hazardous waste

Notification of Regulated Waste Activity Form for Hazardous Waste Generators

The US EPA requires you to submit a Notification of Regulated Waste Activity (8700-12) Form for certain activities involving wastes subject to the regulations of the Resource Conservation and Recovery Act (RCRA).  A Notification is required if you handle a…

Cradle to Grave Under RCRA and CERCLA

RCRA – the Resource Conservation and Recovery Act – was passed in 1976 to amend the Solid Waste Disposal Act of 1965 and to address a growing national concern over the improper management and disposal of both hazardous and non-hazardous…

Inherently Waste-Like

40 CFR 261.2 defines a solid waste as any discarded material not excluded by regulation, variance, or non-waste determination.  A discarded material is any material which is: Abandoned, Recycled, Considered inherently waste-like as described in paragraph (d), or A military munition…

Exception to the Segregation Restrictions of 49 CFR 177.848 for Lab Packs of Hazardous Waste

49 CFR 173.12 contains many exceptions to full regulation for shipments of hazardous waste in a lab pack.  In an earlier blog post I discussed the exception in 173.12(d)that removes the need to include the technical name of a hazardous…

Extensions to the 90/180 Day On-Site Accumulation Time Limits for Hazardous Waste Generators

If you are a generator of hazardous waste, one regulatory requirement you are no doubt familiar with are the limits on the number of days you may accumulate hazardous waste on-site without a permit.  These limits are: Large Quantity Generator…

Hazardous Waste Determination: D001 Ignitable

A person that generates any waste is required to determine if that waste is a hazardous waste pursuant to the method identified in 40 CFR 262.11.  The US EPA has identified two different categories of hazardous waste:  listed and characteristic.  To be listed a…