With few exceptions, facilities and businesses that produce hazardous waste must acquire a hazardous waste permit. Any facility or business that generates, treats, stores, or disposes of hazardous wastes, or has plans to do so on an ongoing basis, must carry a hazardous waste permit. Though the EPA regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA), most hazardous waste permits are issued through state environmental agencies under the guidelines of the RCRA hazardous waste program. In some instances, permits are issued by EPA regional offices.(more…)
When Do You Need to Acquire a Hazardous Waste Permit?
Understanding the EPA’S “PFAS Strategic Roadmap” as a Hazardous Waste Generator
Recognition of the threat from PFAS contamination finally culminated with a 2018 CDC review that confirmed what decades of research had already indicated—that PFAS contamination is a serious threat to human health and the environment. In response to the review, in October of 2021, the EPA implemented its PFAS Strategic Roadmap to take specific actions along with a commitment to a range of policies that safeguard public health, protect the environment, and will finally hold polluters accountable. (more…)
Learn the Basics of Compliant Hazardous Waste Training
Hazardous waste training is mandated by the Resource Conservation and Recovery Act (RCRA) under the authority of the EPA. If your facility generates any hazardous waste, to comply with the law, the act requires that employees who handle the waste be adequately trained. Given the immense consequences at stake—environmental, health and safety, financial, legal, and ethical—the responsibility of proper hazardous waste training for employees should be a top priority for facilities that generate hazardous waste.
By law, those employees handling hazardous wastes must complete a training program either through classroom instruction, computer-based online training, or through direct on-the-job training. All activity must be directed by a person trained in hazardous waste management procedures. The program must teach them to perform their duties in such a way as to ensure the facility complies. At a minimum, the training curriculum must ensure that facility personnel are capable of responding effectively to emergencies. They must be familiarized with emergency procedures, equipment, and systems.
To ensure that your personnel is well prepared to deal with an emergency, training staff should focus on several areas, including:
Site Specific Training
The RCRA regulations cover a wide variety of topics in hazardous waste training. Training regulations not only vary depending on the size and quantity of the monthly hazardous waste generated at a facility but on state laws and regulations, too. Some states may have more exacting requirements than federal law mandates. To meet all necessary regulations, ensure that personnel is trained to comply with the laws specific to your site’s location.
How To Respond To Emergencies
Emergency response is at the core of hazardous waste training, as responding to an emergency could be the difference between life and death. Because every hazardous waste generator is required by law to formulate an emergency contingency plan, as part of training, employees must have a thorough and detailed understanding of the plan and an actionable response to an emergency. Training would include procedures to minimize hazards and reduce risks to human health and the environment during the emergency. Personnel should have contact information and emergency phone numbers on hand, emergency equipment readily available, and additional emergency procedures related to the specific properties of the hazardous waste generated at the facility.
Training in Handling, Storage, and Disposal
Staff training in storing and handling hazardous waste generated at your facility should be at the core of their curriculum. Employees that work for hazardous waste generators must be thoroughly and adequately trained in handling and storing waste. In addition to covering all the various types and classifications of hazardous waste, the specific type of hazardous waste generated at your site, its properties, and associated risks is a topic that should be covered at length. However, several general issues need to be covered as well. Training should instruct employees in identifying hazardous wastes, selecting the correct storage container, where they should be located, knowing how to separate chemicals to prevent a reaction properly, and the procedures for transporting waste to a disposal site, among other topics.
Labeling Procedures and Protocols
Proper labeling is one of the many essential steps to safely handle, store, and ship hazardous waste. Therefore, knowing how to label hazardous waste properly is an integral part of training. To ultimately dispose of hazardous waste, generators must comply with EPA regulations and meet DOT (Department of Transportation) requirements for shipping. In addition, personnel must also be familiar with any state and local agency labeling requirements.
In training, employees must know how to correctly prepare a label and learn best practices for its placement on containers. Note that among the primary purposes of brands is to inform potential handlers of the hazardous risks of the material and ensure that incompatible materials are not stored or transported together. Hazardous waste label requirements can vary from state to state. In general, they include such information as the date when the accumulation of hazardous waste began, the type of material, its composition and current physical state, and the generator’s name and address. The label should visually indicate the primary hazard, as well.
