An interesting question from California (that matters) on January 3, 2018:
Daniel;
I was searching Google when a link to your site came up. We are having to transport sludge and scum from an old wastewater plant across town to a newer plant. We are doing this in a tank truck. What placards do we need to put on the truck?
My reply that same day:
I will do my best to answer your question below.
- If the waste is from a domestic sewage WWT it likely will not be a RCRA hazardous waste per USEPA regulations.
- However, it may be a non-RCRA hazardous waste in California. i.e. an appendix X listed non-RCRA Hazardous Waste.
- Unless it contains or is suspected to contain pathogens – and therefore a Division 6.2 Infectious Substance – it is unlikely to be a hazardous material (HazMat) per USDOT/PHMSA regulations.
- On the unlikely chance it is a HazMat, a government entity is subject to the Government Employee Exemption from USDOT regulations.
- The transport in a tank truck (aka: cargo tank motor vehicle) will likely be subject to California regulations as a commercial vehicle. I am not sure if California has a government employee exemption.
- It’s handling may be subject to California Health Department regulations.
- Human waste is unlikely to be a USEPA hazardous waste though it may be a non-RCRA hazardous waste under California’s more strict regulations. If its transportation is not subject to USDOT/PHMSA regulations as a hazardous material, then no placards are required to be displayed on the vehicle. Due to the size and type of the vehicle it may be regulated in California as a commercial vehicle. This may require fees, registration, driver licensing, &etc.
I hope this helps.
Please contact me with any other questions.
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Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste Daniels Training Services, Inc. 815.821.1550 |
That seemed to satisfy him. I was surprised he didn’t have any other questions:
Thank you for your prompt reply,
Conclusion:
The hazardous waste regulations are much more stringent and more broad in California than the Federal rule. Compliance requires high-quality training that I can provide either as a Webinar or as Onsite Training.