If your operations generate empty – or nearly empty – aerosol cans as a waste you must be aware of your requirements as a generator of hazardous waste under the Resource Conservation and Recovery Act (RCRA). First of all, you…
US DOT Requirements for the Shipment of Empty HazMat Packagings
It’s quite likely that at one time or another you have had to deal with the off-site shipment of empty packagings. Most manufacturing facilities experience this when they empty various non-bulk (usually 55-gallons or smaller) packagings of their contents and…
Q&A: My HazMat packagings have been emptied and rinsed. Are they OK to ship as non-HazMat?
Question (03.17.21): Hi Daniel, We have a customer who wants to ship empty containers to a container cleaning center. The totes and drums are empty and have been rinsed. Those containers had hazmat materials, can they cover up the labels…
Special Requirements for Incompatible Wastes and Materials in Satellite Accumulation Area
When first developing the satellite accumulation area (SAA) regulations in 1984 (hello Knight Rider!) the U.S. Environmental Protection agency (USEPA) inadvertently failed to account for the small quantity generators (SQG) and large quantity generators (LQG) of hazardous waste that might…
USEPA Final Rule: Aerosol Cans as Universal Waste
Effective February 07, 2020, the U.S. Environmental Protection Agency (USEPA) is adding hazardous waste aerosol cans to the universal waste program. The Final Rule includes the following: Defines an aerosol can. Includes aerosol cans with existing management standards for other…
Q&A: Are these paint pens a hazardous waste?
A question I received back on November 28, 2018: Hi Dan, I have a hazardous waste question for you. I am looking for affirmation of a conclusion that I have already come to or new awareness of some sort of…
Counting Hazardous Waste for the Generator Category Determination
After completing the hazardous waste determination as required by USEPA regulations at 40 CFR 262.11, the most fundamental responsibility of the generator of a waste is to count the hazardous waste it generates each month and determine its hazardous waste…
Web Based Training
Are the costs of travel preventing you from completing USDOT HazMat Employee & USEPA RCRA Training? …I can help. What is Web-Based Training? Online HazMat Training and RCRA Training is your best option when you need to meet the…
Q&A: Do I have a P-Listed Hazardous Waste?
A Question (way back on February 16th) requesting help with the annual hazardous waste report (Due March 1st!): I am completing the annual hazardous waste report and am trying to determine whether the material is non-acute or acute. Hopefully you…