Hazardous Waste Report Reminder for Ohio Businesses
From the Ohio Environmental Protection Agency Division of Materials and Waste Management:
In February of 2013, the Division of Materials and Waste Management (DMWM) changed the requirements for submitting the Hazardous Waste Report from annual to biennial. Generator and TSD data has since only been collected for odd numbered years and is due by March 1st for the following year. Please do not submit reports for 2014 as data for even numbered years is no longer required. If you need to submit a report prior to 2016 for the 2015 calendar year, please contact us.
However, if you normally submit other reports or data with your annual report that are not part of that report (e.g., the ground water monitoring annual report required by OAC 3745-65-94) please be aware that the frequency of these reports or data has not changed.
If you have any questions about this, or any other reporting issues, please contact Thomas Babb at 614-914-2527 or through email at thomas.babb@epa.ohio.gov
Mining Overburden – The RCRA Exclusion From Hazardous Waste at 40 CFR 261.4(b)(3)
What’s a Hazardous Waste Generator to do About “Cradle to Grave” Responsibility Under RCRA?
The Resource Conservation and Recovery Act (RCRA) as envisioned by the US Congress when it was passed in 1976 was meant to create a system for controlling hazardous waste from the time it is generated to its final disposal, i.e. “cradle to grave”. While acknowledging this system, many hazardous waste generators fail to realize their responsibility for compliance with the RCRA regulations for the hazardous waste they generate from its initial generation to its final disposal. In short, if you generate a hazardous waste you can be held responsible for its improper off-site transportation and disposal. Short of transporting, storing, treating, and disposing of your hazardous waste yourself, what can a hazardous waste generator do to minimize their potential liability once the hazardous waste is out of their hands? This article will provide guidance on questions to ask and information to seek out when choosing your hazardous waste transporters and TSDFs. (more…)
The Solvent Contaminated Wipes Rule in Michigan
On January 31st of 2014, the USEPA’s Solvent Wipe Rule became effective at the Federal level and in those states lacking authorization under RCRA to operate their own hazardous waste program. As a state with an authorized hazardous waste program, Michigan has the option to adopt the new Federal Rule in its entirety, adopt it in part, or reject it outright and manage solvent-contaminated wipes by its own state rules. The purpose of this article is to explain the regulatory requirements for the management of solvent-contaminated wipes by a hazardous waste generator in Michigan.
Waste Prohibited from Landfill Disposal in Michigan
The following wastes are prohibited from landfill disposal under Part 115 of Act 451:
Training for RCRA Personnel and HazMat Employees in Michigan
Used oil
Whole tires
Liquid waste. Liquid Industrial Waste is subject to strict regulation in Michigan.
Returnable beverage containers. Find a designated collection site and make some money on your returns!
Lead acid batteries. Manage pursuant to Part 111 of Act 451, R 299.9206(2)(d), if reclaimed.
Yard clippings. For disposal options, search the MDEQ website for registered composting facilities.
Medical waste. A universal waste in Michigan.
Sewage
Asbestos unless the landfill meets specific federal requirements.
Empty drums unless crushed.
Hazardous waste from Small Quantity Generators (SQG) and Large Quantity Generators (LQG) of hazardous waste. Waste from a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste is OK.
Low level radioactive waste.
PCB waste unless the landfill meets specific requirements.
For more information about wastes banned from landfill disposal in Michigan: MDEQ Prohibited Wastes.
Frequently Asked Questions Regarding the Regulations of the Resource Conservation and Recovery Act
Got a question about the generation, identification, management, transportation, and disposal of hazardous waste, universal waste, used oil, or non-hazardous waste?
Q: What is the paint filter test?
A: The paint filter test is test method specified by the USEPA (USEPA Method 9095A) used to determine the presence of free liquids in a representative sample of waste. A predetermined amount of material is placed in a paint filter, any portion of the material that passes through the filter in a five-minute test period is identified as free liquids. The method is used to determine compliance with 40 CFR 264.314 and 265.314. However, the presence of free liquids is critical to a generators hazardous waste determination as well; especially for the characteristics of Ignitability (D001) and Corrosivity (D002).
