RCRA civil penalties can be as high as $37,500 per violation, per day. While employee training is one of the most frequently cited violations, once you have a clear understanding of RCRA training requirements, it’s also one of the easiest to avoid. Like many generators, you probably know you are responsible for training employees but may be confused as to who needs to be trained and how much training is necessary. Add another layer of state-specific programs and you have a recipe for compliance issues. This post provides clarification around: who needs RCRA training, federal and state-specific training requirements, and what steps to take next.Read More
Environmental, Health & Safety Blog
On September 5, 2017, the U.S. Environmental Protection Agency awarded North Carolina Department of Environmental Quality (NCDEQ) for the third time in fiscal year 2017 with $1,018,260. This monetary award was given to NCDEQ to support their hazardous waste programs. Initially, the EPA awarded $1,352,976 to NCDEQ to support their hazardous waste-related environmental programs. I wanted to give you some perspective on two recent visits that my clients received from NCDEQ, and discuss how these visits can be a good thing and not something generators should be nervous about. If you would like to learn more about the specifics please click here.Read More
Environmental, health, and safety (EH&S) programs within a higher education niche pose unique challenges due to the complexity and ever-evolving nature of colleges and universities. There are several marks of a successful EH&S program, including a comprehensive training program for faculty and students. Today, we are going to share our tips and best practices for creating an effective lab training program that will help your college or university put together a program to minimize the risk of injury or illness to faculty, students, and researchers. Keep reading to learn the steps to creating a successful lab training program.Read More
The Resource Conservation and Recovery Act (RCRA) requires large quantity waste generators to submit a report every two years detailing their hazardous waste activities generated in the year prior. This is referred to as a Biennial Report or the National Biennial RCRA Hazardous Waste Report.Read More
RCRA civil penalties can be as high as $37,500 per violation, per day.While employee training is one of the most frequently cited RCRA violations, once you have a clear understanding of the requirements it’s also one of the easiest to avoid. Like many generators, you probably know you are responsible for training employees but may be confused as to who needs to be trained and how much training is necessary. Add another layer of state-specific programs and you have a recipe for compliance issues. This post provides clarification around: who needs RCRA training, Federal and State-Specific Training Requirements, and what steps to take next.Read More
I attended one of our very own RCRA hazardous waste trainings today. RCRA training is necessary to your success at your job if you’re dealing with the waste your company generates. RCRA is not just another set of regulations to make your job more difficult and complex. It has an interesting and important history and function within your organization. Not sure what I mean? Here are the top 5 reasons you want to get RCRA trained.
Whether you’re a large or small quantity generator of hazardous waste, you have a lot to think about regarding managing your hazardous waste in a safe and compliant way. In 2012 there was $16 million dollars worth of property damage due to hazardous waste incidents. Of those incidents, only 6% were blamed on natural causes. This means that of all accidents, 94% were preventable. Following hazardous waste regulations is one way to avoid hazardous waste related accidents.
The RCRA F006 rule provides a list of exceptions to wastewater treatment sludge from electroplating operations (40 CFR 260.11).
The list exempts sulfuric acid anodizing or tin-plating of steel, among other chemicals. This rule does a great job of explaining what is not F006 waste, but is pretty vague in regards to what is indeed covered under the F006 rule.
Larger definitions of electroplating include any process that coats a metal in another metal, usually by chemical and electrical means according to the EPA definition. This seems straightforward enough, but this broad definition of electroplating might cover more processes than you think. Many businesses in the metal treating, finishing, and processing fields are subject to this regulation, even those that might not explicitly be involved in electroplating by common definitions.
Overlooking or ignoring this regulation and subsequent improper disposal of waste can land you in hot water with the EPA, and can lead to fines if it's found you are out of compliance. In addition, waste that fits under this regulation is typically designated for special processing to recover the metals in that waste, and your business could benefit from certain compliance incentives if you can show the EPA that you're properly dealing with this waste.
Here are some other processes that aren't electroplating by some definitions, but still generate waste which falls under the umbrella of F006:
The EPA has been busy this month. With a range of suggested and confirmed updates to regulations, we pulled together a list of recent changes to help you keep track. For all the most recent updates in your industry, sign up for our monthly newsletter here.Read More