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McCoy's RCRA Review

December 2019

Aerosol cans now universal waste

On December 9, 2019, EPA published a final rule adding hazardous waste aerosol cans to the universal waste program in Part 273. In general, the requirements for universal waste aerosol cans are the same as those for other universal wastes: handlers may accumulate waste aerosol cans onsite for up to one year and do not have to use a manifest for offsite shipments. Handlers who puncture universal waste aerosol cans must recycle the empty punctured cans and meet certain requirements.   READ MORE  


Relax into the holidays

It’s the time of year for reflection, family and friends, and sharing the joy of the season. Thank you for your support and business throughout the year. We hope you’ll have a magical, relaxing, best-ever holiday season and a bright New Year! And if you have time for a few culinary adventures, try a few Colorado recipes from local bloggers.

As is our tradition, our office will be closed for the holidays from December 23, 2019 through January 1, 2020. We’ll be back on January 2, 2020. Feel free to visit our website and we’ll be watching over our email, though it may take a bit longer to get back to you. Cheers!




Pharma wastes and reverse distribution/logistics

EPA has reaffirmed its position on reverse distribution versus reverse logistics, which was developed in the agency’s February 2019 hazardous waste pharmaceuticals rule. Prescription hazardous waste pharmaceuticals undergoing reverse distribution are solid wastes, but nonprescription pharmaceuticals and other unsold retail items sent through reverse logistics are not solid waste if they have a reasonable expectation of being legitimately used/reused or reclaimed.   READ MORE  


Be a snowbird in Phoenix

Head to our Phoenix, Arizona RCRA seminar, February 10–14, 2020. It just doesn’t get any better than Arizona in the winter with mild temperatures in a beautiful desert setting. Our host is the Tempe Mission Palms Hotel. Herman Miller chairs in the conference room will ensure you’re comfortable for learning, and numerous restaurants are within walking distance. So fly the coop to Phoenix. We hope to see you there.

McCoy Seminar Registration
Tempe Mission Palms Hotel
Actually cool things to do in Phoenix




Pharma rule LTCF definition clarified

In other guidance providing interpretation of the 2019 pharmaceuticals rule, RO 14917 addresses the status of certain intermediate care facilities that provide care to individuals with intellectual disabilities. EPA was asked whether these facilities would be included in the definition of long-term care facilities (LTCFs) in the 2019 rule. While both entities provide care to their residents, LTCFs are typically regulated under Part 266, Subpart P, while wastes generated from intermediate care facilities enjoy the household hazardous waste exclusion.   READ MORE  


Family-friendly RCRA

If you can swing it, bring your family to Orlando, March 9-13, 2020, and piggyback a vacation with our RCRA training. The Rosen Plaza Hotel will be our host and it’s close to all the major theme parks including Walt Disney World®, LEGOLAND® Florida, Universal Studios FloridaTM, and Epcot. You’ll get your annual RCRA training with our comprehensive five-day format and enjoy a wonderful break at the same time.

McCoy Seminar Registration
The Rosen Plaza Hotel
Best theme parks by age group




New non-waste fuel determination

EPA has approved another non-waste fuel determination for a material under Part 241. [RO 14916] This time, the nonhazardous secondary material (NHSM) is “Btu Boost,” which is not considered a waste when burned as a fuel. Non-waste fuel determinations are often issued to individual companies for a specific material. You can read our previous article for more information on this unique concept.


Refresherrr in Denver

If you’re in a hurry and can’t be away from your facility for long, and you need a two-day training, try our Denver, Colorado, March 24–25, 2020 RCRA Refresher. March is as beautiful as it is unpredictable; it can be 60 degrees one day and snowy the next. The Renaissance Boulder Flatiron hotel will be our host. Located half-way between Denver and Boulder, the mountain views are amazing and the accommodations will keep you toasty. Join us!

McCoy Seminar Registration
Renaissance Boulder Flatiron
Packing tips for a winter trip


Sampling and analysis in Tucson

A significant, although sometimes overlooked, part of RCRA compliance is proper sampling and analysis. This includes where and how to take samples, how many samples are needed, and how to evaluate analytical results. EnviroStat, Inc. is offering two courses: 1) “Sampling for Defensible Environmental Decisions,” March 2-5, 2020; and 2) “Sampling for Defensible Environmental Decisions - Advanced Topics,” April 7-9, 2020—both in Tucson, AZ. As an expert in the areas of sampling and statistics, Charles Ramsey will provide training on correct sampling principles and design, quality control, statistics for sampling activities, and how to avoid costly sampling errors.




2020 Seminars

5-Day RCRA Seminars
Phoenix: February 10–14, 2020
Orlando: March 9–13, 2020
Houston: April 13–17, 2020
Hilton Head Island: May 18–22, 2020
Seattle: June 22–26, 2020
San Antonio: July 13–17, 2020
Lake Tahoe: August 24–28, 2020
Virginia Beach: September 21–25, 2020
Denver: October 5–9, 2020
Chicago: October 26–30, 2020

2-Day RCRA Refreshers
Denver: March 24–25, 2020
Las Vegas: June 2–3, 2020
Boston: August 4–5, 2020

3-Day Puerto Rico RCRA Seminar
Guaynabo: August 11–13, 2020

Visit to register or call us at 303-526-2674.


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Copyright ©2019 McCoy and Associates, Inc. 12596 West Bayaud Avenue, Suite 210 Lakewood, CO 80228

McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided in RCRA Review. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance in RCRA Review is general in nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.

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