Rules & Regulations, Proposed Rules, & Notices From: USEPA (RCRA Only); and FAA, FMCSA, FRA, & PHMSA (HazMat Transportation Only) for November 2014
November 2014 – 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.
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.
November 1, 2014 through November 30, 2014
USEPA – 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:
Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties, Issuance of Compliance or Corrective Action Orders, and the Revocation, Termination or Suspension of Permits Pages 65897 – 65901 [FR DOC # 2014-26321] PDF| Text | More
Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Final Exclusion Pages 70108 – 70113 [FR DOC # 2014-27780] PDF| Text | More
Proposed Rules:
Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties, Issuance of Compliance or Corrective Action Orders, and the Revocation, Termination or Suspension of Permits Pages 65910 – 65912 [FR DOC # 2014-26318] PDF| Text | More
Contact me with any questions you may have about the management of hazardous waste
Agency Information Collection Activities; Proposed Collection; Comment Request; Requirements and Exemptions for Specific RCRA Wastes Pages 65652 – 65653 [FR DOC # 2014-26329] PDF | Text | More
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:
The FMCSA sets the minimum standards for Commercial Driver’s Licenses
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:
Training, Qualification, and Oversight for Safety-Related Railroad Employees Pages 66459 – 66510 [FR DOC # 2014-26290] PDF| Text | More
Proposed Rules:
None
Notices:
Roadway Worker Authority Limits-Importance of Clear Communication, Compliance With Applicable Rules and Procedures, and Ensuring That Appropriate Safety Redundancies Are in Place in the Event of Miscommunication or Error Pages 70268 – 70270 [FR DOC # 2014-27955] PDF| Text | More
PHMSA – Pipeline and Hazardous Materials Safety Administration:
Publications not related to the transportation of hazardous materials are not included here.
Rules and Regulations:
None
Proposed Rules:
None
Notices:
List of Delayed Applications Pages 65296 – 65296 [FR DOC # 2014-25165] PDF| Text | More
Actions on Special Permit Applications Pages 65297 – 65298 [FR DOC # 2014-25168] PDF| Text | More
Pipeline Safety: Renewal Requests for Special Permit Pages 65477 – 65478 [FR DOC # 2014-26086] PDF | Text | More
International Standards on the Transport of Dangerous Goods Pages 65768 – 65768 [FR DOC # 2014-26184] PDF| Text | More
Office of Hazardous Materials Safety; Notice of Application For Special Permits Pages 69559 – 69560 [FR DOC # 2014-27426] PDF| Text | More
Actions on Special Permit Applications Pages 69560 – 69561 [FR DOC # 2014-27427] PDF| Text | More
Delayed Applications Pages 69561 – 69562 [FR DOC # 2014-27428] PDF| Text | More
Notice of Application for Modification of Special Permit Pages 69562 – 69563 [FR DOC # 2014-27430] 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 railInternational and DomesticDaniels Training Services815.821.1550Info@DanielsTraining.com
Please contact 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.
Hazardous Waste Container not Labeled = RCRA Violation for Delaware Body Shop
The Bullet:
It does not appear that any fines were issued, but a simple violation of the state hazardous waste regulations could have been avoided with a little knowledge.
Who:
Enforcement Agency: Delaware Department of Natural Resources and Environmental Control (DNREC)
Brandywine Body Shop
1325 Newport Gap Pike
Wilmington DE
When:
Date violation discovered: 08/19/2014
Date corrected: 08/19/2014
Date notice of violation served: 11/28/2014
Why:
Containers of hazardous waste were not marked with the words “Hazardous Waste” or with other words that identify the contents of the containers.
How:
As a state with an authorized hazardous waste program, Delaware may conduct RCRA compliance inspections of businesses within its borders and issue violations and fines for non-compliance.
Conclusion:
Something as simple as failing to label a hazardous waste container resulted in a violation for this business. If you don’t have the time or resources for my Onsite Training or for one of my Training Seminars, consider the low-cost and quick alternative to formal training that will bring you into compliance: Webinar Training.
As a state with an authorized hazardous waste program, Colorado had the ability to make its state regulations more stringent and more broad than those of the USEPA; and it has. The Colorado hazardous waste regulations enforced by the Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment (CDPHE) are more strict than those of the USEPA.
