Are You Ready for a Waste Management Inspection? Is Your Documentation in Order?

While there is no one national list of the most common violations, several sources keep track of various state violations issued. These violations can be broken out into waste handling, tracking (documentation) and training, and labeling. Lack of documentation is one of the easiest violations to correct. Simply, have all of your documents in order and […]

Are Your Spent Solvents Hazardous Waste?

Subtitle C of the Resource Conservation and Recovery Act (RCRA) requires generators to identify, count, notify, manage, transport, and recycle, treat or dispose of hazardous waste. Of all of these steps, the one I find the most neglected is the first: Identifying hazardous waste. Often times the personnel I encounter know how each material in […]

Kentucky Chamber 14th Annual Environmental Conference

With multiple environmental reporting due at the first of the year, it’s hard to find time to attend Conferences. However, February 9-10 is the 14th Annual Kentucky Chamber Environmental Conference. Several people from SMG will be providing value information on a host of subjects including “Environmental Policy, Politics and the Courts”, “Those Containers and Areas […]

Update on Proposed Changes to RCRA

EPA has received a number of requests to extend the comment period and in response is providing a 30-day extension. On November 5, 2015, EPA extended the comment period for both the generator improvements and hazardous pharmaceutical management proposed rules until December 24, 2015. Both of those rules were proposed in the September 25, 2015 […]

Proposed Rule: EPA RCRA Hazardous Waste Generator Rules

As we informed you in the last blog, the EPA Administrator signed the proposed Hazardous Waste Generator Improvements Rule on August 31, 2015. A pre-publication copy has been circulated and published at http://www2.epa.gov/hwgenerators/proposed-rule-hazardous-waste-generator-improvements. The proposed changes will have an effect for large, small and conditionally exempt small quantity generators. The proposed rule was published in […]