RCRA
Review Articles
 
 

Rulemaking priorities revealed

EPA has released their Fall 2017 agenda. In addition to the two final rules discussed elsewhere in this newsletter, EPA is working on five rules that will make interesting changes to the hazardous waste regs. Two new rulemakings would add aerosol cans as universal waste and make changes to the ignitability characteristic. See what you can expect in 2018. READ MORE

NORM issues?

People periodically ask us: “How should we manage NORM?” They are not referring to their coworker—Norm, but to naturally occurring radioactive material—NORM. Unfortunately, there is no simple or nationally consistent answer to managing Norm or NORM. We can’t help you with the former, but we’ve got some considerable background information to get you going in the right direction on NORM. READ MORE

No secrets here

Documentation for regulatory compliance sometimes involves confidential business information, which can be protected under law. On the other hand, EPA has finalized a rule to exclude hazardous waste import-export documents from confidentiality claims. This action is consistent with the agency’s previous decision that manifest data is not confidential business information. READ MORE

e-Manifest launches June 30, 2018
Fee rule finalized

Put it on your calendar! June 30, 2018 is the day EPA expects that the new e-manifest system will be up and running. But, who’s going to pay and how much? A final rule issued by the agency has answers. We’ve summarized the final fee structure and other changes being made to the manifest management system. READ MORE

Annual RCRA training required if…

The regs say that “facility personnel” need annual RCRA training. But who is that exactly? Sometimes, you have to look past the job title to what the person actually does. The preamble to the November 28, 2016 generator improvements rule has given us guidance on what job functions at a facility trigger the annual RCRA training requirement. READ MORE

Ready for the new container standards?

The November 28, 2016 generator improvements rule made some significant changes to the management of hazardous waste in containers. Some states have already adopted these changes and because they are more-stringent, they are coming to your state, too. The good news is that compliance should not be too difficult. In order to assist you, we’ve summarized the new RCRA container requirements. READ MORE

EPA reveals its strategic plan

Every four years, EPA is required to give us an update on where it’s going and how it’s going to get there. The agency has released its draft FY 2018–2022 strategic plan. In this time of uncertainty, it is well worth a read. READ MORE

DOT puts thumb print on manifest

Because most RCRA hazardous waste meets DOT’s hazardous material definition, and waste is often transported, there is significant interface between these two programs. Thus, a few recent DOT interpretations may affect hazardous waste manifest preparation. READ MORE

Recalled airbags are…

With all the airbag recalls due to inflators, the question arises as to the RCRA status of these devices. EPA has considered many issues regarding the status of airbags that are being held and/or will be discarded. For example, did you know that undeployed airbags that have been installed in vehicles and are subsequently removed are considered “used” (i.e., spent materials). READ MORE

Form 8700-12 is up-to-date!

The Site ID form (EPA Form 8700-12) has recently been modified and revamped, adding numerous additional data fields that allow the various new notifications required by the November 28, 2016 generator improvements and import-export rules. To find out more about the new form and what notifications are required, see our summary. READ MORE






 

 

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