The document discusses a webinar about the EPA's Hazardous Waste Generator Improvements Rule. The webinar covered an overview of RCRA regulations for hazardous waste generators, current issues with the existing rules, details on the 7 major components of the finalized rule, and next steps for compliance. Attendees would receive a copy of the presentation, recording, and link to provide feedback on the webinar.
In October of 2016, the EPA signed the final Hazardous Waste Generator Improvements Rule to provide greater flexibility for hazardous waste generators and clarification around certain components of the hazardous generator program in an effort to improve compliance and environmental protection. The EPA has described the rule as “an overhaul of the hazardous waste generator regulatory program.” Some revisions appear to be more lenient than existing regulations, while others are more stringent, such as documenting hazardous waste determinations.
This presentation provides an overview of the major provisions proposed by the EPA in the new hazardous waste generator improvements rule. It outlines the four primary issues that exist with today's regulations and how some of the more significant proposals seeks to address those issues. Find out about the rule process and schedule and what this means for hazardous waste generators.
This presentation focuses on tactics for hazardous waste disposal and opportunities to save time and money. It delves into the regulations and how you can take advantage of storage options. Our speaker also addresses waste minimization and ways to reduce and and segregate your waste streams to meet sustainability goals. Learn about a few case studies that back these strategies up.
How well do you know your local EHS regulators? As 2019 rule proposals continue to develop, meet your local regulator to discuss how you may be impacted as an EHS practitioner. Do you have questions about existing regulations? This is the perfect opportunity to get them answered.
Benzene Fenceline Monitoring: An Introduction and What the Regulations Don’...All4 Inc.
Kristin Gordon presented, "Benzene Fenceline Monitoring: An Introduction and What the Regulations Don’t Tell You" at the 4C Conference in Austin, Tx in February 2016.
Presented to:
Chemical Destruction Community Advisory Board’s Explosive Destruction Technology Working Group
Presented by:
John McArthur, Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP)
Neil Frenzl, BGCAPP
Allison Respess, BGCAPP
Mark Wenclawiak All4 GHG PSD Permitting ChallengesAll4 Inc.
Mark Wenclawiak of All4 Inc. presented the challenges of greenhouse gas (GHG) Prevention of Significant Deterioration (PSD) permitting at the NCASI West Coast Regional Meeting on September 24, 2014. In the presentation, Mark discussed drivers for such projects and five (5) challenges encountered during the application development and agency review.
In October of 2016, the EPA signed the final Hazardous Waste Generator Improvements Rule to provide greater flexibility for hazardous waste generators and clarification around certain components of the hazardous generator program in an effort to improve compliance and environmental protection. The EPA has described the rule as “an overhaul of the hazardous waste generator regulatory program.” Some revisions appear to be more lenient than existing regulations, while others are more stringent, such as documenting hazardous waste determinations.
This presentation provides an overview of the major provisions proposed by the EPA in the new hazardous waste generator improvements rule. It outlines the four primary issues that exist with today's regulations and how some of the more significant proposals seeks to address those issues. Find out about the rule process and schedule and what this means for hazardous waste generators.
This presentation focuses on tactics for hazardous waste disposal and opportunities to save time and money. It delves into the regulations and how you can take advantage of storage options. Our speaker also addresses waste minimization and ways to reduce and and segregate your waste streams to meet sustainability goals. Learn about a few case studies that back these strategies up.
How well do you know your local EHS regulators? As 2019 rule proposals continue to develop, meet your local regulator to discuss how you may be impacted as an EHS practitioner. Do you have questions about existing regulations? This is the perfect opportunity to get them answered.
Benzene Fenceline Monitoring: An Introduction and What the Regulations Don’...All4 Inc.
Kristin Gordon presented, "Benzene Fenceline Monitoring: An Introduction and What the Regulations Don’t Tell You" at the 4C Conference in Austin, Tx in February 2016.
