A question from a recent attendee of one of my RCRA Training Webinars (01.19.18):

Thank you so much for the training this morning! Very useful information.

Does a facility that has a written “No Smoking” policy (and possibly signs at the front of the building) required to have the No Smoking signs posted near ignitable and reactive wastes accumulation areas?

Thank you!

My answer 01.30.18:

The answer is yes, “No Smoking” signs must be displayed as indicated even if the facility has a “no smoking” policy [(40 CFR 262.17(a)(vi)(B)].

Please allow me to expand and clarify this regulation (see below). For a full explanation, read: Special Conditions of a Large Quantity Generator to Prevent Accidental Ignition or Reaction of Ignitable or Reactive Hazardous Waste

• Applicable solely to a large quantity generator of hazardous waste (LQG).
• Applicable solely to hazardous waste displaying a characteristic of Ignitability (D001) or Reactivity (D003).
• “‘No Smoking’ signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.”

This letter of interpretation from EPA explains further (RO 14036). Note: The letter is old and it refers to a TSDF but the regulations are the same so I think it would still apply. A formal request for interpretation from EPA could be made as well.

Please contact me if you have any other questions.

That did it!

Wonderful, thank you for the information!

Conclusion:

A LQG has many responsibilities for the cradle-to-grave management of its hazardous waste. One of them, codified at §262.17(b)(7), mandates initial and recurrent training for hazardous waste personnel.