There is a myriad of potential liabilities, exposures and RCRA compliance risks associated with the storage of containerized products at Third Party Locations and warehouses for producers. How do we ensure that our partners in… Read More »Ensuring RCRA Compliance at Warehouse and Third-Party Locations
Many states’ waste programs classify solid waste as solely hazardous or nonhazardous per the regulations found in 40 CFR; however, some states including Texas have more complex and stringent nonhazardous waste classification programs based on… Read More »Waste Classification In Texas
The chemical industry is accelerating forward on a path towards sustainability with an ultimate objective of circularity. Circularity, with regard to the economy and business, is aimed at the reduction and eventual elimination of waste. … Read More »TSCA Implications when Managing By-Products for Re-Use
49 CFR 172.604 defines the requirements for the inclusion of Emergency Response Phone Numbers on Hazardous Waste Manifests (HWM). At times though, there can be some ambiguity and confusion as to when a contract number needs… Read More »Knowing When to Include a Contract Number on your Hazardous Waste Manifest
If you store hazardous wastes in your facility, you are likely to need secondary containment systems to meet one or more regulations. Neither the EPA nor OSHA specifies what a secondary containment system must look like.… Read More »Secondary Containment: Use and Management of Containers
Regulating Authority Comparison Moving products overseas often starts with a sample evaluation by the end user, even if a Certificate of Analysis or other product information is available. Care must be taken to ship samples… Read More »Shipping Product Samples Internationally
Large Quantity Generators (Generated 2,200 lbs. or more of Hazardous Waste in any single calendar month or accumulated at any time more than 2.2 lbs. of acute hazardous waste in any single calendar month; or generated more… Read More »News for New York State Hazardous Waste Generators
Focus on Speculative Accumulation Generators accumulating Hazardous Secondary Materials (HSM) for reclamation and reuse need to satisfy the regulatory requirements set forth in §40CFR 261.1 which states in section (c)(8): A material is “accumulated speculatively” if it is accumulated before being recycled. A material is not accumulated… Read More »Rules Around Speculative Accumulation