Presented to:
Chemical Destruction Community Advisory Board’s Explosive Destruction Technology Working Group
Presented by:
John McArthur, Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP)
Neil Frenzl, BGCAPP
Allison Respess, BGCAPP
Mark Wenclawiak All4 GHG PSD Permitting ChallengesAll4 Inc.
Mark Wenclawiak of All4 Inc. presented the challenges of greenhouse gas (GHG) Prevention of Significant Deterioration (PSD) permitting at the NCASI West Coast Regional Meeting on September 24, 2014. In the presentation, Mark discussed drivers for such projects and five (5) challenges encountered during the application development and agency review.
This presentation provides an overview of the major provisions proposed by the EPA in the new hazardous waste generator improvements rule. It outlines the four primary issues that exist with today's regulations and how some of the more significant proposals seeks to address those issues. Find out about the rule process and schedule and what this means for hazardous waste generators.
Training consistently ranks high on lists of most frequently cited violations. There are a variety of regulations that EH&S and lab professionals need to comply with. This presentation will help you understand which of your employees need which training and how much is necessary.
If your facility loses power what do you do? If there is a fire or flood how will you respond? These often-overlooked emergency situations are a costly threat to facilities across the US. Planning for emergencies can often seem daunting and time consuming, especially considering that OSHA requires a written plan. To make your life easier, our experts will share best practices for developing and implementing a rock-solid emergency action plan.
Handling Hazardous Building Materials: How to Avoid a Construction NightmareTriumvirate Environmental
Is your organization planning a renovation or expansion? Maybe you'd like to conduct building maintenance to prevent a future emergency? There are multiple hazards and toxins that need to be taken into consideration before starting a construction project. If hazards are not properly identified, tested and removed, they have the potential to derail a project. This presentation will show you how to handle hazardous building materials from the perspective of two environmental engineers.
Hazardous materials transportation compliance issues can cast a wide net across an organization and impact many people and departments. It is not unusual for compliance in this area to be decentralized and not fall completely under an EH&S department’s or manager’s responsibility. Check out this webinar presentation to learn from the twelve common mistakes which often arise in decentralized environments.
Learn how you can safely recycle the plastic from your single-use products. MilliporeSigma has partnered with Triumvirate Environmental to help you reduce what is currently being disposed of via landfill and incineration. This presentation offers a detailed look at the biopharma recycling program that is challenging conventional wisdom.
Internal vs. External EH&S: Considerations for Using Partners to Drive Greate...Triumvirate Environmental
Despite well-defined requirements, procedures, and targets, many organizations still struggle with delivering well-defined, exceptional EH&S compliance programs. Regardless of best intentions and expectations, the dragging factors of increasing regulatory complexity, hard to maintain skill sets, and operational mis-alignment continue to plague organizations resulting in poor EH&S outcomes. A strong partnership can reposition and drive stronger operational and financial outcomes. This presentation will help you find out if an external partnership is the right move for your organization.
Hazardous materials transportation compliance issues can cast a wide net across an organization and impact many people and departments. It is not unusual for compliance in this area to be decentralized and not fall completely under an EH&S department’s or manager’s responsibility. Check out this presentation to learn from the twelve common mistakes which often arise in decentralized environments.
Managing sharps and regulated medical waste (RMW) can be a costly and complicated process for healthcare facilities. Staying OSHA and RCRA compliant is a top priority, in addition to keeping costs down and operational efficiency up. This presentation provides information on how to revamp your program in a way that streamlines your RMW process to boost safety, efficiency and cost savings.
Internal vs. External EH&S: Considerations for Using Partners to Drive Greate...Triumvirate Environmental
Despite well-defined requirements, procedures, and targets, many organizations still struggle with delivering well-defined, exceptional EH&S compliance programs. Regardless of best intentions and expectations, the dragging factors of increasing regulatory complexity, hard to maintain skill sets, and operational mis-alignment continue to plague organizations resulting in poor EH&S outcomes. A strong partnership can reposition and drive stronger operational and financial outcomes. This webinar presentation will help you find out if an external partnership is the right move for your organization.
