The Bullet:
Zippo Manufacturing Company will pay a $186,000 penalty to settle alleged violations of hazardous waste regulations at its manufacturing facility in Bradford, Pa.
Who:
Zippo Manufacturing Company
And…
United States Environmental Protection Agency (EPA) – Region III
1650 Arch Street Philadelphia, Pennsylvania 19103-2029
Phone – 215/814-5100 Fax – 215/814-5102
Contact: Roy Seneca seneca.roy@epa.gov 215-814-5567
What:
The alleged RCRA violations include:
- Storage of hazardous waste without interim status or a permit. This could be as simple as exceeding the on-site accumulation time limit – 90 days for a large quantity generator or 180 days for a small quantity generator. On-site storage in excess of these limits is forbidden without a permit.
- Operation of an unpermitted thermal treatment unit. This could be as simple as hanging solvent-contaminated rags out to dry or allowing volatile solvents (e.g. solvent-based paint) to evaporate at room temperature. Thermal treatment of a hazardous waste is not allowed without a permit.
- Failure to properly manage hazardous waste containers. I don’t have enough information here, but examples of improper management of a hazardous waste container include:
- Not marked with the words “Hazardous Waste” and the initial date of accumulation.
- Not kept closed except when actively adding or removing hazardous waste.
- Not in good condition.
- Hazardous waste or hazardous waste residue on the outside of the container.
- Reactive (D003) or Ignitable (D001) hazardous waste within 50′ of the facility property line.
- Failure to maintain job descriptions of personnel managing hazardous waste. This frequently misunderstood requirement is found in the regulations for documenting annual Hazardous Waste Personnel Training at a large quantity generator of hazardous waste.
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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 815.821.1550 |
EPA also alleged violations of the Emergency Planning and Community Right-to-Know Act (EPCRA). According to EPA, Zippo did not submit annual toxic release reports for three chemicals – copper, nickel and chromium — for three years when the facility used or processed chemicals in reportable quantities.
Where:
Zippo Manufacturing Company is located in Bradford, PA.
When:
Published: August 25, 2015
There are no other dates mentioned in the published news release.
Why:
EPA cited Zippo for violating the Resource Conservation and Recovery Act (RCRA), the federal law governing the treatment, storage, and disposal of hazardous waste. RCRA is designed to protect public health and the environment, and avoid costly cleanups, by requiring the safe, environmentally sound storage and disposal of hazardous waste.
The settlement penalty reflects the company’s compliance efforts, and its cooperation with EPA in the resolution of this matter. As part of the settlement, Zippo has neither admitted nor denied liability for the alleged violations, but has certified its compliance with applicable RCRA requirements.
How:
Inspectors of the U.S. Environmental Protection Agency (EPA) can enter the property of a hazardous waste generator at any reasonable time in order to conduct an inspection. Inspectors are authorized to inspect any area of the facility that hazardous waste are or have been and to inspect records documenting compliance. The hazardous waste generator is required to make three years of records accessible in the event of an inspection.
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Conclusion:
All generators of hazardous waste – regardless of their status – should be prepared for an inspection of their facility by either state or Federal agents at any time. Are you prepared? Can you demonstrate compliance on the shop floor and in the records you maintain. My training for Hazardous Waste Personnel will meet the regulatory requirements, identify potential violations like these, and answer any questions you may have about both state and Federal regulations for the management of hazardous waste (and universal waste, used oil, & non-hazardous waste).
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Daniels Training Services 815.821.1550 |