazardous waste management program under RCRA, the MPCA has the authority to investigate, enforce, and assess penalties for violations of state environmental regulations.

Conclusion:

Whether you generate a little waste or a lot.  Whether the waste is hazardous, non-hazardous, used oil, or universal waste, you must comply with the regulations of the USEPA or your state for its management at your site, its off-site transportation, and its final disposal.  One requirement of those cradle-to-grave regulations is training for all Facility Personnel who come in contact with hazardous waste.  Contact me for this training or for any questions you have about the management of hazardous waste.

Read the full MPCA press release

All of us can learn more about the regulations.  And when an opportunity presents itself to learn them directly from the environmental regulatory agency in your state – in this case the Michigan Department of Environmental Quality (MDEQ) – it’s a good idea to take advantage of it.

What is it?

2014 Michigan Environmental Compliance Conference

When and where?

May 29 -Traverse City
June 5 – Grand Rapids
June 10 – Livonia

How much?

Registration Fee: $130.  This includes breakfast, lunch, conference materials and the brand new 8th Edition of the “Michigan Guide to Environmental, Health, and Safety Regulations.  That’s practically worth the whole $130 right there!

Conference highlights include:

• Four concurrent tracks with 24 sessions that cover waste and wastewater management, air quality requirements, remediation, pollution prevention and other topics.
• Release of the 8th Edition of the “Michigan Guide to Environmental, Health, and Safety Regulations” developed by the DEQ and the Department of Licensing and Regulatory Affairs (LARA).
• “Expert Area” devoted to one-on-one assistance providing you an opportunity to network with DEQ, MIOSHA, and Michigan State Police staff and to get your questions answered.

You will not want to miss this training opportunity if you are responsible for making sure your company, municipality, or institution is in compliance with Michigan’s environmental regulations. Environmental consultants, state and local officials, and anyone else interested in learning about Michigan’s environmental regulations and how to comply are also welcome to attend.

Click here for more information and to register!

Questions:
Alana Berthold
bertholda@michigan.gov
517-284-6854

Learning the regulations of every state that has an authorized hazardous waste program – like Michigan – is a priority of mine.  My Onsite Training focuses on just the regulations you need to know for compliance at your facility, whether it’s State or Federal.  I highly recommend attending this conference (I can’t make it due to scheduling conflicts, but I’ll do everything I can to make the next one).

After attending the conference you decide you need assistance in complying with the regulations of the MDEQ f0r hazardous waste, universal waste, used oil, or liquid industrial waste (it’s a Michigan thing), don’t hesitate to contact me.  I can help.

This quarterly newsletter from the CT DEEP is a great source of information for everyone, not just businesses in Connecticut.  It contains helpful information on pollution prevention activities that can be applied at home or at work nationwide.

Contents for Volume 14, Issue 2 – Spring 2014:

1. Bon Appetit:  A New Life for Leftovers – Read the statistics about food waste and its impact on our environment.  Celebrate the companies that are already taking steps to reduce food waste and its disposal in landfills.  Learn a simple thing all businesses and homeowners can do to reduce the disposal of compostable food waste in landfills.
2. Businesses, Institutions, and Agencies Getting Waste Wise – Waste Wise is a waste reduction program managed by the USEPA.  Persons may establish waste minimization goals for their enterprise.  Resources are available from the USEPA for participants.  Those meeting their goals are acknowledged by USEPA and can promote their company as “Waste Wise”.  Read more about USEPA’s Waste Wise program.
3. Ask Eartha – Read Eartha’s response to a question about microbeads.  Spoiler:  They’re not good.

View the entire P2 View Newsletter for Spring 2014

Since March 24, 2011 the Maine Department of Environmental Protection (ME DEP) policy has offered an option for management of solvent-contaminated wipes (wipers in ME DEP policy) for generators of hazardous waste.  In the absence of a comparable exclusion in USEPA regulations, this state policy held the force of regulations for ME businesses.  That changed with the USEPA’s announcement July 23, 2013 of a conditional exclusion for both disposable and reusable solvent-contaminated wipes effective January 31, 2014 (read about the Federal Rule).

These Federal regulations force ME DEP (and all other states without an authorized hazardous waste program) to choose between adopting the new regulations as is or to create its own – possibly more stringent – state regulations.  Continuing the management of solvent contaminated wipes as a state “policy” is no longer acceptable for Maine businesses.  I was informed by Michael Hudson of ME DEP on March 24, 2014 that Maine is expected to adopt the new Federal rule – as is – into its state regulations some time before July 2015, possibly in 2014.  Until then, per Michael Hudson, Maine businesses have two options:

• Comply with the new Federal Rule.
• Continue to comply with the ME DEP policy until the Federal Rule is adopted into state regulations.

Read on for a summary of the ME DEP Policy for Solvent Contaminated Wipers. (more…)

The transportation in commerce of a hazardous material is usually subject to the Hazardous Material Regulations (HMR) of the USDOT/PHMSA.  However, the transportation of certain hazardous materials, below specified thresholds, in authorized packaging may receive an exception from full regulation.  And, in some cases, the hazardous material may be fully excepted from regulation under the HMR.  Just such a case of a full exception is the De Minimis Exception, found at 49 CFR 173.4b and summarized below. (more…)