An industrial hygiene program is critical to environmental, health and safety. A good program can maximize worker health and safety, while a poor program can compromise safety and lead to frustration and confusion. The implementation and ongoing management of your employees' health and safety depends on a well-designed and properly executed industrial hygiene program.
Lithium batteries are the hottest topic in hazmat transportation today and the Federal Aviation Administration is aggressively enforcing penalties against employers who incorrectly offer them for transport (up to $77,114 per violation). To make matters worse, the shipping regulations are notoriously convoluted and confusing, and since their inception, have been continually changing. This presentation provides an overview of the regulatory requirements and enforcement trends, including the April 1, 2016 ICAO/IATA revisions.
The ANSI standard sets the stage for this discussion of glasses, goggles and face shields. When should each be used? Wearing eye protection is an important safety practice; choosing the correct type to protect your eyes, however, is crucial. Eye wash fountains, contact lens use, and portable shields are also discussed in this presentation.
While the ER coordinator serves as the point person during an emergency, it is important to prepare your entire facility for a possible ER in order to streamline the response and control the situation. Practicing different spill scenarios and other emergencies is the best way to identify procedural flaws and potential issues that could exacerbate an already dangerous situation.
This guide takes readers through maximum and minimum penalties from each regulatory body. Regulatory bodies covered include: OSHA, RCRA, Joint commission, Clean Water Act, and Clean Air Act.
For many higher education institutions, hazardous waste is disposed of as soon as it's generated and waste streams are typically comingled. Unfortunately, this approach toward waste management could cause you to lose money and result in your goals falling flat. It’s time to rethink your approach and adopt a more cost-effective and efficient strategy to managing your hazardous chemical waste.
DEA Pharmaceutical controlled substances infographic on the pros and cons of setting up a drop-off location for unused prescription drugs. For more information, look here. http://bit.ly/1HBi1cy
This presentation provides an overview of the major provisions proposed by the EPA in the new hazardous waste generator improvements rule. It outlines the four primary issues that exist with today's regulations and how some of the more significant proposals seeks to address those issues. Find out about the rule process and schedule and what this means for hazardous waste generators.
Training consistently ranks high on lists of most frequently cited violations. There are a variety of regulations that EH&S and lab professionals need to comply with. This presentation will help you understand which of your employees need which training and how much is necessary.
If your facility loses power what do you do? If there is a fire or flood how will you respond? These often-overlooked emergency situations are a costly threat to facilities across the US. Planning for emergencies can often seem daunting and time consuming, especially considering that OSHA requires a written plan. To make your life easier, our experts will share best practices for developing and implementing a rock-solid emergency action plan.
Handling Hazardous Building Materials: How to Avoid a Construction NightmareTriumvirate Environmental
Is your organization planning a renovation or expansion? Maybe you'd like to conduct building maintenance to prevent a future emergency? There are multiple hazards and toxins that need to be taken into consideration before starting a construction project. If hazards are not properly identified, tested and removed, they have the potential to derail a project. This presentation will show you how to handle hazardous building materials from the perspective of two environmental engineers.
Hazardous materials transportation compliance issues can cast a wide net across an organization and impact many people and departments. It is not unusual for compliance in this area to be decentralized and not fall completely under an EH&S department’s or manager’s responsibility. Check out this webinar presentation to learn from the twelve common mistakes which often arise in decentralized environments.
Learn how you can safely recycle the plastic from your single-use products. MilliporeSigma has partnered with Triumvirate Environmental to help you reduce what is currently being disposed of via landfill and incineration. This presentation offers a detailed look at the biopharma recycling program that is challenging conventional wisdom.
