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What is a Product and What is a Waste?
When you look around your facility it’s important for you to know when you are looking at a product – and therefore not subject to RCRA – and when you are looking at a waste – and therefore subject to...
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What Counts When Counting Hazardous Waste?
If you discard anything from your home, business, or government office you are a generator of a solid waste. As a generator of solid waste you are required to conduct a Hazardous Waste Determination...
View ArticleProper Disposal of a Hazardous Material: Is it a Hazardous Waste?
On February 2, 2015 an EHS Professional who had attended one of my Training Seminars contacted me with a question: Dan, I attended your HazMat Employee & Hazardous Waste Training class last...
View ArticleAmendment to the Speculative Accumulation Provision Under the New Definition...
In a Final Rule published January 13, 2015 in the Federal Register, USEPA amended the definition of solid waste it had enacted in 2008 (2008 DSW). The Federal regulations of the 2015 DSW become...
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What is a D003 Reactive Hazardous Waste?
The EPA – and most states with an authorized hazardous waste program – identify two types of hazardous waste: Listed: Hazardous waste from non-specific sources (F-codes). Hazardous waste from specific...
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Q&A: Do I have a P-Listed Hazardous Waste?
A Question (way back on February 16th) requesting help with the annual hazardous waste report (Due March 1st!): I am completing the annual hazardous waste report and am trying to determine whether the...
View ArticleQ&A: Disposal of Used X-Ray Lamps
This question was posted on a Yahoo Group, of which I am a member, back on January 22, 2016: A very happy Friday to all. Here is an interesting one. I have five used X-ray Lamps to dispose of. Ohio...
View ArticleOne Time Notice to USEPA or State Environmental Agency per 40 CFR...
USEPA regulations at 40 CFR 261.4(a)(20) provide for a conditional exclusion from management as a solid waste – and therefore as a hazardous waste as well – for hazardous secondary materials used to...
View ArticleRecordkeeping Requirements of 40 CFR 261.4(a)(20)(ii)(D)
USEPA regulations at 40 CFR 261.4(a)(20) provide for a conditional exclusion from management as a solid waste – and therefore as a hazardous waste as well – for hazardous secondary materials used to...
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