Is there a special permit that allows for mixed batteries (Alkaline, Nickel Cadmium, Lead Acid, Lithium, etc.) to ship in the same container for Disposal / Recycle? USDOT’s Pipeline and Hazardous Materials Safety administration (PHSMA)… Read More »Mixed Batteries Special Permits
Soil on my property has been identified as being “contaminated”. What do I do now? Contaminated environmental media (soil and groundwater) can take many forms. Is the source oil? Chemical spill? Historic contamination from a… Read More »Soil Remediation
Less String Provisions Details Allows VSQGs and SQGs to exceed waste generation quantities in certain instances (Episodic Generation) An episodic event is an activity that does not normally occur and results in an increase in… Read More »Hazardous Waste Generators Improvements Rule (HWGIR) – Part 3
More Stringent Provisions Details Consolidated the regulations for Hazardous Waste Generators into 40CFR262 Consolidates the regulations for generators into Part 262. Before the rules the regulations were found in different Parts (261.5, 262, 265). More… Read More »Hazardous Waste Generators Improvements Rule (HWGIR) – Part 2
Summary and Important Provisions Updated: 05/06/2021 – Rule now in effect: AR, MD, NV, WI, TN as well According to the USEPA, the new Hazardous Waste Generators Improvement Rule “finalizes a much-needed update to the… Read More »Hazardous Waste Generators Improvements Rule (HWGIR) – Part 1
Generators and shippers of hazardous waste need to be cognizant of what training is required before signing any shipping papers. Training is regulated under both RCRA (Resource Conservation and Recovery ACT) and US Department of… Read More »What Training is Required to Sign a Hazardous Waste Manifest?
As we enter our seventh month of Coivd-19 PPE use, the question of how to dispose of it correctly comes up quite often. As the Covid-19 pandemic rolls on, one of the biggest issues that… Read More »PPE Disposal in a COVID World
If signing paper manifests is not reasonably practical, EPA encourages use of the e-Manifest system. If e-Manifest system is not an option: (source: EPA Memorandum Dated August 20, 2020) The transporter should write the name… Read More »Temporary COVID-19 Manifest Signature Policy
One of the three major types of hazardous waste “manifest discrepancies” listed in 40 CFR § 265.72 is rejected wastes, which is defined as a full or partial shipment of hazardous waste that the designated… Read More »Managing Manifest Requirements for Rejected Hazardous Waste Shipments
There are many businesses that either produce or consume containerized products, and in doing so these businesses may find themselves with empty containers. Depending on the material that was last inside that container, that empty… Read More »Empty Containers: The difference between RCRA Empty and DOT Empty
According to Section 262.27 of the Code of Federal Regulations, Waste Minimization Certification, a generator who initiates a shipment of hazardous waste must certify to one of the following statements on the Uniform Hazardous Waste… Read More »Hazardous Waste Minimization Program – In-Place
The requirements for accumulation (storage) in a central Accumulation area can be found in 40CFR 262.17: Conditions for exemption for a large quantity generator that accumulates hazardous waste. There are requirements listed for ignitable and… Read More »Segregation Requirements in Accumulation Areas
