Universal Waste Aerosol Cans - Final Rule Summary
The Aerosol Cans Universal Waste Final Rule (UW Rule) incorporates aerosol cans containing hazardous waste that are generated and accumulated by various entities into the EPA’s Federal Universal Waste Rules found in Title 40 of the Code of Federal Regulations (40 CFR) Part 273. …
read moreThe US EPA’s View on Legitimate Recycling and the Generator-Controlled and Transfer-Based Exclusions for Hazardous Secondary Materials
The US EPA’s View on Legitimate Recycling and the Generator-Controlled and Transfer-Based Exclusions for Hazardous Secondary Materials (HSM). The concept of defining legitimate recycling in a manner that does not contribute to the disposal problem has been a historically difficult issue for the United States Environmental Protection Agency (EPA or Agency). The Agency has described many past environmental contamination and/or cleanup issues from the stockpiling of materials that were never actually recycled. In some cases, companies continued to stockpile these materials until they went out of business leaving cleanup issues behind. …
read moreTCLP vs SPLP and the Proper Applications for Each
Questions frequently arise within the regulated community regarding the differences between the TCLP and SPLP laboratory tests, and the proper applications for each. TCLP is an abbreviation of Toxicity Characteristic Leaching Procedure and SPLP is an abbreviation of Synthetic Precipitation Leaching Procedure. Both procedures are laboratory tests used to analyze leachate. …
read moreThe U.S. EPA's HWGIR Update of Container Accumulation Requirements for CAAs vs SAAs
The hazardous waste generator improvements rule (HWGIR), has created changes in some of the requirements for Central Accumulation Areas (CAAs) and Satellite Accumulation Areas (SAAs). The following table has been developed by Novesis to summarize the differing requirements for the accumulation/storage of hazardous wastes in containers by generators in CAAs versus SAAs. We hope you find it helpful. …
read moreThe U.S. EPA’s View on Solvents Used As Ingredients
When solvents are utilized by a process as an ingredient, they are no longer considered "spent" or "discarded", therefore they cannot be considered a listed hazardous waste (e.g. F001-F005 do not apply). …
read moreRequirements for Hazardous Waste Determinations as a Result of the Hazardous Waste Generator Improvements Rule (HWGIR)
The United States Environmental Protection Agency (U.S. EPA) published the final version of the Hazardous Waste Generator Improvements Rule (HWGIR or Rule) on November 28, 2016 and it became effective federally May 30, 2017. States have been allowed up to two (2) years from the effective date of the Rule to incorporate/adopt the more stringent elements of the Rule into their state programs. The Rule significantly changes the hazardous waste determination landscape for companies. …
read more7 Changes to SAAs by GIR
Seven (7) Significant Changes for the Management of Hazardous Waste in Satellite Accumulation Areas as a Result of the U.S. EPA’s Hazardous Waste Generator Improvements Rule (GIR) …
read moreThe U.S. EPA “Continued Use” Policy
Materials are not solid wastes until the decision is made to discard them. Materials that are not solid wastes cannot be RCRA regulated hazardous wastes. In the case of solvents, they are used until considered spent at which point they will be discarded. The U.S. EPA has a long established concept that materials are not solid wastes when they qualify for the Agency’s continued use policy, or in similar fashion, the secondary materials exemption regarding source substitution. …
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