Internal vs. External EH&S: Considerations for Using Partners to Drive Greate...Triumvirate Environmental
Despite well-defined requirements, procedures, and targets, many organizations still struggle with delivering well-defined, exceptional EH&S compliance programs. Regardless of best intentions and expectations, the dragging factors of increasing regulatory complexity, hard to maintain skill sets, and operational mis-alignment continue to plague organizations resulting in poor EH&S outcomes. A strong partnership can reposition and drive stronger operational and financial outcomes. This presentation will help you find out if an external partnership is the right move for your organization.
Hazardous materials transportation compliance issues can cast a wide net across an organization and impact many people and departments. It is not unusual for compliance in this area to be decentralized and not fall completely under an EH&S department’s or manager’s responsibility. Check out this presentation to learn from the twelve common mistakes which often arise in decentralized environments.
Managing sharps and regulated medical waste (RMW) can be a costly and complicated process for healthcare facilities. Staying OSHA and RCRA compliant is a top priority, in addition to keeping costs down and operational efficiency up. This presentation provides information on how to revamp your program in a way that streamlines your RMW process to boost safety, efficiency and cost savings.
Internal vs. External EH&S: Considerations for Using Partners to Drive Greate...Triumvirate Environmental
Despite well-defined requirements, procedures, and targets, many organizations still struggle with delivering well-defined, exceptional EH&S compliance programs. Regardless of best intentions and expectations, the dragging factors of increasing regulatory complexity, hard to maintain skill sets, and operational mis-alignment continue to plague organizations resulting in poor EH&S outcomes. A strong partnership can reposition and drive stronger operational and financial outcomes. This webinar presentation will help you find out if an external partnership is the right move for your organization.
An industrial hygiene program is critical to environmental, health and safety. A good program can maximize worker health and safety, while a poor program can compromise safety and lead to frustration and confusion. The implementation and ongoing management of your employees' health and safety depends on a well-designed and properly executed industrial hygiene program.
Lithium batteries are the hottest topic in hazmat transportation today and the Federal Aviation Administration is aggressively enforcing penalties against employers who incorrectly offer them for transport (up to $77,114 per violation). To make matters worse, the shipping regulations are notoriously convoluted and confusing, and since their inception, have been continually changing. This presentation provides an overview of the regulatory requirements and enforcement trends, including the April 1, 2016 ICAO/IATA revisions.
The ANSI standard sets the stage for this discussion of glasses, goggles and face shields. When should each be used? Wearing eye protection is an important safety practice; choosing the correct type to protect your eyes, however, is crucial. Eye wash fountains, contact lens use, and portable shields are also discussed in this presentation.
While the ER coordinator serves as the point person during an emergency, it is important to prepare your entire facility for a possible ER in order to streamline the response and control the situation. Practicing different spill scenarios and other emergencies is the best way to identify procedural flaws and potential issues that could exacerbate an already dangerous situation.
This guide takes readers through maximum and minimum penalties from each regulatory body. Regulatory bodies covered include: OSHA, RCRA, Joint commission, Clean Water Act, and Clean Air Act.
For many higher education institutions, hazardous waste is disposed of as soon as it's generated and waste streams are typically comingled. Unfortunately, this approach toward waste management could cause you to lose money and result in your goals falling flat. It’s time to rethink your approach and adopt a more cost-effective and efficient strategy to managing your hazardous chemical waste.
DEA Pharmaceutical controlled substances infographic on the pros and cons of setting up a drop-off location for unused prescription drugs. For more information, look here. http://bit.ly/1HBi1cy
The Petroleum Refinery Sector Rule: What’s all the fuss about and what are th...All4 Inc.
Kristin Gordon presented, "The Petroleum Refinery Sector Rule: What’s all the fuss about and what are the key implications for Texas (including other industry sectors)?” at the AWMA Central Texas Chapter Meeting on January 21, 2016.