Are you in compliance with the regulations of the CDPHE?
For the regulations pertaining to hazardous waste management in Colorado, one must refer to 6 CCR 1007-3 of the Colorado Code of Regulations. However, many responsibilities of a hazardous waste generator are not found in the regulations but in the guidance and compliance documents of a regulatory agency; and the training requirement for a Conditionally Exempt Small Quantity Generator of hazardous waste in Colorado are a good example of this. (more…)
October 2014 – 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.
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), Federal Motor Carrier Safety Administration (FMCSA), 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.
October 1, 2014 through October 31, 2014
The Code of Federal Regulations (CFR) is the source of US Federal Regulations
USEPA – 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:
Arkansas: Final Authorization of State-Initiated Changes and Incorporation by Reference of State Hazardous Waste Management Program Pages 59438 – 59444 [FR DOC # 2014-23364] PDF | Text | More
Florida: Final Authorization of State Hazardous Waste Management Program Revisions Pages 60756 – 60759 [FR DOC # 2014-24006] PDF | Text | More
Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance With the Disposal Regulations; Panel Closure Redesign Pages 60750 – 60756 [FR DOC # 2014-24025] PDF | Text | More
Arkansas: Final Authorization of State Hazardous Waste Management Program Revision Pages 64678 – 64682 [FR DOC # 2014-25724] PDF | Text | More
Proposed Rules:
Arkansas: Final Authorization of State-Initiated Changes and Incorporation by Reference of State Hazardous Waste Management Program Pages 59471 – 59472 [FR DOC # 2014-23363] PDF | Text | More
Florida: Final Authorization of State Hazardous Waste Management Program Revisions Pages 60795 – 60796 [FR DOC # 2014-24007] PDF | Text | More
Review Process To Determine Whether the Waste Isolation Pilot Plant Continues To Comply With the Disposal Regulations and Compliance Criteria Pages 61268 – 61271 [FR DOC # 2014-24260] PDF | Text | More
Arkansas: Final Authorization of State Hazardous Waste Management Program Revisions Pages 64721 – 64722 [FR DOC # 2014-25725] PDF | Text | More
Contact me with any questions you may have about the management of hazardous waste
Publications not related to the transportation of hazardous materials are not included here.
Rules and Regulations:
The Federal Register is the tool used by the US Government to communicate with interested parties
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:
Hours of Service of Drivers: Application for Renewal of Illumination Fireworks, LLC and ACE Pyro LLC Exemptions From the 14-Hour Rule During Independence Day Celebrations Pages 61687 – 61688 [FR DOC # 2014-24287] PDF | Text | More
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:
Proposed Agency Information Collection Activities; Comment Request Pages 59891 – 59893 [FR DOC # 2014-23511] PDF | Text | More
Proposed Agency Information Collection Activities; Comment Request Pages 62513 – 62517 [FR DOC # 2014-24688] PDF | Text | More
Proposed Agency Information Collection Activities; Comment Request Pages 63017 – 63018 [FR DOC # 2014-24987] PDF | Text | More
PHMSA – Pipeline and Hazardous Materials Safety Administration:
Publications not related to the transportation of hazardous materials are not included here.
Rules and Regulations:
None
Proposed Rules:
None
Notices:
List of Delayed Special Permit Applications Pages 59360 – 59361 [FR DOC # 2014-23077] PDF | Text | More
Office of Hazardous Materials Safety; Notice of Application for Special Permits; Special Permit Applications Pages 59552 – 59552 [FR DOC # 2014-23476] PDF | Text | More
Office of Hazardous Materials Safety; Notice of actions on Special Permit Applications Pages 59552 – 59554 [FR DOC # 2014-23478] PDF | Text | More
Office of Hazardous Materials Safety; Notice of Application for Special Permits Pages 63485 – 63486 [FR DOC # 2014-25167] PDF | Text | More
Office of Hazardous Materials Safety; Notice of Applications for Modification of Special Permit Pages 63486 – 63486 [FR DOC # 2014-25166] PDF | Text | More
Safety Advisory: Packaging and Handling Ebola Virus Contaminated Infectious Waste for Transportation to Disposal Sites Pages 64646 – 64647 [FR DOC # 2014-25778] 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
Please contact 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.
