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Daniels Training Services Blog

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What is a Sludge? The US EPA Definition

Air pollution control devices

Like the term "solid waste", "sludge" when used by the EPA can be confusing.  It can be found in 40 CFR 261.2 as part of EPA's description of what wastes may and may not be a solid waste (more on that below) .

The Recordkeeping Requirements for RCRA Training for Hazardous Waste Personnel

In an earlier article I explained the requirements for training of Facility Personnel at a Large Quantity Generator (LQG) of hazardous waste.  Just as important as providing the correct training is documenting its successful completion, that is the point of this

The Uniform Hazardous Waste Manifest and Personal Liability

I used to work for a hazardous waste disposal company named Laidlaw Environmental Services in Pecatonica, IL.  A frequent question I was asked as I directed the client to sign the Uniform Hazardous Waste Manifest (Manifest) was:  "Will I go

Options for the Recycling of Scrap Circuit Boards

If you generate scrap circuit boards as a waste, you may be unaware of your options for disposal or recycling under USEPAs hazardous waste regulations.  The purpose of this article is to identify and briefly explain your options for the

Empty Steel Aerosol Cans as a Reactive Hazardous Waste (D003)

Pursuant to 40 CFR 262.11 it is the responsibility of the generator to determine if the waste they generate is hazardous.  This responsibility applies to empty steel aerosol cans that are likely generated somewhere within your facility (think:  Maintenance).  While

DOT Requirements for Frequency of HazMat Employee Training

When must you train your HazMat Employees:  How soon after employment begins, and how frequently must you provide refresher training?  Fortunately 49 CFR 172.704(c) provides answers to these questions. First of all a new hire or one whose job function

When to Remove Hazardous Waste From a Satellite Accumulation Area

The EPA regulations for the management of hazardous waste in "Satellite Accumulation Areas", which, incidentally doesn't define or use the term "Satellite Accumulation Areas" can be found at 40 CFR 262.34(c).  Here we learn the seven most important requirements to

General Display Requirements for Hazardous Material Placards

In an earlier article I wrote about the requirement of the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) to ensure the visibility of placards on a motor vehicle

Avoid Double-Counting of Hazardous Waste When Determining Generator Status

In an earlier article I directed you towards the applicable regulations (40 CFR 261.5) for determining your hazardous waste generator status.  Specifically, 40 CFR 261.5(c) listed the hazardous wastes that need not be counted toward your generator status. Another concern when

Counting Hazardous Waste to Determine Generator Status

In order to determine your status as a generator of hazardous waste:  Large Quantity Generator (LQG), Small Quantity Generator (SQG), or Conditionally Exempt Small Quantity Generator (CESQG), you must know how much hazardous waste and/or acute hazardous waste you generate

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