RCRA
Review Articles
 
 

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

Cigarettes and fireworks, anyone?

Some of the risks associated with products are fairly obvious—like using cigarettes and fireworks simultaneously. But what happens when these products are discarded? EPA has recently weighed in on the RCRA regulatory status of unused cigarettes and fireworks. READ MORE

Burning questions on off-spec used oil

EPA regulates the combustion of off-spec used oil under the Part 279 burner standards in the RCRA regulations. But due to statutory requirements added to the CAA in 1990, the CAA has much more to say about off-spec used oil when burned for energy recovery. To understand the landscape, have a look at our summary. READ MORE

Electronic filing of export paperwork

After December 31, 2017, exporters of hazardous waste, universal waste, spent lead-acid batteries, and cathode ray tubes will be required to file information in the U.S. Customs’ Automated Export System for each export shipment. We’ve got some pointers on where to get information on accessing the system and what paperwork is required. READ MORE






 

 

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