After the hazardous waste determination, the single most important responsibility of any hazardous waste generator is to determine their hazardous waste generator status. The USEPA identifies three (3) status of hazardous waste generators (note that your state may not recognize…
Calculating Your Hazardous Waste Generator Status – All
A pre-requisite for compliance with the regulations of the Resource Conservation and Recovery Act (RCRA) is the determination of your hazardous waste generator status. And though their identification of the status may differ from the USEPA, the same is true…
Potentially Infectious Medical Waste in Illinois
As a result of a national scare from needles and other medical waste washing up on eastern shores in the late 1980’s the USEPA passed the Medical Waste Tracking Act of 1988, which was only effective in a limited number…
What is the Small Quantity Exception to the HMR?
The transportation of a hazardous material (HazMat) is subject to the Hazardous Material Regulations (HMR) of the PHMSA/USDOT. This includes but is not limited to the following: Classification of the HazMat. Selection and use of specification packaging. Application of the…
RCRA Recordkeeping Requirements – All
The hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) require Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) of hazardous waste to maintain a copy of certain documents as a record of their compliance. In a…
The Requirements of 40 CFR 265, Subpart C – Preparedness and Prevention for Generators of Hazardous Waste
Certain generators of hazardous waste – large quantity generator (LQG) & small quantity generator (SQG) – are required to comply with 40 CFR 265.30 – Emergency Preparedness and Prevention. Though awareness of this regulation is widespread, full understanding of it…
The Identification and Management of Universal Waste in Michigan
1st Half of April 2013 – Announcements of Proposed Rules, Changes to the Rules, and Final Rules for RCRA & the HMR
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. Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the…
Waste Analysis Plans: What are Your Recordkeeping Requirements?
The regulations of the Resource Conservation and Recovery Act (RCRA) require both large and small quantity generators of hazardous waste (conditionally exempt small quantity generators are exempt) to develop and adhere to a Waste Analysis Plan if they are treating…
The Requirements of 40 CFR 265.32 Required Equipment for Generators of Hazardous Waste
In the previous article of this series I described the requirements of 40 CFR 265.31 – Maintenance and operation of facility. That section was not filled with a lot of specific requirements but instead set a general performance standard to…