In this presentation, FMC’s Bernard Roth outlines the current trends in energy regulatory law. The presentation includes the following topics:
- Trends in Facilities Regulation
- Alberta Non-Utility Oil and Gas Facilities
- AER Structure
- Responsible Energy Development
- Federal Budget Legislative Changes
- Federal Fisheries Act
- Navigable Waters Protection Act
- Canadian Environmental Assessment Act
- Trends in Utilities Regulation
- Performance Based Regulation for Alberta Utilities
In June 2010, EPA proposed a rule to regulate coal combustion residuals (“CCRs”) under the Resource Conservation and Recovery Act (RCRA). After a lengthy delay, the proposed rule, which set forth two options for the regulation of CCRs, is expected to be finalized by the end of this year.
Requirements for Continuous Emissions Monitoring. Proposed Amended Rules (PAR...GeneAmnuel
If you missed the last meeting, here is the presentation that was discussed with Community Groups and Industry Partners. We were fortunate to have a strong technical presence at the meeting, and welcome any discussion that is of interest to your facility.
A Deep Dive into the RCRA Regulations: Are You Aware of These Lesser Known Re...Triumvirate Environmental
We are all familiar with the standard requirements found within the hazardous waste regulations such as labeling, closure requirements, secondary containment, training, and other basic rules and requirements. But are you aware that there are more? Taking a deeper look into RCRA regulations reveals much more, including:
Daily Tank Inspections and Recording Requirements
Subpart AA- Organic Emission Standards
Subpart BB- Air Emission Standards
And more…
We will review each of the lesser known RCRA requirements to provide you with a complete understanding of the regulation and help ensure compliance.
Similar to The Hazardous Waste Generator Improvements Rule (20)
How to Prepare for and Respond to a Confirmed COVID-19 Case at Your Lab or Ma...Triumvirate Environmental
As essential businesses continue to operate, it’s crucial to consider how to handle a confirmed COVID-19 case in the workplace. Despite safety precautions to avoid the spread, one of your employees may get sick – do you know what to do? The COVID-19 pandemic has drastically altered how we work and operate. Take a proactive approach to safely keep your business operational in the event of a confirmed COVID-19 case by developing sound disinfection policies and procedures.
ISO auditing leads to improved company EHS culture, consistency, and team focus. When organizations conform to these ISO standards and obtain third-party ISO certification, it authenticates that they utilize standardized management systems to continuously improve Occupational Health and Safety and Environmental performance.
Does your organization need an industrial hygiene program? Are you looking to create a program but don’t know where to start? Industrial hygiene allows you to anticipate, evaluate and control environmental factors that impact people’s health. Critical to environmental health and safety, an industrial hygiene program is important not only for regulatory compliance but also to maintain your public relations and reputation.
The deadlines for Tier II Reports, Biennial Reports, and OSHA 300 Logs are all fast approaching. Are you prepared to file all your necessary reports in time? It is important to take the time to carefully review your facility to determine your requirements for these regulatory reports.
Cannabis growers, cultivators, and distributors face unique compliance challenges when navigating federal and state regulations, managing hazardous and non-hazardous waste streams, and ensuring your facility runs safely and compliantly. This webinar will help early-stage and fast-growing cannabis companies understand the state and federal regulatory environment, obtain permits and licenses, and build environmental, health, and safety (EH&S) programs. Whether your cannabis organization is new to the compliance world or has some safety programs in place, this webinar will provide guidance on how to reach operational excellence.
The Key Elements of Building an OSHA-Compliant Workplace from the Ground UpTriumvirate Environmental
OSHA violations are expensive and time consuming to resolve. It is significantly cheaper and easier to create an OSHA-compliant workplace from the start. Ensuring OSHA compliance requires a complete understanding of the OSHA requirements and a complete assessment of your current workplace. In this webinar, our expert will walk you through the key steps to creating an OSHA-compliant workplace.
In September, OSHA released its latest “Top 10” list of most frequently cited workplace violations. Hear our expert analyze the most common OSHA violations and the overall state of EHS regulatory compliance in 2019.
