The EnviroBlog

  In July 2013 the US Environmental Protection Agency (EPA) published a final rule that modified the federal hazardous waste regulations around solvent-contaminated rags and wipes. The rule revised the definition of solid waste to conditionally exclude solvent-contaminated wipes that are cleaned and reused and revises the definition of hazardous waste to conditionally exclude disposable solvent-contaminated wipes. We’re here to share with you “What You Need To Know”. Solvent-Contaminated Wipes Final Rule adoption by state According to Maryland Department of Environment (MDE), the regulation is less-stringent with respect to disposal of solvent-contaminated rags & wipes and the provisions are not currently effective in Maryland. Meanwhile, the regulation is more-stringent with regards to laundering and reusing solvent-contaminated rags & wipes and MDE has changed its previous policy in order to maintain consistency with the basic element of these provisions of the federa...

 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...

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.

Effectively developing, implementing and managing an integrated waste solution requires a very specific set of expertise, resources and planning.   We’re here to ensure your organization has the solutions and services you need to implement a scalable program that handles all you waste streams at all your locations. As your single source partner with our Enviroexpert Integrated Waste Solutions, we offer: ·          Assess and evaluate your companywide waste management and disposal programs for all waste including but not limited to hazardous waste, non-hazardous waste, pharmaceutical waste, regulated medical waste, universal waste, recycling materials, and secure and confidential documents for shredding.  We also assess points of generation and equipment efficiency with focus on evaluating collective effectiveness and identifying needs and conditions for success. ·          Design, Deve...

While the EPA normally prohibits hazardous waste treatment without a permit, in Maryland one rare exception can be found.   Using an ENU under certain conditions and meeting certain requirements in Maryland help some generators of hazardous waste lower disposal cost and sometimes even generator status designation. An Elementary neutralization unit is defined as a device which is used for neutralizing wastes which are hazardous only because they exhibit the corrosivity characteristic and is a tank, tank system, container, transport vehicle, or vessel.   In order to reap the extended benefits of using this equipment you must meet the following requirements: 1.        The waste must only be corrosive characteristic (D002).   If the waste is hazardous for any other reason (ie. Toxic in addition to corrosive), the benefits cannot be applied. 2.        The waste must be treated in an ENU immediately upon gene...

Are you on track to complete your TRI report on time? What are TRI toxic chemicals? Every year on July 1, Toxic Release Inventory (TRI) Reports are due as required by EPCRA Section 313.   Section 313 contains a list of specific chemicals and chemical categories and requires facilities to file a TRI report annually for each “Section 313” chemical exceeding an activity threshold. Who needs to report?   If you meet all three of these criteria you are required to report: 1.        10 or more full-time employees or the equivalent 2.        Are in a TRI-covered industry sector (ie. NAICS codes are listed) 3.        At least one TRI-listed chemical meets minimum threshold during the calendar year Is this the same as Tier II? Although both are mandated regulatory reports and deal with chemical inventory, there are basic differences that make them distinct from one another...

In November 2016, the above mentioned rule was finalized, which marked a historic update to the Federal RCRA regulations as it pertains to hazardous waste generators.  The major changes in the rule went effective May 30, 2017.  Authorized states will have to adopt the more stringent regulations typically by July 1, 2018 (July 1, 2019 if state law change is required).  If you aren’t already, you need to ask yourself immediately, when and how are we affected?  The following are the noteworthy changes and states affected in the region: All regions An overall re-org and re-structuring of 40 CFR 262 to streamline navigation and understanding. For example previously known conditionally exempt small quantity generators (CESQGs) are now known as very small quantity generators (VSQGs). Updated retention policies for waste determination records. More stringent regulations An expansion of the marking and labeling requirements for hazardous waste containers in ...