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Showing posts for tag: hazardous waste

Hazmat in Healthcare: Division 6.2 and Medical Waste

7/15/2014

Hazmat in Healthcare: Division 6.2 and Medical Waste

Hazardous materials shippers have many responsibilities under US DOT regulations. The first and arguably most important step of the hazmat shipping process is classifying the material.
 
If this first step is done incorrectly, the packaging selected for the shipment may not be compatible or strong enough; the marks, labels, and shipping papers will be inaccurate; etc. In the event of an incident in transit...
EPA Moves Forward with e-Manifest Standards

5/27/2014

EPA Moves Forward with e-Manifest Standards

On February 7, 2014, the US EPA established a new set of rules (79 FR 7518) for the e-manifest system. This system is meant to provide an alternative method of tracking hazardous waste shipments from generators to treatment, storage, and disposal facilities (TSDFs). While the EPA has a long-term goal of tracking hazardous waste electronically, the e-manifest system will coexist with...
How to Dispose of 2-Part Epoxy Solutions

4/23/2013

How to Dispose of 2-Part Epoxy Solutions

What Is an Epoxy Solution?
 
Epoxy resins are common in many industries, and disposing of them under RCRA rules can be complicated. Epoxy-based resins are two-part solutions created by combining an epoxy with a hardener or “cureative.” When combined, these materials create...
Understanding Your Generator Status

1/29/2013

Understanding Your Generator Status

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a generator of hazardous waste. Waste can be produced by industrial processes or through recycling and waste treatment. Wastes can become subject to regulation without actually being produced through the closure of a process or facility or the cleanup...

7/2/2012

DOT Training Requirements for Signing a Waste Manifest

“I have an employee that is responsible for signing the manifest for our off site shipments of hazardous waste. I have heard that this employee is subject to DOT training. If this is true, what training must I provide to this employee?”
 
This is a common question that is asked by compliance managers at sites dealing with...

2/28/2012

Hazardous Waste Labels: Industry Standards vs. Regulations

The Hazardous Waste Label: It’s an industry standard, but not actually a Federal rule.
There is no official “EPA Hazardous Waste Label.” Instead, there are a handful of requirements from both the EPA and the DOT for marking and labeling hazardous waste containers before and during shipment. There are also many non-standardized commercial labels that meet some or...

8/17/2011

Can CESQGs Use the Materials of Trade Rule?

Q. I work in an R&D laboratory doing quality testing for a manufacturing plant at the other end of town. We are a conditionally exempt small quantity generator (CESQG) of hazardous waste, mostly ignitable spent solvents.
 
Our corporate EH&S specialist says we can use the Materials of Trade (MOT) rule to haul our hazardous waste across...

8/2/2011

Question of the Week: Hazard Communication for CESQGs

Q. We are a conditionally exempt small quantity generator (CESQG). We hold waste on site in a central storage area for up to six months before we ship everything off site, but we don’t follow the actual 180–day rules while we’re storing the waste. We mark the words “Hazardous Waste” on our containers but nothing else. Since some of the waste is flammable, do we need to label the containers with either DOT labels or OSHA hazard communication labels while we’re storing them...

7/19/2011

Question of the Week: DOT Rules for Reusing Drums for Shipping Hazardous Waste

Q. As a small manufacturer, we buy lots of chemicals each month to use as solvents, purifiers, or catalysts. When we’re done, we ship the used chemicals back to the supplier for recycling and, in many cases, eventual reuse.
 
Most of the time, when we return-ship this hazardous waste, we refill the waste material into the...

6/30/2011

Question of the Week: Classifying Aerosol Can Waste

Q. Are aerosol cans considered to be a D003 simply because they are pressurized?
 
A. When it comes to waste identification, it is the responsibility of the generator to make a waste determination based on all aspects of the material (40 CFR 262.11). RCRA programs in some authorized states simplify your waste classification process and declare that each and every aerosol can...

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