2019 Healthcare Accreditation Regulatory Updates: How Do the New Regulations ...Triumvirate Environmental
Recently there have been regulatory updates that affect healthcare facilities including standards that apply to hospital accreditation. The Joint Commission applies standards that pertain to federal Medicare and Medicaid reimbursement. Has your facility adapted to comply with the current and updated standards? Hear our expert provide a comprehensive look at the “Environment of Care” and see how to better adapt your facility to ensure the health and safety of hospital staff, patients, and visitors.
Oil spills present real public health and environmental concerns. In response to these concerns, the EPA created rules around SPCC. The EPA’s SPCC rules are meant to prevent oil discharge from entering navigable waters and/or adjoining shorelines.
There have been many recent changes to the DEA and EPA regulations regarding pharmaceutical waste management. Is your organization compliant with the current rules? Here is a comprehensive look at the disposal and onsite waste management regulations for controlled substances.
Measuring the Success of Your EHS Program: Are You Tracking These Key Perform...Triumvirate Environmental
You have taken the first step and implemented an EHS program in your workplace, but how do you know if the program is working? Do you fall short on meeting department and corporate goals? Do you know which metrics you should be tracking to ensure the success of your EHS program?
There are over 90 biotechnology and pharmaceutical laboratories located within the Cambridge city limits. With such a high concentration of labs, the city has stringent regulations to contain exposure risks and ensure that the community is safe. In this session, the Department of Public Health will discuss lab safety in the city. Join us to gain a more comprehensive understanding of Massachusetts and Cambridge regulations to ensure you are running a safe and compliant lab.
Why Audit? What Is the Difference Between Regulatory Auditing and ISO 14001 o...Triumvirate Environmental
We hear about the importance of conducting audits of your facilities. They allow us to be prepared for when the regulators show up. However, have you ever considered obtaining an ISO certification? The two standards that focus solely on EH&S are the ISO 14001 Environmental Management Standard or the ISO 45001 Occupations Health and Safety Standard. This session will cover the importance of auditing, what the ISO standards entail, and how they may actually help you with compliance and to show your end users that you care about your employees' health and safety and the environment.
Managing Medical or Biological Waste in Massachusetts - Guidance for GeneratorsTriumvirate Environmental
Medical or Biological Waste, a.k.a., Regulated Medical Waste, is regulated by the Massachusetts Department of Public Health. DPH has adopted management requirements codified under 105 CMR 480 that affect those who generate such wastes. Individuals impacted by these rules would be employees who are responsible for the medical/bio waste management program and those who manage the waste onsite (e.g., internal transport, storage, onsite treatment, and other handling).
Recently the National Safety Council collaborated with three Campbell Institute members to understand the role fatigue plays in their operations at selected locations. Research participants took part in a two-part survey consisting of an operational needs assessment and an employee survey.
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Despite well-defined requirements, procedures, and targets, many organizations still struggle with delivering well-defined, exceptional EHS compliance programs. A strong external partnership can reposition your EHS compliance program and drive strong operational and financial outcomes. But once you decide to establish an EHS partnership, how do you ensure you are getting the most out of it?
Chemical inventory management is often a confusing and labor-intensive exercise. This webinar sheds light on how to build, operationalize, and improve a chemical inventory program. We will dissect the many nuances of a chemical inventory, and offer innovative, service-based solutions to help you successfully manage your chemical inventory program.
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Does your facility have a fully compliant environmental program? Are you prepared for your next EPA audit? In this session, you will receive a comprehensive overview of the EPA and the components needed to create a compliant environmental program for your workplace. We will cover environmental compliance in both laboratory and manufacturing settings.
"Understanding the Carbon Cycle: Processes, Human Impacts, and Strategies for...MMariSelvam4
The carbon cycle is a critical component of Earth's environmental system, governing the movement and transformation of carbon through various reservoirs, including the atmosphere, oceans, soil, and living organisms. This complex cycle involves several key processes such as photosynthesis, respiration, decomposition, and carbon sequestration, each contributing to the regulation of carbon levels on the planet.
