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.

The regulations of the Resource Conservation and Recovery Act (RCRA) administered by the U.S. Environmental Protection Agency (USEPA) address the generation, identification, management, treatment, transportation, and final disposal of hazardous waste from cradle-to-grave.  Most of the regulatory responsibilities are those of the generator of the hazardous waste.  USEPA and most – but not all – states identify three hazardous waste generator status:

• Large quantity generator (LQG)
• Small quantity generator (SQG)
• Very small quantity generator (VSQG)

Of these three the majority of the regulatory burden is borne by the LQG.  The subject of this article is no exception:  Special conditions of an LQG to prevent accidental ignition or reaction of ignitable or reactive hazardous waste.  Or, more succinctly:  The No Smoking Rule. (more…)