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Showing posts with the label Hazardous waste management

Sustainable Solutions: Sustainable waste management

 There are different approaches to treating waste, but the following points are common principles followed by many inside and outside the US. Which of the following categories does your organization fall in? Prevent waste The best thing to do is to not generate waste. If that is not possible, try to substitute non-hazardous or less hazardous chemicals into your processes. Think about only ordering chemicals that you need to use now vs. buying bulk chemicals/larger quantity to receive a discount in cost. In the end, this costs you more because you have to dispose of the excess that you do not end up using. In addition, this is not a sustainable practice. Instead of sending something to the waste pile, find out if others in the organization are able to use it, this prevents waste and cuts disposal costs. Prepare to re-use You may ask yourself, how am I going to reuse this? Electronic waste can be reused, instead of disposing of the escrap as hazardous waste, it can be taken apart and...

Regulatory Update: EPA increases civil penalties

 The US EPA has increased its maximum civil penalties with publishing the Final Rule on December 23, 2020. Below is a table showing the increases (Note: Penalties are assessed on a per day, per infraction basis). Program Previous Current Resource Conservation and Recovery Act ( RCRA ) $75,867 $76,764 Clean Air Act ( CAA ) $101,439 $102,638 Clean Water Act ( CWA ) $55,800 $56,460 Comprehensive Env. Response... Act ( CERCLA ) $58,328 $59,017 Emergency Planning/ Right-to-Know Act ( EPCRA ) $58,328 $59,017 Fed Insecticide, Fungicide/Rodenticide Act ( FIFRA ) $20,288 $20,528 Safe Drinking Water Act ( SDWA ) $58,328 $59,017 Toxic Substances Control Act ( TSCA ) $40,576 $41,056 The above table d...

Regulatory Update: EPA issues temporary enforcement policy in response to COVID-19 Pandemic

The US Environmental Protection Agency (EPA) has announced a temporary enforcement policy in the wake of the COVID-19 pandemic. Prior to the policy the EPA was inundated with questions about how to handle current situations where COVID-19 imposed restrictions prevented enforcement tasks from being completed. The Agency recognizes that work shortages, travel restrictions, and social distancing caused by the pandemic will have an impact on ability to enforce compliance with federal environmental regulations. In response to these projections the EPA has issued a temporary policy that outlines how they intend to "exercise enforcement discretion" with respect to certain compliance situations. On April 2, 2020 The US EPA sent a letter to members of congress clarifying the temporary enforcement policy. This letter aimed to reassure federal lawmakers and the regulated community that EPA's enforcement activities will remain active and to address concerns caused by the release of...

Regulatory Update: Aerosol Cans As Universal Waste

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The EPA has added aerosol cans that contain hazardous waste to the Universal Waste listing as indicated in their federal register posting on Monday, 12/9/2019. This will become effective February 7, 2020. What this means: Adding aerosol cans to the Universal Waste program offers potential cost savings to generators or a change in generator status (to a less regulated status).   This also means that generators may simplify disposal processes around aerosols from the stringent and sometimes burdensome RCRA requirements. However as is with all new Federal regulations, authorized states may choose to adopt the new rules into their state programs or not. Since Maryland and DC state regulations don’t specifically address aerosol cans, this rule will go into effect in both jurisdictions until such time they would explicitly write rules otherwise. See the Final Rule here or read on for more details.