Human activities, particularly fossil fuel combustion and deforestation, have significantly altered the natural carbon cycle, leading to increased atmospheric carbon dioxide concentrations and driving climate change. Understanding the intricacies of the carbon cycle is essential for assessing the impacts of these changes and developing effective mitigation strategies.
By studying the carbon cycle, scientists can identify carbon sources and sinks, measure carbon fluxes, and predict future trends. This knowledge is crucial for crafting policies aimed at reducing carbon emissions, enhancing carbon storage, and promoting sustainable practices. The carbon cycle's interplay with climate systems, ecosystems, and human activities underscores its importance in maintaining a stable and healthy planet.
In-depth exploration of the carbon cycle reveals the delicate balance required to sustain life and the urgent need to address anthropogenic influences. Through research, education, and policy, we can work towards restoring equilibrium in the carbon cycle and ensuring a sustainable future for generations to come.
UNDERSTANDING WHAT GREEN WASHING IS!.pdfJulietMogola
Many companies today use green washing to lure the public into thinking they are conserving the environment but in real sense they are doing more harm. There have been such several cases from very big companies here in Kenya and also globally. This ranges from various sectors from manufacturing and goes to consumer products. Educating people on greenwashing will enable people to make better choices based on their analysis and not on what they see on marketing sites.
WRI’s brand new “Food Service Playbook for Promoting Sustainable Food Choices” gives food service operators the very latest strategies for creating dining environments that empower consumers to choose sustainable, plant-rich dishes. This research builds off our first guide for food service, now with industry experience and insights from nearly 350 academic trials.
3. During this Webinar
All lines will be muted.
Communicate via the questions tab in your
webinar panel.
Unanswered questions will be responded to after
the webinar.
Webinar recording and slides will be emailed to
you tomorrow.
4. Meet Your Presenter
Geraldine “Gigi”
Dambreville
Environmental Health and Safety
Consultant,
Triumvirate Environmental Inc.
7. The Resource Conservation and
Recovery Act of 1976:
Originally conceived as a law
addressing municipal trash
disposal, Subtitle C of RCRA
was included to give the U.S.
Environmental Protection
Agency (EPA) the authority to
regulate hazardous waste. This
includes the generation,
transportation, treatment,
storage, and disposal of
hazardous waste.
RCRA and Generators
8. HSWA continued where RCRA, Subtitle C left off,
including: adding mandates for the regulation of small
quantity generators, restrictions on land disposal of
hazardous waste, regulation of underground storage tanks
(USTs), and corrective action provisions to prevent RCRA
facilities from becoming Superfund sites.
The Hazardous and Solid Waste
Amendments of 1984:
HSWA and Generators
9. History of the Rule
• Hazardous Waste Generator Program
evaluation – April 2004
• Hazardous Waste Determination Program
evaluation – 2013
• Hazardous Waste Generator Proposed Rule
– 2015
10. 40 CFR Parts 260 – 265
mainly
Federal register notice
September 25th, 2015
Comment period ended
December 24th,2015
Proposed
Regulations
11. Final Rule!
Signed by the EPA
Administrator on October
28, 2016
Will be published in the
Federal Register in the
coming weeks
Made effective May 30th
2017
12. Generators
Transporters
Treatment,
Storage and
Disposal Facilities
(TSDFs)
• Part 261- Waste Identification
• Part 262- Generator Requirements
• Part 263- Transporter Requirements
• Part 264- 265- TSDF Requirements
• Part 266- Recycling
• Part 268- Land Disposal Restrictions
• Part 270- TSDF Permitting
• Part 271- State RCRA Programs
40 CFR Parts: 260-281
Who’s Covered Under State &
Federal RCRA Regulations?
13. The amount and type of hazardous waste
generated in a given calendar month will
determine your “generator status”.
