March 1st is the due date for submittal of the 2011 Biennial Hazardous Waste Report (EPA Form 8700-12 A/B). Its purpose: reporting to the EPA about the generation, management and final disposition of hazardous waste regulated by the Resource Conservation…
The Exception From use of the Technical Name for Lab Pack Shipments of Hazardous Waste
Sometimes when shipping hazardous materials the proper shipping name does not adequately describe the contents of the shipment. An example of this, found in the Hazardous Materials Table (HMT) at 49 CFR 172.101 is the proper shipping name of: Flammable Liquids, n.o.s. This…
Pharmaceuticals as Hazardous Waste
(Kansas City, Kan., Nov. 23, 2011) – Eldo W.R.M.S., Inc., a commercial goods salvage wholesale and retail business, has agreed to pay a $23,900 civil penalty to the United States to settle a series of hazardous waste violations at its…
D003 – The Characteristic Hazardous Waste Code for Reactive Waste
The first step in the waste identification process – assuming you’ve already identified the material as a waste – is to determine if it is a solid waste as defined at 40 CFR 261.2. Once identified it is the responsibility of…
US EPA Regulations for the Management of Used Oil
The prospect of burning used oil on-site for energy recovery may seem daunting. You may think that the regulatory burden and related costs would far outstrip any savings on fuel consumption. I think you may be pleasantly surprised to learn…
The Universal Waste Option for the Management of Hazardous Waste
Recently, Waste Management LampTracker, Inc. was fined $118,800 for violations at its Kaiser, MO facility where it collects and recycles universal waste lamps, mercury-containing equipment, and batteries (US EPA news release). Its violations include: Failure to maintain adequate aisle space…
The USEPA Regulations for “Closed Containers” of Hazardous Waste
Generators of hazardous waste should be aware of the packaging requirements of the U.S. Department of Transportation (USDOT) when shipping their hazardous waste off-site for final treatment and disposal: the packaging must be in good condition, approved by the USDOT…
An Extension to the Hazardous Waste On-Site Accumulation Limits for Large Quantity Generators of Hazardous Waste that Generate F006 Wastewater Treatement Sludge from Electroplating Operations
As a Large Quantity Generator (LQG) of hazardous waste, you are aware that hazardous waste may not accumulate at your site for longer than 90 days unless it is managed in a satellite accumulation area pursuant to 40 CFR 262.34(c)(1). However, did…
A Hazardous Waste Treatment Storage and Disposal Facility (TSDF) Faces Stiff Fines From the US EPA
When facing an inspection and possible enforcement actions from the US EPA or their state regulatory agency a hazardous waste generator may wonder, “Why me? Why don’t they go after one of those big companies like BP, DuPont, or Goodyear…
Stiff Fines From the US EPA for Hazardous Waste Generators are Easily Avoidable
No matter how many times I read about it, I never fail to be surprised by two things: The severity of penalties faced by regulated facilities that violate US EPA hazardous waste (RCRA) regulations; and, How easily avoidable those violations…