Things You Think You Know About Hazardous Waste – Pt. 3

This week we finish our things you think you know series contributed by Heritage Compliance Manager Mike Karpinski. The topic of this weeks post; as long as a business complies with EPA waste regulations they don’t have to worry about anything else.

Working at a national waste management company like Heritage, I often dream this was the case, but unfortunately there are many other federal agencies such as the Department of Transportation (DOT), Occupational Health and Safety Administration (OSHA), Department of Homeland Security, Drug Enforcement Agency and others that all have regulations pertaining to hazardous wastes and that’s not the end of it.

Each state (except for Iowa and Alaska) also has state specific regulations that are, at a minimum, equivalent to the federal regulations and may be stricter than the federal regulations.  Oftentimes, a state will have equivalent regulations, but different administrative requirements that cannot be ignored. For a company like Heritage that does business across all 50 states that means complying with a minimum of 196 different regulations relating to the proper management of hazardous materials (and I haven’t even mentioned all the city or county requirements yet…. I need an aspirin).

This reminds me, many of the statements made in the previous posts are based on general descriptions of federal regulations. Other Federal, State, or Local regulations may apply to your situation which may counteract these statements. This is one of the best reasons for working with a company like Heritage Environmental Services, LLC, we have experience dealing with these regulations and are trained to work closely with our customers to assist them in complying with these requirements.

Top Ten Hazardous Waste Generator Violations (And How to Avoid Them): Part 3

This week we will finish the article about the Top 10 Hazardous Waste Violations (And How to Avoid Them) written by Patty Smith, CHMM (Certified Hazardous Materials Manager).

4. Used Oil Labeling Violations   

          AVOID this by:

1.) Understand the definition of used oil.

2.) Any container or tank utilized to hold used oil should be labeled “Used Oil”.

3.) Ensure fill pipes used to transfer used oil to a UST are marked “Used Oil”.

3. Universal Waste Violations

-Violations for Spent Batteries:

1.) If universal waste batteries are in poor condition, they must be stored in a closed container.

2.) Labeled “Universal Waste Batteries”, “Waste Batteries”, or “Used Batteries”.

-Violations for Spent Lamps:

1.) Universal waste lamps must be stored in a closed container.

2.) Labeled “Universal Waste Lamps”, “Waste Lamps”, or “Used Lamps”.

AVOID this by:

1.) Understand the regulations for universal waste.

2.) Train employees on proper universal waste handling procedure.

2. Open Container Violations

AVOID this by:

1.) Rule of Thumb- if the contents would spill if the container was overturned, then the container is considered open.

2.) Close and latch funnels; screw in bungs; use drum rings and tighten bolts.

3.) Train employees to close containers when not adding or removing waste.

 1. Storage Area Accumulation Date Violations

-Containers of hazardous waste in a 90 or 180-day storage area must be marked with an accumulation date.

 AVOID this by:

1.) Once 55 gallons of hazardous waste or 1 quart of acute hazardous waste is exceeded at the satellite accumulation area, storage area dating requirements apply after three days.

 2.) Make sure all containers of hazardous waste in storage are marked with waste accumulation dates during weekly inspections.

 In General:

• Familiarize yourself with the regulations.

• Know your generator classification.

• Select the best storage method for your hazardous waste.

• Train employees so compliance is a team effort.