Training is Ongoing
By law, RCRA hazardous waste regulations require annual training for designated hazardous waste personnel. However, ongoing training should be part of every program, as much because federal and state laws continue to change, as a way to stay on top of procedures and protocols to effectively manage hazardous waste at your facility. Managers should meet with staff to go over new laws and regulations and how they impact your facility whenever they are enacted. Establishing regular hazardous walk-through programs can help keep procedures and protocols fresh or identify areas in managing dangerous waste that must be addressed. Ongoing training of designated personnel will ensure that your facility complies with the law and that those employees are ready in an emergency.
MLI Environmental provides hazardous waste training services to help your facility stay compliant. To learn more, please get in touch with us today.
“Cradle-to-Grave” Hazardous Waste: 6 Responsibilities to Understand When Shipping Dangerous Goods
Cradle-to-grave hazardous waste management is a comprehensive regulatory program established by the EPA under the Resource Conservation and Recovery Act (RCRA). The RCRA is a public law passed in 1976 that continues to provide a framework to manage hazardous and non-hazardous solid waste in the U.S properly. The law also pertains to dangerous goods—those hazardous materials or substances capable of posing an unreasonable risk to the health and safety of people, places, and the environment when transported in commerce.
Understanding the EPA’s “Cradle-to-Grave” Program
The EPA’s “cradle-to-grave” program aims to ensure that, during the life cycle of hazardous waste, it is safely handled and managed from the time it is created or generated until it is either permanently stored or disposed of.
As its name implies, hazardous wastes are material wastes that hold dangerous properties harmful to humans or the environment. They are primarily generated through industrial and manufacturing activities, energy production, chemical production, or medical and research processes. They are generally in the form of liquids, solids, contained gases, or sludges.
By law, those who generate hazardous waste and dangerous goods are legally responsible for managing it safely from “cradle-to-grave,” i.e., it must be safely managed from its origin to its treatment, disposal, or storage. A key component of the law also includes shipping and transporting hazardous wastes and dangerous goods safely. In other words, companies, businesses, agencies, and institutions that create the waste are responsible for its safe transportation from where it was created to a designated site where it can be safely treated.
Because the transportation of hazardous wastes and dangerous goods is moved over public highways, roads, rails, and waterways, regulations for transport are under the jurisdiction of multiple federal, state, and local agencies. The U.S. Department of Transportation (DOT) is the primary regulatory authority for hazardous waste. Though the DOT and the EPA work in conjunction with each other, the EPA defers to the DOT to avoid discrepancies and redundant regulations. OSHA (Occupational Safety and Health Administration) also has a limited role in regulating hazardous waste that covers emergency response personnel responding to the incident. Additionally, hazardous waste transporters must also follow state and local regulations.
6 Responsibilities of Hazardous Waste Generators
Transporting hazardous waste is as much a matter of compliance as it is a responsibility. To understand the shipping component in the “cradle-to-grave” management of the material, here are 6 responsibilities that every generator must understand when shipping hazardous waste and dangerous goods from their facility:
1. Generators are liable and legally responsible for correctly packaging and labeling hazardous materials and generating the necessary documentation for shipping the material.
2. Generators must know the hazard classification for hazardous material and goods they are shipping, along with the regulations governing their shipment.
3. A shipper’s declaration must detail the exact contents of the shipment, its specific hazard classification, how the material is packed and labeled, and by whom.
4. Labeling requirements must be adhered to when transporting hazardous material. The appropriate HAZMAT placards and stickers should be placed where they can be easily read on cartons, drums, crates, shipping containers, vehicles, and trailers.
5. Transportation of hazardous waste and dangerous goods in commerce must be done by licensed, certified personnel registered conformance with DOT regulations.
6. Hazardous waste transporters must obtain an EPA ID number and comply with EPA’s hazardous waste manifest system to track the hazardous waste shipment from the generator facility to the off-site waste management facility.
Cradle-to-grave hazardous waste management is a regulatory and legal responsibility for all generators of hazardous goods. Integral to the process is the off-site transportation of hazardous waste to a designated facility for treatment, storage, or disposal. Companies and institutions are best served by partnering with a hazardous waste removal service to reduce the liability and risk factors associated with transporting hazardous waste. One that can ensure that you, as a generator of hazardous wastes, remain in compliance with laws and regulations that govern the safe transportation of your hazardous material to a designated facility.
Contact the Hazardous Waste Management Experts at MLI Environmental
MLI Environmental offers a range of expertise in hazardous waste management and removal services for generators. Our services include consulting, material identification, packaging, shipping, and transporting hazardous materials for companies and institutions large and small. Our professionally trained and certified personnel classify and identify all hazards associated with your goods according to DOT and EPA regulations, and generate appropriate documentation, placards, and labels to ensure compliance. We are a leader in shipping and transporting all hazardous wastes, materials, and dangerous goods. To ensure that your hazardous wastes are shipped in compliance with the law, consider partnering with MLI Environmental, a proven leader in hazardous waste management and removal services.
Hazardous Waste Q&A: What is Toxic Waste?
What is toxic waste? The answer is not as obvious as it may seem at first thought. The terms “toxic waste” and “hazardous waste” are frequently used interchangeably to define waste material that poses a threat to public health and the environment, which is true to a large extent. Either type of waste material does indeed pose a threat. Yet, for local, state, and federal regulatory agencies, there is a difference between the two. The Environmental Protection Agency (EPA) defines toxic and hazardous waste as not necessarily the same.(more…)
A Guide to Low-Level Radioactive Waste
If your facility, company, or institution generates low-level radioactive waste, it must be disposed of properly by law. Low-level radioactive waste is considered any type of material directly contaminated through contact with neutron radiation in small concentrations. It may also include any type of low-level material exposure to neutron radiation. Informally designated by the EPA as Low-Level Radioactive Wastes (LLRW), the classification is considered more a concept than a set definition. Degrees of radioactivity can range from low background levels that occur in nature to the highly contaminated radioactive material found inside the reactors of nuclear power plants or that produced from uranium or thorium mill tailings.(more…)
How to Choose a Hazardous Waste Disposal Company
A hazardous waste disposal company provides necessary, if not vital, services for businesses, companies, and institutions that generate hazardous waste streams. Finding the “right” disposal company cannot be understated. For starters, regulations and protocols that govern the management of hazardous waste are numerous and often present many challenges for generators. Staying compliant in an ever-evolving regulatory environment requires expertise. Ultimately, the responsibility is on you, the generator—by law, companies that generate hazardous waste have a cradle to grave responsibility for its proper disposal.(more…)
Hazardous Waste Materials Guide: Flammable Liquids
Flammable liquids classification is defined as a Class 3 hazardous material. As one of 9 such hazardous material classifications by the EPA, flammable liquids and combustible liquids are also regulated by the DOT during transportation and OSHA where workplace safety matters. If your company, business, institution, or facility is handling a Class 3 hazardous material its storage and disposal are subject to cradle-to-grave management. There is a good reason. Flammable liquids and combustible liquids, sometimes referred to as pyrophoric liquids, are capable of posing serious threats at any time, given the circumstances, due to their volatility and potential to cause severe conflagrations and explosions. (more…)
5 Important Requirements for Hazardous Waste Drum Shipping Labels
A hazardous waste label is an important step when preparing a drum of harmful or dangerous goods for transportation. The specific intent of all hazardous waste labels is intended to communicate the specific hazards that the packaging may pose. The markings on the label ensure that the material is handled properly to prevent accidents, spills, or exposure and for the handlers to know what to do in such an occurrence. Correct hazardous waste labels provide detailed information that is vital, if not critical, to make certain the safety of those handling and transporting the drums is ensured. (more…)
Hazardous Waste Materials Guide: Oxidizers
Common oxidizers, as examples of Class 5 hazardous materials, are composed of any solids, liquids, or gasses that react with most organic material or reducing agents that promote combustion in other materials. Though not necessarily combustible, oxidizers can increase the flammable range of chemicals to ignite more easily or intensify the chemical reaction between substances to cause a combustible reaction. Thus, common oxidizers are those substances that oxidize other substances and, through such a reaction, pose a severe fire hazard. (more…)