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Daniels Training Services Blog

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Visibility Requirements for Display of Hazardous Material Placards on a Motor Vehicle

In the general placarding requirements of 49 CFR 172.504(a) of the USDOT/PHMSA Hazardous Materials Regulations (HMR), it states that when required each bulk packaging, freight container, unit load device, transport vehicle, or rail car "must be placarded on each side

Whatever Happened to the “Drive Safely” Placard?

Stop and think, when was the last time you saw the once ubiquitous "Drive Safely" placard on a truck going down the highway?  It's been awhile hasn't it?  Since October 1, of 2001 to be exact.  On that date 49

Retention of Material Safety Data Sheets

How long are you required to retain a Material Safety Data Sheet (MSDS) for the hazardous materials in use at your facility?  Forever?  30 years?  Only until you stop using the material?  A complete answer to that question requires a

The Waste Minimization Mandate for Hazardous Waste Generators

Waste Minimization is not just a nice sounding phrase that we roll out once a year around Earth Day.  As a generator of hazardous waste 40 CFR 262.27 requires you to demonstrate some form of waste minimization activity depending on your hazardous

The “RCRA Empty” Exemption from Hazardous Waste Regulation

The federal regulations of the U.S. Environmental Protection Agency (USEPA) at 40 CFR 261.7(a)(1) read, "Any hazardous waste remaining in either: an empty container; or an inner liner removed from an empty container, as defined in paragraph (b) of this

A Possible Security Threat v. Security Breach

The latest political scandal at the time of this writing, and likely to be eclipsed by a new one by the time you read this, involves the President's Secret Service detachment and a bevy of prostitutes in a Columbia hotel

Proper Management of Household Hazardous Waste

The wastes generated in the average American home may be just as hazardous for human health and the environment as any waste generated in an industrial or commercial setting; think of things like paints (both liquid and aerosol), bleach, toilet

9 Questions to ask Your RCRA Training Provider

I hope you use my services to provide RCRA Training to your Hazardous Waste Personnel as required by the US EPA (and your State).  However, there are other training providers out there and perhaps you are considering one of them.

Who is the Generator of Hazardous Waste?

Storage of HHW in St. Louis

A generator of hazardous waste is defined in the regulations of the U.S. Environmental Protection Agency (USEPA) at 40 CFR 260.10 as any person, by site, whose act or process produces hazardous waste identified or listed in Part 261 or

Who is Responsible for the Securing of Hazardous Material Packages on a Motor Vehicle: the Shipper or the Carrier?

49 CFR 177.834(a) requires packages of hazardous materials to be secured against shifting within the vehicle and between the packages under normal transportation conditions.  If you offer a hazardous material for transportation (a shipper) to be transported by another company (a

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