Large Quantity Generators (LQGs)
Small Quantity Generators (SQG)
Conditionally Exempt Small
Quantity Generators (CESQGs)
Generator Status
20. Goals of the
Final Rule
1. Reorganize the regulations to make them more user friendly and
enable improved compliance
2. Provide greater flexibility for hazardous waste generators to
manage waste in a cost-effective manner
3. Strengthen environmental protection by addressing identified gaps
in the regulations
4. Clarify certain components of the hazardous waste generator
program to address ambiguities and foster improved compliance
21. 40 CFR Part 260 – Standards for
the classification of hazardous
wastes generators and specific
Types of Hazardous Waste
Management Facilities
Part 262 – Management
Standards for Hazardous Waste
Where Will the
Regulations Live?
23. 1. Consolidation of CESQG Waste at LQG’s:
• CESQG to be called VSQG
• CESQG’s and LQG’s must be under the control of the same
person
• Eliminate RCRA permit requirement to accept CESQG’s waste
• Additional option for CESQG’s to manage their waste
• Increased training and documentation
• Potentially decrease generator cost
Rule #1
24. 2. Episodic Generation for CESQG’s and SQG’s:
• Only allowed once a year
• Would not change current generator status
• Would not have to complete biennial requirement
• Notification of planned and unplanned events
• Labeling requirement for accumulation of episodic waste
• 60 days from initiation and completion of episodic event
Rule #2
25. 3. Emergency Planning and Preparedness:
• Only applicable to LQG’s and SQG’s
• Require generators to make arrangements with local LEPC’s first
• If no local LEPC, generators to make arrangements with local Fire
Departments
• NEW LQG’s to submit executive summary to LEPC rather than full
contingency plans
• Eliminating employee personal information in plans
Rule #3
26. 4. Labeling changes:
• Applicable to SQG’s, LQG’s and Transporters
• Marking containers with hazardous waste codes
• Make it easier for TSDF’s to identify content
• Relevant areas on site: SAA’s, CAA’s, transfer facilities
consolidating waste from different generators
• Labeling requirement for tanks, drip pads and containment buildings
• Recordkeeping requirements for tanks, drip pads, containment
building for 90 and 180 day storage
Rule #4
27. 5. Reporting Requirements:
• Biennial reporting required only for LQG’s
• Reporting for all hazardous waste generated
during reporting year
• Not applicable to CESQG’s and SQG’s under
episodic rule
• Allow new source code for CESQG’s transferred
waste
Rule #5
28. 6. Satellite Accumulation areas:
• Prohibiting incompatible waste to be mixed in the
same container
• Limited exception for keeping containers closed at
all times at SAA’s
• Modify labeling to include flexibility on hazard
category type
• Clarify the “three day” rule
Rule #6
29. Rule #7
7. Closure:
• Require closure as landfill for when LQG’s
accumulating in containers fail to clean close
• Notification to EPA or authorized state 30 days
prior to closing an accumulation area or within 90
days after closure of unit or facility
30. • Documenting hazardous waste determinations
• SQG re-notification
• Labeling
• Notification of closure
• Biennial reporting for the whole year
• Executive summary for contingency plan
More Stringent Rules
32. EPA Considers certain proposed provisions to be more
stringent than current regulations
• More stringent regulations – all states will be required to adopt
the final rule
• Less stringent regulations – states may but are not required to
adopt federal regulations
No final authorization on base State RCRA program
• Will be effective in these states on the effective date for the final
rule, even before the state adopts it
State Adoption
34. Prepare yourself for drastic changes
Understand how you may be affected
Follow up for more information
What’s next?
Wrap Up
35. Thank You For Attending!
You Will Receive:
• A copy of this presentation and the
webinar recording
• A link to a short survey
• A special offer to help ensure that
your hazardous waste program is
fully compliant
Geraldine “Gigi” Dambreville
gdambreville@triumvirate.com
www.Triumvirate.com
Contact: