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June 11, 2019

U.S.: New Hazardous Waste Pharmaceuticals Rule: Significant Changes Coming for Health Care Facilities, Particularly Long-Term Care Facilities

Filed under: Industry News — TWP Admin @ 12:01 am


Health care facilities that provide a host of health care-related services or distribute, sell, or dispense pharmaceuticals will need to learn a whole new set of regulations thanks to a finalized new rule promulgated by the United States Environmental Protection Agency (EPA). The new rule revises management standards for hazardous waste pharmaceuticals (HWPs) for health care facilities, including nursing, skilled nursing, and inpatient hospice facilities, more than three years following the close of comments for the EPA’s initial proposed rule. The revised regulations will take effect six months following publication in the Federal Register.

The Resource Conservation Recovery Act (RCRA) governs the generation, management, storage, treatment, and disposal of hazardous wastes. Before the new rule was promulgated, certain health care facilities, such as hospitals and reverse distributors were subject to the same hazardous waste requirements under the RCRA as most industries. The management of HWPs at long-term care facilities, however, was excluded from the RCRA and treated the same as HWPs at residential households. EPA makes clear in this new rule that because nursing, skilled nursing, and inpatient hospice facilities are more akin to hospitals, their management of any hazardous waste, including HWPs, will also be subject to RCRA requirements.

The final rule revises some of the regulations and management standards for HWPs under the RCRA and sets them apart in a separate section of the RCRA regulations, to be codified at 40 C.F.R. Part 266, Subpart P (“Subpart P”), that are applicable specifically to health care facilities and reverse distributors. According to the EPA, this is necessary because hazardous waste generation and management practices at health care facilities differ significantly from those encountered in industry generally. As a result, regulating HWPs under the standard provisions of RCRA Subtitle C has been unnecessarily difficult. The EPA maintains that the new management standards are more streamlined and tailored specifically for healthcare HWPs and thus will promote proper management of HWPs by healthcare workers and pharmacy employees.

The final rule does not increase the universe of pharmaceuticals that are considered hazardous waste. However, it does accomplish four significant and practical changes in the management of pharmaceuticals: (1) HWPs that are to be sent off-site for reverse distribution will be regulated as hazardous wastes under the RCRA while still at the health care facility, (2) HWPs are banned from being disposed of down a drain or in a toilet, thereby reducing the amount of pharmaceutical ingredients that contaminate drinking water and endanger the environment, (3) it is easier to make a HWP container legally “empty,” and (4) nicotine replacement therapies are no longer considered potential hazardous wastes. Some of the components of the final rule will relieve the existing burdens on generators of HWPs, while other components may make the management of HWPs more onerous, at least initially.


Applicability to Long-Term Care Facilities

As noted above, the final rule applies to health care facilities. The definition of “health care facility” specifically includes long-term care facilities. A “long-term care facility,” in turn, is defined as:

[A] licensed entity that provides assistance with activities of daily living, including managing and administering pharmaceuticals to one or more individuals at the facility. This definition includes, but is not limited to, hospice facilities, nursing facilities, skilled nursing facilities, and the nursing and skilled nursing care portions of continuing care retirement communities. Not included within the scope of this definition are group homes, independent living communities, assisted living facilities and the independent and assisted living portions of continuing care retirement communities. (emphasis added).

The exclusion of assisted living from the definition of long-term care facility in the rule avoids many of the practical issues with control over medications taken directly by patients and use of multiple pharmacies that flow from the functional differences between nursing homes and assisted living facilities. The distinction constitutes a welcome change from the 2015 proposed rule, which sought to include such facilities in the definition of long-term care facility. The EPA stated unequivocally that HWPs that are in (a) the custody of the long-term care facility on behalf of the resident, or (b) an in-house pharmacy maintained by such facility (if any), must be managed under Subpart P.

Definitions and Analysis

The analysis necessary to determine whether a given substance is considered a HWP involves three questions:

Question 1 – Is it a Pharmaceutical? Under the final rule, a pharmaceutical includes, but is not limited to, the following:

  • Dietary supplements, as defined by the Federal Food, Drug and Cosmetic Act;
  • Prescription drug, as defined by 21 C.F.R. § 203.3(y);
  • Over-the-counter drugs;
  • Homeopathic drugs;
  • Compounded drugs;
  • Investigational new drugs;
  • Pharmaceuticals remaining in non-empty containers;
  • Personal protective equipment contaminated with pharmaceuticals; and
  • Clean-up material from spills of pharmaceuticals.

The definition also includes any electronic nicotine delivery system and liquid nicotine packaged for retail sale. Excluded from the definition are sharps and dental amalgam.

Question 2 – Is it a Solid Waste? A solid waste is any discarded material that is not otherwise excluded under the regulations that implement RCRA. What constitutes a RCRA solid waste, however, is not limited to wastes that are physically solid. Many solid wastes are liquid, semi-solid, or gaseous material. A material is considered “discarded” once the facility has decided to discard it, and must be managed appropriately at that point in time. A material that is legitimately going to be used, reused or reclaimed is not discarded and is not a solid waste. Note, however, that under the final rule, EPA has pre-determined that a health care facility’s decision to reverse distribute a pharmaceutical constitutes a decision to discard the pharmaceutical.

Question 3 – Is it a HWP? Solid wastes that are pharmaceuticals are only considered hazardous waste under RCRA if they are either listed as hazardous wastes or exhibit one of the characteristics of hazardous waste. There are four lists–F , K , P and U –based on either manufacturing and industrial processes, or chemical designations. The F and K lists are based on manufacturing and industrial processes, none of which apply to pharmaceuticals for humans. The P and U lists are based on chemical products. The EPA notes that there are approximately 30 “Commercial Chemical Products” on the P and U lists that have uses in multiple pharmaceuticals. A Commercial Chemical Product is only a waste if (i) it has not been used or used as intended, and (ii) consists of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed or the chemical is the sole active ingredient in the formulation. If these criteria are not met, then the pharmaceutical is not a HWP, even if included in the P or U list.

As noted above, even if a pharmaceutical waste is not listed on any of the lists, it may also qualify as a hazardous waste if it exhibits one of the four characteristics of hazardous waste:

  • Ignitability (something flammable) – for example, solutions containing more than 24% alcohol,
  • Corrosivity (something that can rust or decompose) – for example, certain compounding chemicals,
  • Reactivity (something explosive), and
  • Toxicity (something poisonous).

The answer to all three of the foregoing questions must be yes for the material to qualify as a HWP, though the final rule does contain certain exceptions that may apply to exclude a pharmaceutical from being considered a HWP for purposes of RCRA Subpart P. A long-term care facility that determines that it does generate HWPs must then conduct further analysis to determine the nature of its obligations under Subpart P.


Scope of Obligations under Subpart P – Amount of Waste Generated

Once the determinations have been made that a long-term care facility is covered by the final rule and has HWPs, the analysis shifts from the type of facility and nature of the waste to the amount of the waste, to determine the scope of the facility’s obligations under Subpart P. Specifically, the next inquiry is the amount of HWPs that the facility generates. Under RCRA, a “Generator” is a person whose act or process produces hazardous waste or whose act first causes a hazardous waste to become subject to regulation. Therefore, a facility that makes the determination to “discard” a pharmaceutical becomes a Generator. A facility that generates less than or equal to any of the following per calendar month qualifies as a Very Small Quantity Generator (VSQG) :

  • 100 kg (220 pounds) of hazardous waste; or
  • 1 kg (2.2 pounds) of acute hazardous waste.

Under the final rule, long-term care facilities with 20 or fewer beds are presumed to be VSQGs, thereby shifting the burden of proof to the EPA Administrator to establish that a facility is not a VSQG. Facilities with more than 20 beds, however, bear the responsibility of demonstrating that they qualify as a VSQG.

If a facility generates total hazardous waste in amounts exceeding the VSQG thresholds, it must treat its HWPs in accordance with the management standards of Subpart P. While VSQGs may opt to handle their HWPs in accordance with the management standards of Subpart P, they are not required to do so except for the sewering ban and empty container provisions of Subpart P. If a VSQG does not opt to comply with the management standards of Subpart P, its HWPs are subject to the general hazardous waste provisions of 40 C.F.R. § 262.14, which may be less than the requirements of Subpart P. Further, a long-term care facility that is a VSQG may dispose of its HWPs (other than contaminated personal protective equipment or clean-up materials) in an on-site collection receptacle of an authorized collector that is registered with the Drug Enforcement Administration (DEA), provided the contents are collected, stored, transported, destroyed and disposed of in compliance with all applicable regulations for controlled substances.

Whether a long-term care facility that qualifies as a VSQG opts to treat its HWPs in accordance with the management standards of Subpart P likely will depend on (1) the willingness of the facility to undertake the monthly calculations, monitoring and recordkeeping required to demonstrate that their hazardous waste is within the limits established for VSQGs, or (2) whether the decision not to comply with Subpart P would render the facility subject to more onerous requirements on other hazardous waste that it generates. If a facility also generates non-pharmaceutical RCRA hazardous waste, such as lab wastes for example, those wastes are not regulated under Subpart P but under the existing RCRA regulations. The standard regulations become more stringent as the amount of applicable waste increases. Facilities could decrease the overall amount of waste and thus lessen the impact of the standard regulations by not including the HWPs that are managed instead under Subpart P.


Scope of Obligations under Subpart P – Prescription HWPs versus Non-Prescription HWPs and Non-Creditable Prescription HWPs versus Potentially Creditable Prescription HWPs

Once the determination has been made that a long-term care facility is subject to the management standards of Subpart P, the requirements vary based on whether or not the pharmaceutical required a prescription. For prescription drugs, a facility must determine if it is managing a potentially creditable HWP or a non-creditable HWP. A “potentially creditable hazardous waste pharmaceutical” is a prescription HWP that has a “reasonable expectation to receive manufacturer credit through reverse distribution and is (1) in original manufacturer packaging (except pharmaceuticals that were subject to a recall) even if opened; (2) undispensed; and (3) unexpired or less than one year past expiration date.”

A non-creditable HWP is a prescription pharmaceutical that does not meet the above three criteria and therefore is not likely to receive credit back through reverse distribution. Non-prescription HWPs that do not have a reasonable expectation to be legitimately used, reused or reclaimed are also considered non-creditable HWPs. On the other hand, non-prescription over the counter pharmaceuticals that go through reverse logistics because they have a reasonable expectation of being recycled are not “Solid Waste” under RCRA at all, and therefore are not subject to Subpart P either. The management standards for potentially creditable HWPs are not as stringent as those for non-creditable HWPs.

Because of the requirement that the pharmaceutical be undispensed, it is likely that only long-term care facilities that have an in-house long-term care pharmacy will be managing potentially creditable HWPs. Those long-term care facilities that contract for their pharmacy services with a long-term care pharmacy will be managing non-creditable HWPs because pharmaceuticals are considered to be dispensed when the order is filled by the external pharmacy.

Unlike the existing general RCRA standards for the management of hazardous wastes, standards for HWPs under the new Subpart P are the same regardless of the amounts generated or the places where they are accumulated.


Management Standards for Non-Creditable HWPs

Notification – A long-term care facility that is subject to the requirements of Subpart P must notify the EPA Regional Administrator within 60 days of the effective date of Subpart P (or within 60 days of becoming subject to Subpart P) that it is a healthcare facility operating under Subpart P, even if the facility already has an EPA Identification Number. Notification may be filed electronically. The facility must keep a copy of the notification on file for as long as the facility is subject to Subpart P. If the facility subsequently qualifies as a VSQG and elects to withdraw from Subpart P, it must so notify the EPA Regional Administrator and may not begin operating under the conditional exemption applicable to VSQGs generally under RCRA until notification has been made. Withdrawal notifications must be kept on file for a period of three (3) years.

Training – All facility personnel that manage HWPs must be trained and be “thoroughly familiar” with proper waste handling and emergency procedures relative to their responsibilities. EPA has not stated whether the agency will offer compliance assistance or training materials to facilities. As a result, because the final rule will become effective six months following publication in the Federal Register, facilities should begin exploring their options for training as early as possible.

Hazardous Waste Determination – The facility must determine whether a non-creditable pharmaceutical is a HWP. In lieu of making such a determination, the facility may choose to manage all waste pharmaceuticals as HWPs under Subpart P.

Containers – Because a facility will likely accumulate HWPs for some period of time before shipping them off-site, the final rule prescribes standards for containers that will be used to store HWPs. Generally, any container used to accumulate HWPs must be structurally sound, compatible with its contents, and lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. Such container must be kept closed and secured so as to prevent unauthorized access to its contents.

Labeling Containers – All containers used to accumulate HWP must be labeled or clearly marked with the phrase “Hazardous Waste Pharmaceuticals.”

Maximum Accumulation Time – A facility may accumulate non-creditable HWPs on-site for a period not to exceed one year without a permit. The period begins on the date the pharmaceutical first becomes a waste, and the facility is responsible for demonstrating how long HWPs have been accumulating. The final rule allows the facility to make this demonstration by marking/labeling the container, maintaining an inventory system or by placing the HWPs in a specific area and identifying the earliest date that any of the HWPs in that area became a waste. To the extent that any HWPs are able to be commingled safely in a container, the date on which the very first HWP was deposited in the container would start the one year clock running.

Land Disposal Restrictions – A facility must comply with extensive requirements pertaining to land disposal restrictions at 40 C.F.R. Section 268.7(a), but these have been relaxed to the extent that the individual waste codes no longer need to be identified on the land disposal restriction notification.

Shipping – As noted above, a long-term care facility may accumulate non-creditable HWPs on-site only for a limited time before it must ship them off-site to a pre-designated authorized facility for treatment, storage or disposal. The final rule includes specific requirements for such shipments.

  • Pre-Transport
    • Packaging, Labeling and Marking – Generally, all waste must be packaged, labeled and marked in accordance with applicable Department of Transportation (DOT) regulations.
      • Containers of 119 gallons or less must be marked with specific words and information, including “HAZARDOUS WASTE.”
      • With limited exceptions specified in the final rule, lab packs that will be incinerated are not required to be marked with EPA Hazardous Waste Numbers.
    • Placarding – A long-term care facility must placard or offer the initial transporter the appropriate placards as specified under DOT regulations.
  • Manifests – A facility must use a uniform manifest and comply with applicable manifest requirements except that instead of listing the individual waste codes, the facility should write “PHARMS” on the form.
  • Facilities may ship HWPs across state lines, but will only be able to use the provisions in Subpart P if both states have adopted the same regulations (see below).

Managing Rejected Shipments – A long-term care facility will need to ship any rejected shipments of non-creditable HWPs to a new designated and authorized facility within 90 days of their return.

Reporting – There is no requirement to report the amounts of HWPs generated at a facility unless specifically requested by the EPA. Other than the initial notification, the only report required under the new rule is when the facility does not receive back a copy of a fully received manifest from the receiving facility in connection with a shipment.

Record keeping – A health care facility must keep a copy of each manifest, exception report, and hazardous waste determination test result and analysis for three years. All records must be readily available during an inspection.

Response to Spills – Spills of HWPs must be immediately contained and the cleanup materials managed themselves as HWPs.

Accepting Non-Creditable HWPs from an Off-Site Facility that is a VSQG – A facility may accept non-creditable HWPs from a VSQG, such as when a health care facility returns drugs back to a pharmacy, even though the receiving facility does not have a RCRA permit, if the receiving facility (i) is under the same control as the transferring facility or has a business relationship, (ii) is operating under Subpart P, (iii) manages the new wastes under Subpart P, and (iv) keeps records of the shipment for three years.


Management Standards for Potentially Creditable HWPs

As noted above, because the definition of a potentially creditable HWP requires that a pharmaceutical be undispensed, and the use of a third party long-term care pharmacy results in medication being dispensed to a resident by the pharmacy rather than the facility, most long-term care facilities will not be managing potentially creditable HWPs. However, for those facilities that maintain their own in-house long-term care pharmacy, the requirements of the final rule with respect to potentially creditable HWPs are relevant as the facility is likely to have undispensed prescription medications on hand that can qualify as potentially creditable HWPs that can be sent to a reverse distributor.

  • Accepting Potentially Creditable HWPs from an Off-Site Facility that is a VSQG – A facility may accept potentially creditable HWPs from a VSQG, such as when a care facility returns drugs back to a pharmacy, even though the receiving facility does not have a RCRA permit, if the receiving facility (i) is under the same control as the transferring facility or has a business relationship, (ii) is operating under Subpart P, (iii) manages the new wastes under Subpart P, and (iv) keeps records of the shipment for three years.
  • Only Potentially Creditable HWPs – A facility is prohibited from sending hazardous wastes other than potentially creditable HWPs to a reverse distributor.
  • Reporting – There is no requirement to report the amounts of HWPs generated at a facility unless specifically requested by EPA.
  • Recordkeeping – A facility that initiates a shipment of potentially creditable HWPs to a reverse distributor must retain for a period of three years paper or electronic records of (i) the confirmation of delivery, and (ii) shipping papers prepared in accordance with DOT regulations. All records must be readily available during an inspection.
  • Response to Spills – Spills of potentially creditable HWPs must be immediately contained and the cleanup materials managed as non-creditable HWPs.
  • Shipping – Unlike with respect to a non-creditable HWP, a manifest is not required for shipping potentially creditable HWPs to a reverse distributor. Nevertheless, the facility must comply with all applicable DOT regulations in 49 C.F.R. Parts 171 through 180 for any HWP that meets the definition of “hazardous material” in 49 C.F.R. Section 171.8. Also, the receiving reverse distributor must provide confirmation to the facility that it has received the shipment. If the facility has not received such confirmation within 35 calendar days from the date the potentially creditable HWPs were sent, the facility must contact the carrier and the reverse distributor promptly to report that the confirmation was not received and to determine the status of the potentially creditable HWPs.

Conditional Exemption for HWPs that are Controlled Substances:

The final rule includes a conditional exemption from RCRA requirements for HWPs that are listed on a schedule of controlled substances by the DEA. The conditional exemption will apply if the HWPs are collected, stored, transported, and disposed of in compliance with all applicable DEA regulations for controlled substances, and will be destroyed by a method that DEA has publicly deemed in writing to meet their non-retrievable standard of destruction or combusted at one of five types of combustion facilities.


Generally Applicable Provisions of Subpart P to all HWPs:

The following provisions apply to all health care facilities, regardless of whether the facilities are managing creditable or non-creditable HWPs or are required to comply with the other provisions of Subpart P.

  • Sewering Ban – All health care facilities covered by the rule are prohibited from discharging HWPs to a sewer system that passes through to a publicly-owned treatment works.
  • Empty Containers – Under the new regulations, certain stock, dispensing and unit-dose containers are considered “empty” and therefore not regulated as hazardous waste under RCRA, even if minor pharmaceutical residue remains, if they have been emptied using the practices commonly employed to remove materials from that type of container. This also applies to syringes provided that the contents have been removed by fully depressing the plunger into the patient, another delivery device such as an intravenous bag, or a hazardous waste collection container. Intravenous bags avoid RCRA regulation provided the pharmaceuticals inside have been fully administered to a patient. All other types of containers—whether partially or completely empty—are to be managed as non-creditable HWPs unless they meet the general RCRA empty test for non-acute hazardous wastes.

Over the Counter Nicotine Replacement Therapies:

Nicotine and salts are currently included in the hazardous waste listed code P075 . The new rule exempts FDA approved over the counter nicotine replacement therapies, specifically patches, gums, and lozenges, from waste code P075. The rule does not exempt e-cigarettes, nicotine-containing e-liquids or prescription nicotine replacement therapies because they are not regulated in the same way as the exempted methods. Nevertheless, any nicotine replacement therapy that has been used in the manner initially intended is not a “solid waste” under RCRA and therefore is not a “hazardous waste” either.


Effective Date; Authorized State RCRA Programs:

The final rule will become effective six months following publication in the Federal Register; however, many states operate their own hazardous waste program. Once authorized by EPA, state hazardous waste programs operate in lieu of the RCRA regulations, though authorized states are required to adopt new regulations that are more stringent than existing rules. Most provisions of the pharmaceutical waste final rule are more stringent than the current RCRA generator regulations. Accordingly, authorized state programs will be required to adopt those provisions such that the new rule will not take effect in any of those states until it has been adopted and the state regulations updated. In contrast, the ban against HWP disposal in a drain or a toilet will be effective in every state as soon as it is effective under Federal law because the sewering prohibition component of the new rule, also more stringent than existing requirements, was adopted under separate legal authority. States are not required to adopt the part of the rule exempting over-the-counter nicotine replacement therapies from the hazardous waste requirements because it is less stringent. Also, facilities should be aware that states may include more stringent requirements than those included in the final rule. As a result, facilities will need to monitor adoption and implementation efforts in those states very closely.


Conclusion:

There can be no doubt that EPA’s final rule will require health care facilities, particularly long-term care facilities other than assisted living facilities, to navigate the new regulatory framework provided in Subpart P, while still potentially being subject to many other RCRA-related provisions and to regulations from other Federal agencies including the DOT. Additionally, facilities in states that have their own authorized hazardous waste program will need to monitor their state agency to determine exactly which rules apply and when. With an effective date only six months following publication of the final rule in the Federal Register, no guarantees of education or compliance assistance from EPA other than three webinars scheduled for February and March, 2019, and steep fines for violations, facilities will be hard-pressed to come up to speed in time. Health care facilities are well advised to begin their efforts now to understand the requirements, draft and implement effective policies and procedures, develop a staff training program, and enter into such contractual relationships as may be necessary to ensure compliance.

Original Source

 

June 4, 2019

Household Hazardous Waste (HHW)

Filed under: Industry News — TWP Admin @ 12:01 am

EPA considers some leftover household products that can catch fire, react, or explode under certain circumstances, or that are corrosive or toxic as household hazardous waste. Products, such as paints, cleaners, oils, batteries, and pesticides can contain hazardous ingredients and require special care when you dispose of them.


Safe Management of HHW

To avoid the potential risks associated with household hazardous wastes, it is important that people always monitor the use, storage, and disposal of products with potentially hazardous substances in their homes. Improper disposal of HHW can include pouring them down the drain, on the ground, into storm sewers, or in some cases putting them out with the regular trash.

The dangers of such disposal methods might not be immediately obvious, but improper disposal of these wastes can pollute the environment and pose a threat to human health. Certain types of HHW have the potential to cause physical injury to sanitation workers, contaminate septic tanks or wastewater treatment systems if poured down drains or toilets. They can also present hazards to children and pets if left around the house.

Some quick tips for the safe handling of household hazardous wastes include:

Follow any instructions for use and storage provided on product labels carefully to prevent any accidents at home.

Be sure to read product labels for disposal directions to reduce the risk of products exploding, igniting, leaking, mixing with other chemicals, or posing other hazards on the way to a disposal facility.

Never store hazardous products in food containers; keep them in their original containers and never remove labels. Corroding containers, however, require special handling. Call your local hazardous materials official or fire department for instructions.

When leftovers remain, never mix HHW with other products. Incompatible products might react, ignite, or explode, and contaminated HHW might become unrecyclable.

Check with your local environmental, health or solid waste agency for more information on HHW management options in your area.

If your community doesn’t have a year-round collection system for HHW, see if there are any designated days in your area for collecting HHW at a central location to ensure safe management and disposal.

If your community has neither a permanent collection site nor a special collection day, you might be able to drop off certain products at local businesses for recycling or proper disposal. Some local garages, for example, may accept used motor oil for recycling. Check around.

Remember, even empty containers of HHW can pose hazards because of the residual chemicals that might remain so handle them with care also.


Safe Disposal and Recycling

Many communities have collection programs for HHW to reduce potential harm posed by these chemicals.

Search for “household hazardous waste collection” near your zip code in the Earth 911 database.

Contact your local environmental, heath, or solid waste agency to learn about permanent or periodic HHW collections near you.


Reducing HHW in Your Home

Consider reducing your purchase of products that contain hazardous ingredients. Learn about the use of alternative methods or products—without hazardous ingredients—for some common household needs. When shopping for items such as multipurpose household cleaners, toilet cleaners, laundry detergent, dish soap, dishwashing machine pods and gels, bug sprays and insect pest control, consider shopping for environmentally friendly, natural products or search online for simple recipes you can use to create your own.

Below are some ideas to get you started. Additional information is available from EPA’s Safer Choice program.

Hazardous Waste Source Reduction around the Home:

Drain Cleaner: Use a plunger or plumber’s snake.
Glass Cleaner: Mix one tablespoon of vinegar or lemon juice in one quart of water. Spray on and use newspaper to dry.
Furniture Polish: Mix one teaspoon of lemon juice in one pint of mineral or vegetable oil and wipe furniture.
Rug Deodorizer: Liberally sprinkle carpets with baking soda. Wait at least 15 minutes and vacuum. Repeat if necessary.
Silver Polish: Boil two to three inches of water in a shallow pan with one teaspoon of salt, one teaspoon of baking soda and a sheet of aluminum foil. Totally submerge silver and boil for two to three more minutes. Wipe away tarnish and repeat if necessary.

Mothballs: Use cedar chips, lavender flowers, rosemary, mints or white peppercorns.


Regulating HHW

While most hazardous wastes that are ignitable, reactive, corrosive or toxic in America are regulated in America under Subtitle C of the Resource Conservation and Recovery Act (RCRA), Congress developed an exclusion for household waste. Under this exclusion, found in Title 40 of the Code of Federal Regulations Part 261.4, wastes generated by normal household activities (e.g., routine house and yard maintenance) are excluded from the definition of hazardous waste. Specifically, wastes covered by the household hazardous waste exclusion must satisfy two criteria:

The waste must be generated by individuals on the premise of a temporary or permanent residence, and

The waste stream must be composed primarily of materials found in wastes generated by consumers in their homes.

Although household hazardous waste is excluded from Subtitle C of RCRA, it is regulated under Subtitle D of this law as a solid waste. In other words, household hazardous waste is regulated on the state and local level.


Additional Information for State and Community Programs

Household Hazardous Waste Management: A Manual for One-Day Collection Programs (78 pp, 2.1 MB, About PDF)

State regulatory requirements for generators may be more stringent than those in the federal program. Be sure to check your state’s policies.

Original Source: https://www.epa.gov/

 

May 28, 2019

What Is the Difference Between Hazardous Waste & Solid Waste?

Filed under: Industry News — TWP Admin @ 7:21 pm

 

Hazardous waste threatens human health or the environment if it is carelessly thrown away, dumped into the ground or handled improperly. According to the EPA, solid waste or municipal solid waste (MSW) is commonly known as trash or garbage. It refers to the overall garbage created by a community, including household waste, as well as the waste generated by businesses, schools and institutions.

Types of Waste

A hazardous waste may be in solid, semi-solid, liquid or gaseous form. According to the EPA, the hazardous waste can be classified into listed wastes (source-specific wastes, non-specific source wastes and unused chemical products), characteristic wastes (toxic wastes, ignitable wastes, reactive wastes and corrosive wastes) universal wastes (batteries, pesticides, mercury-containing equipment and bulbs) and mixed wastes.

Municipal solid waste consists of paper, yard waste, metals, food, glass, wood, plastic and miscellaneous materials.

Problems

Solid waste generation is escalating with the increasing population. Disposal of solid waste in landfills is detrimental to the environment, as it can pollute the surrounding air and water. Toxic gases such as methane and carbon dioxide are formed when the waste in landfills decomposes. People living near landfills are susceptible to lung cancer, bladder cancer and leukemia. Incineration of solid waste releases toxic air pollutants, such as dioxins, which are carcinogenic and may cause birth defects.

Nuclear waste is hazardous and can remain radioactive for long periods of time, thereby affecting the environment and human health. Improper hazardous waste disposal from industries causes health problems in nearby communities. The presence of cancer-causing metal arsenic and toxic metal toluene may cause memory loss, hearing loss and various other conditions.

Disposal

Disposal options for hazardous waste are landfills, incineration, land treatment units and injection wells. Other alternatives include recycling and reducing the use of hazardous waste.

Landfill is the most prevalent disposal option for solid waste. In addition, solid waste is also burned at extremely high temperatures to reduce the waste volume. Alternative techniques of disposing solid waste include recycling and composting.

Potential Uses

Hazardous waste containing metal particles and ash are sent to metal recovery facilities where metal can be recovered from them. According to Science Daily, a new technology involves the recovery of uranium from the ashes of radioactive garbage to be recycled back into nuclear fuel.

Recycling solid waste materials such as paper, plastic, glass, metal and rubber, transforms the old products into new ones by mechanical or chemical methods. Heat is generated during incineration of solid waste, which could be used to heat water. The steam thus produced could be used to drive turbines to generate electricity.

Regulation

The EPA has clear regulations on how to dispose hazardous and solid wastes.

Special precautions need to be taken to dispose hazardous waste both in solid and liquid forms. EPA mandates the combustion or incineration of hazardous waste when possible. For waste in liquid form, underground injection wells should be used.

For solid waste disposal, EPA has guidelines on how to design landfills, where to locate them and how to maintain them.

Original Source

May 21, 2019

Hazardous Waste

Filed under: Industry News — TWP Admin @ 12:01 am

Toxic Waste

Standards

This section highlights OSHA standards, preambles to final rules (background to final rules), Federal Register notices (rules, proposed rules, and notices), directives (instruction to OSHA staff), model training programs, and other federal and national consensus standards related to hazardous waste.


State Standards

There are twenty-eight OSHA-approved State Plans, operating state-wide occupational safety and health programs. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA’s and may have different or more stringent requirements.

OSHA

General Industry (29 CFR 1910)

  • 1910 Subpart E, Means of egress
    • 1910.38, Emergency action plans
  • 1910 Subpart H, Hazardous materials
    • 1910.120, Hazardous waste operations and emergency response
      • Appendix A, Personal protective equipment test methods
      • Appendix B, General description and discussion of the levels of protective gear
      • Appendix C, Compliance guidelines
      • Appendix D, References
      • Appendix E, Training curriculum guidelines (Non-mandatory)
  • 1910 Subpart I, Personal protective equipment
    • 1910.134, Respiratory protection
  • 1910 Subpart J, General environmental controls
    • 1910.141, Sanitation
    • 1910.146, Permit-required confined spaces
      • Appendix A, Permit-required confined spaces decision flow chart
      • Appendix B, Procedures for atmospheric testing
      • Appendix C, Examples of permit-required confined spaces programs
      • Appendix D, Confined space pre-entry check list
      • Appendix E, Sewer system entry
  • 1910 Subpart L, Fire protection
    • 1910.165, Employee alarm systems
  • 1910 Subpart Z, Toxic and hazardous substances
    • 1910.1200, Hazard communication

Construction Industry (29 CFR 1926)

  • 1926 Subpart D, Occupational health and environmental controls
    • 1926.65, Hazardous waste operations and emergency response
      • Appendix A, Personal protective equipment test methods
      • Appendix B, General description and discussion of the levels of protection and protective gear
      • Appendix C, Compliance guidelines
      • Appendix D, References
      • Appendix E, Training curriculum guidelines (Non-mandatory)

Preambles to Final Rules

  • Hazardous Waste Operations and Emergency Response

Federal Register Notices

  • Hazardous Waste Operations and Emergency Response. Final Rules 59:43268-43280, (August 22, 1994).

Directives

  • Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases (PDF). CPL 02-02-073, (August 27, 2007). Updates enforcement procedures for compliance officers who need to conduct inspections of emergency response operations. It defines additional terms and expands on training requirements for emergency responders and other groups such as skilled support personnel. This OSHA instruction revises CPL 02-02-059, issued April 24, 1998.
  • Technical Enforcement and Assistance Guidelines for Hazardous Waste Site and RCRA Corrective Action Clean-up Operations HAZWOPER 1910.120 (b)-(o) Directive. CPL 02-02-071, (November 5, 2003).
  • Compliance policy for emergency action plans and fire prevention plans. CPL 02-01-037 [CPL 2-1.037], (July 9, 2002).Clarifies several Regional Instructions regarding 29 CFR 1910.38. Change to OSHA Instruction CPL 2-2.59A, Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, Appendix F, page F-3, rescind citation policy of 29 CFR 1910.120(q)(1). Rescinds Clarifications of Interpretations and Citation Policy on 29 CFR 1910.38 and 1910.157 Standards.
  • Hazardous Waste Operations and Emergency Response; Final Rule and Corrections. CSP 01-01-024 [STP 2-1.154C], (June 10, 1991). Describes a federal program change to the regions and state designees.

Model Training Programs

  • Draft Model Training Program for Hazard Communication

Other Related Information

  • The Application of HAZWOPER to Worksite Response and Cleanup Activities

Other Federal

Note: These are NOT OSHA regulations. However, they do provide guidance from their originating organizations related to worker protection.

Environmental Protection Agency (EPA)

  • 40 CFR Part 311, Worker protection. Describes the applicability of OSHA’s HAZWOPER Standard, 29 CFR 1910.120, to state and local government employees.

National Consensus

Note: These are NOT OSHA regulations. However, they do provide guidance from their originating organizations related to worker protection.

American Society for Testing and Materials (ASTM)

  • D6235 – 04, Standard Practice for Expedited Site Characterization of Vadose Zone and Ground Water Contamination at Hazardous Waste Contaminated Sites.
  • D6498 – 99, Standard Guide for Household Hazardous Waste Training Outline for Household Hazardous Waste Collection Operations.

 

Original Source: https://www.osha.gov/

 

May 14, 2019

EPA – Hazardous Waste

Filed under: Industry News — TWP Admin @ 12:01 am

History

When EPA proposed regulations for managing hazardous waste under Subtitle C of Resource Conservation and Recovery Act (RCRA) on December 18, 1978 (43 FR 58946), the agency deferred hazardous waste requirements for six categories of waste—which EPA termed “special wastes”—until further study and assessment could be completed to determine their risk to human health and the environment. These wastes typically are generated in large volumes and, at the time, were believed to possess less risk to human health and the environment than the wastes being identified for regulation as hazardous waste.

On October 12, 1980, Congress enacted the Solid Waste Disposal Act Amendments of 1980 (Public Law 96-482), which included the Bentsen and Bevill Amendments (sections 3001(b)(2)(A) and 3001(b)(3)(A)) These new sections exempted “special wastes” from regulation under Subtitle C of RCRA until further study and assessment of risk could be performed. Specifically, the Bentsen Amendment (section 3001(b)(2)(A)) exempted drilling fluids, produced waters, and other wastes associated with the exploration, development, and production of crude oil or natural gas or geothermal energy. The Bevill Amendment (section 3001(b)(3)(A)) exempted fossil fuel combustion waste; waste from the extraction, beneficiation, and processing of ores and minerals (including phosphate rock and overburden from uranium ore mining); and cement kiln dust.

The Bevill and Bentsen Amendments also required EPA to complete full assessments of each exempted waste and submit a formal report to Congress on its findings. Section 8002 explicitly identified the requirements for each special waste study and established deadlines for submission of the final reports. After completion of each respective “Report to Congress”, EPA was then required to make a final regulatory determination within six months as to whether the special waste in question warranted regulation as a hazardous waste under Subtitle C of RCRA.

The EPA submitted Reports to Congress and issued final regulatory determinations for each of the special wastes. For more information on each of the special wastes and links to their regulatory timelines, see the next section.

 

Types of Special Wastes

Categories of special wastes include:

Cement Kiln Dust Waste

Cement kiln dust (CKD) is a fine-grained solid by-product generated during the cement manufacturing process and captured by the facility’s air pollution control system. Because much of the CKD is unreacted raw materials, it is often returned to the production process. CKD that is not returned to the system, typically due to the presence of undesired constituents such as alkali metals, is disposed of in landfills, or sold for beneficial use. Currently, CKD waste is generally excluded from the definition of hazardous waste under federal regulations.

 

Crude Oil and Natural Gas Waste

Certain wastes from the exploration and production of oil, natural gas, and geothermal energy are excluded from hazardous waste regulations under Subtitle C of RCRA. These wastes include those that have been brought to the surface during oil and gas exploration and production operations, and other wastes that have come into contact with the oil and gas production stream (e.g., materials used to process natural gas).

Learn more about the proper management of oil and gas exploration and production waste

View the Crude Oil and Natural Gas Waste Legislative and Regulatory Timeline

 

Fossil Fuel Combustion Waste

Fossil fuel combustion (FFC) wastes are the wastes produced from the burning of fossil fuels (i.e., coal, oil, natural gas). These wastes can include fly ash, bottom ash, boiler slag and particulates removed from flue gas. During its assessment of the regulatory status of FFC wastes, EPA divided the wastes into two categories:

Large-volume coal combustion wastes generated at electric utility and independent power producing facilities that are managed separately.

All remaining FFC wastes, including:

Large-volume coal combustion waste generated at electric utility and independent power producing facilities that are co-managed with certain other coal combustion wastes (referred to as “co-managed wastes”).

Coal combustion wastes generated at non-utilities.

Coal combustion wastes generated at facilities with fluidized bed combustion technology.

Petroleum coke combustion wastes.

Waste from the combustion of mixtures of coal and other fuels.

Waste from the combustion of oil.

Waste from the combustion of natural gas.

After studying these categories of wastes, EPA made two separate regulatory determinations (in 1993 and in 2000) to exclude large- volume coal combustion wastes and the remaining fossil fuel combustion wastes from hazardous waste regulation under Subtitle C of RCRA.

On April 17, 2015, EPA issued federal regulations establishing requirements for the safe disposal of residuals generated from the combustion of coal at electric utilities and independent power producers. These regulations establish technical requirements for CCR landfills and surface impoundments under Subtitle D of RCRA, the nation’s primary law for regulating solid waste. Read more about this rule that went into effect on October 19, 2015.

 

Mining and Mineral Processing Waste

Mining wastes include waste generated during the extraction, beneficiation, and processing of minerals. Most extraction and beneficiation wastes from hardrock mining (the mining of metallic ores and phosphate rock) and 20 specific mineral processing wastes (see side bar) have been excluded from federal hazardous waste regulations under Subtitle C of the RCRA:

 

Mineral Processing Wastes Covered by the Mining Waste Exclusion

 

Slag from primary copper processing
Slag from primary lead processing
Red and brown muds from bauxite refining
Phosphogypsum from phosphoric acid production
Slag from elemental phosphorous production
Gasifier ash from coal gasification
Process wastewater from coal gasification
Calcium sulfate wastewater treatment plant sludge from primary copper processing
Slag tailings from primary copper processing
Flurogypsum from hydrofluoric acid production
Process wastewater from hydrofluoric acid production
Air pollution control dust/sludge from iron blast furnaces
Iron blast furnace slag
Treated residue from roasting/leaching of chrome ore
Process wastewater from primary magnesium processing by the anhydrous process
Process wastewater from phosphoric acid production
Basic oxygen furnace and open hearth furnace air pollution control dust/sludge from carbon steel production
Basic oxygen furnace and open hearth furnace slag from carbon steel production
Chloride process waste solids from titanium tetrachloride production
Slag from primary zinc processing

 

Extraction is the first phase of hardrock mining which consists of the initial removal of ore from the earth. Beneficiation follows and is the initial attempt at liberating and concentrating the valuable mineral from the extracted ore. After the beneficiation step, the remaining material is often physically and chemically similar to the material (ore or mineral) that entered the operation, except that particle size has been reduced. Beneficiation operations include crushing; grinding; washing; dissolution; crystallization; filtration; sorting; sizing; drying; sintering; pelletizing; briquetting; calcining; roasting in preparation for leaching; gravity concentration; magnetic separation; electrostatic separation; flotation; ion exchange; solvent extraction; electrowinning; precipitation; amalgamation; and heap, dump, vat, tank, and in situ leaching. The extraction and beneficiation of minerals usually generates large quantities of waste.

Mineral processing operations generally follow beneficiation and include techniques that often change the chemical composition the physical structure of the ore or mineral. Examples of mineral processing techniques include smelting, electrolytic refining, and acid attack or digestion. Mineral processing waste streams typically bear little or no resemblance to the materials that entered the operation, producing product and waste streams that are not earthen in character. Twenty mineral processing wastes (see side bar) qualify for the exclusion from federal hazardous waste regulation. The remainder of mineral processing wastes are regulated under RCRA and subject to applicable regulations (e.g., land disposal restrictions.) For more information on the management of mineral processing wastes, visit EPA’s Office of Enforcement and Compliance Assurance Mineral Processing Wastes Web page.

Original Source: https://www.epa.gov

 

May 7, 2019

News Global waste market to reach $435B by 2023, report finds

Filed under: Industry News — TWP Admin @ 12:01 am

 

A new report by Allied Market Research forecasts the global waste management market to reach $435 billion by 2023, after being valued at $285 billion in 2016.

The report, Global Waste Management Market by Waste Type, and Service: Global Opportunity Analysis and Industry Forecast, 2017-2023, shows the municipal solid waste market may reach $222.8 billion by 2023, with a compound annual growth rate of 6.1% during the forecast period.

 

The report anticipates that the fastest growing service for the waste management market will be the disposal segment, which is expected to grow by 6.9% and is forecast to reach $230.7 billion by 2023.

Original Source

April 29, 2019

Household Hazardous Waste

Filed under: Industry News — TWP Admin @ 7:56 pm

Hazardous wastes are wastes or products that have the potential to harm humans or the environment, either now or in the future. There are many options to help you dispose of household hazardous wastes safely, protect the environment and keep your home safe. Recycling programs are available for some hazardous wastes.

Over the last two decades, there have been major changes to the way Australians manage their waste. Recycling has increased but so has the amount of waste we are generating, including the quantity of hazardous waste.

Household hazardous waste

The average Australian household stores many hazardous substances or products that contain harmful elements. It can be dangerous to dispose of hazardous wastes through regular rubbish collections. Examples of household hazardous waste include:

  • Solvent-based paints
  • Pesticides and other garden chemicals
  • Batteries (for example car, mobile phone or regular household batteries)
  • Motor oils (for example from cars or mowers)
  • Petrol and kerosene
  • Cleaning and polishing chemicals
  • Swimming pool or spa bath chemicals
  • Pharmaceuticals (all medicines)
  • Obsolete computer equipment
  • Thermometers, barometers, thermostats, fluorescent tubes and compact fluorescent globes (CFLs).

Handling and storage suggestions

To handle hazardous waste at home safely you should:

  • Keep the goods in their original containers if possible. If containers are leaking, use new containers but never use food containers like soft drink bottles.
  • Don’t mix chemicals when decanting a substance into a new storage container.
  • Make sure all labels, including warning labels and manufacturer’s instructions, remain intact on the packaging.
  • Store goods upright with lids secured tightly and out of the reach of young children.
  • Keep all ignition sources, such as matches, well away from the storage area.
  • Keep the storage area cool and dry.
  • Buy the smallest amount for your needs.

How to dispose of hazardous waste

Always store hazardous wastes properly while waiting for a suitable disposal method. There are various schemes in Victoria to recycle and dispose of household hazardous waste. For example:

  • Computers – materials used to make computer equipment contain valuable resources that can be re-used. They also contain hazardous materials that could pose a threat to the environment if they are not disposed of in a responsible manner. In Victoria, unwanted computer equipment – monitors, keyboards, laptops, CD and disc drives – can be recycled through the Byteback scheme. Some councils and equipment manufacturers also provide a disposal service for unwanted computers and equipment. Contact your local council or equipment manufacturer for details.
  • Mobile phones and phone batteries – some mobile phones and accessories contain heavy metals. Mobile phone retailers, some banks and other retail stores will accept used mobile phones for recycling as part of MobileMuster, the mobile phone industry recycling program.
  • Rechargeable batteries – batteries can be taken to Detox your home collections and some permanent sites or to one of a small number of Batteryback or company-owned retail locations.
  • Car batteries – these are collected at many council waste transfer stations, landfills and some major battery retailers. Contact your local council.
  • Gas cylinders (LPG) – these include cylinders used for BBQs, patio heaters, caravans, camping and lamps. These cylinders can be returned through swap programs provided by retailers for replacement, refilling or disposal. Charges may apply in some instances.
  • Used motor oils – these can be recycled. There are over 100 motor oil collection points at transfer stations across Victoria. You can return a maximum of 20 litres of motor oil per visit. Contact your local council or use the Oil directory.
  • Laser and printer inkjet cartridges – these can be taken to Australia Post and Harvey Norman outlets for recycling.
  • Fluorescent tubes and compact fluorescent globes (CFLs) – fluorescent lamps and other mercury products, including mercury spills, can be taken to Detox your home collections, selected retail outlets and some permanent sites.
  • Plastic shopping bags – supermarkets have collection bins for used plastic shopping bags for recycling. Plastic shopping bags create an ugly litter problem if not recycled or disposed of properly. If these bags get into waterways, they may be a threat to wildlife.
  • Unused medicines – take unused pharmaceuticals, including prescription and non-prescription drugs, to a pharmacist for disposal through the Return of Unwanted Medicines program. Always store unused pharmaceuticals out of reach of children before you dispose of them.

Contact details for these services are listed in the Where to get help section.

The Detox your Home household chemical disposal service

Sustainability Victoria operates a mobile Detox your home service, which collects household chemicals for safe, responsible disposal or recycling. This service is delivered in collaboration with local government.

The service moves around the State. Collection events are run on weekends. Items accepted for recycling and disposal at Detox Your Home mobile events are:

  • Empty aerosol cans
  • Insect spray
  • Floor-care products
  • Kitchen and bathroom cleaners
  • Ammonia based cleaners
  • Pharmaceuticals
  • Nail polish and remover
  • Fluorescent tubes
  • Batteries
  • Fuels
  • Gas cylinders
  • Paints
  • Fertiliser
  • Weed killer
  • Rat poison
  • Pool chemicals
  • Solvents and glues
  • Paint stripper
  • Engine oil
  • Coolant and antifreeze
  • Mobile phones
  • Fire extinguishers
  • Old car batteries
  • Car wax
  • Brake fluid
  • Transmission fluid
  • Car body filler.

Sustainability Victoria has also established a network of permanent drop-off centres at local transfer stations. These centres are available during transfer station operating times. These centres ONLY accept paint, motor oil, batteries, fluorescent tubes and, in most cases, gas cylinders.

Detox your Home does not accept:

  • Containers larger than 20 litres or 20 kilograms
  • Chemicals for uses other than household purposes
  • Chemicals used for farm, commercial or industrial purposes
  • Waste asbestos.

Disposing of industrial or farm chemicals

To dispose of industrial waste and asbestos:

  • Check the Yellow Pages for waste reduction and disposal services.
  • Go to the EPA website for a list of licensed companies that receive certain types of industrial waste.

What happens when you DON’T dispose of dangerous waste properly

You should never put hazardous household wastes into regular rubbish collections, tip it down the sink, toilet or gutters, or bury it in the ground. This is what can happen if you don’t use correct disposal methods:

  • Buried in the garden – dangerous chemicals and poison can leach into the surface or groundwater. This can affect the soil, plants and water for a long time.
  • Tipped down the sink – wastes may corrode the pipes or block stormwater drains and cause problems at water treatment plants.
  • Put into the regular garbage – this can put the health and safety of garbage collection workers at risk. It may also pollute waterways and drinking water if sent to normal landfills. Hazardous waste should only be stored in specially designed landfills.
  • Plastic shopping bags – these can create an ugly litter problem if not recycled or disposed of properly. If these bags get into waterways, they may be a threat to wildlife. Most supermarkets now collect plastic bags for recycling.
Illegal disposal, dumping or misuse of wastes is a serious offence and subject to large financial penalties.

 

 

April 23, 2019

Arizona Firefighters Critical After Explosion

Filed under: Industry News — TWP Admin @ 5:04 pm

Eight firefighters were injured Friday night in an explosion at an Arizona Public Service facility in Surprise. Four Peoria firefighters were the most seriously hurt, with three flown to Maricopa County Medical Center’s burn unit in Phoenix, said Michael Selmer, a Peoria Fire Department spokesman. One was in critical condition. The fourth was taken to a West Valley hospital.

In addition, four other firefighters for the city of Surprise were taken to a hospital for evaluation of less serious injuries, said Battalion Chief Julie Moore of the Surprise Fire Department.

The explosion occurred at the APS McMicken Energy Storage facility near Grand Avenue and Deer Valley Road in Surprise on Friday evening. The facility houses utility-sized batteries on the site used in the storage and distribution of solar energy, according to the APS website.

Read Full Story Here

January 31, 2019

RCRA/DOT Training

Filed under: Remediation — Kelly Sherwood @ 3:39 pm

Register Your Team Today!

October 31, 2018

Wayne County Michigan Household Hazardous Waste Event November 3, 2018

Filed under: Household Hazardous,Universal Waste — Tags: , , , — Kelly Sherwood @ 8:19 pm

WC-hhwc-taylor-11-3-2018

Attention Wayne County, MI residents!

Recycle your household hazardous waste!

Saturday, November 3, 2018

Please be sure to review the flyer for the list of accepted items and items NOT accepted, hours of service etc.

https://www.waynecounty.com/departments/environmental/land-resource-management.aspx

#HHW #Household #Hazardous #Waste #WayneCountyMI @WayneCountyMI #EWaste #Recycle #Recycling #ThinkGreen #ActGreen #LoveThePlanet #Lightbulbs #Batteries #MedicalWaste #Sharps #Mercury #AutoWaste

 

October 25, 2018

Register your Team –RCRA DOT Training Events

Dec 5th Livonia, MI RCRA/DOT Training

5 Seats Left!  Register your team today!  

RCRA Refresher Training is Annually Required!

RCRA/DOT Training

December 2018

ERG is now in open-enrollment for an all-inclusive training course.  This mandatory course will provide our clients with affordable training that (1) meets/exceeds regulatory requirements, (2) focuses specifically on issues of interest in industrial operations, and (3) provides an enjoyable, informative experience.  Our trainers are experts in their fields; have extensive experience working with industrial companies, and work hard to make their courses interesting.

We are offering the following class that is required of virtually all hazardous waste generators and many other companies as well.

The training course will include:

  • RCRA Hazardous Waste Management Training, which is required annually for employees of hazardous waste generators who work in any position related to hazardous waste management as defined by 40 CFR 262.34(a) and 40 CFR265.16.
  • DOT Hazardous Materials Training, which is required every three years for all hazmat employees, which are defined as “a person (including a self-employed person) who loads, unloads, or handles hazmat; tests, reconditions, repairs, modifies, marks, or otherwise represents packaging as qualified for use in the transportation of hazmat; prepares hazmat for transportation; is responsible for safety of transporting hazmat; or operates a vehicle used to transport hazmat” as defined by 49 CFR 172.700- 172.704.
  • The rates for the listed training courses are based on the number of attendees from each company.

Attendees (Per Company)                                                  One Day Rate

1-2                                                                                         $300.00

3+                                                                                          $250.0

If several people/group at your facility need training, ERG recommends on-site training that can be tailored to address specific operations, plans, and procedures at your facility.

ERG is ready and able to help you establish, improve and/or maintain a safe workplace and a successful regulatory compliance program.  If you are interested in other ERG EH&S services, including (but not limited to) on-site training courses, integrated contingency planning, permitting and environmental/safety/hazardous waste compliance audits, please contact us.

Register your team today.  Please review the course description.

2 Dates ~~ 2 Locations!

Livonia Michigan – Wednesday, December 5th

Bowling Green Ohio — Wednesday, December 12th

Register:

Training@ERGenvironmental.com or call  (855)459.0021

#Training #RCRA #DOT #EnvironmentalServices #Safety #SafetyTraining #Regulations #Compliance #GetCompliant #StayCompliant #AlwaysBePrepared #SafetyFirst #Osha

 

 

July 17, 2018

Wayne County MI Household Hazardous Waste Collection 7/21/18

Filed under: Household Hazardous,Universal Waste,Waste Management — Tags: , , , — Kelly Sherwood @ 6:38 pm

Wayne County Residents!

Household Hazardous Waste Collection Event

Saturday, July 21, 2018

Wayne County’s Department of Public Services hosts four Household Hazardous Waste Collections per year for County residents. The collections are designed to accept unwanted household chemicals for proper disposal and electronics for recycling from residents. Only household generated products from Wayne County residents are accepted. ERG Environmental Services will be hosting the event.  Please see the attached flyer for the important details.  Please review the accepted items & non-accepted items list as well as times of service and location.

Wayne County Michigan Residents

Household Hazardous Waste Collection Event 7-21-18

Detroit HHW 7-21-18

 

#HouseholdHazardousWaste #HHW #Detroit #Michigan #Livonia #Romulus #Hamtramck #GrossePointe #Trenton #Wayne #Dearborn #DearbornHgts #Westland #Canton #Taylor #Redford #Belleville #Inkster #Plymouth #Wyandotte #LincolnPark #GardenCity #SouthGate #FlatRock #VanBurenTwp #GrosseIle #Melvindale #WayneCounty @WayneCountyMI @DetroitMI @ERGenvServices

We look forward to serving you!

 

 

 

 

 

 

 

 

 

 

May 23, 2018

June Compliance Training Events! Enroll Now!

RCRA/DOT June 20th

HAZWOPER June 27th 

 rcraTraining flyer June 20 2018

HAZWOPERTraining flyer June 27 2018

 

Register Today!  Call 1.855.459.0021

Email: Training@ERGenvironmental.com

May 14, 2018

New Online Shop!

Filed under: Universal Waste,Waste Management — Tags: , , , , , , — Kelly Sherwood @ 9:34 pm

We’ve launched! 

You asked for it, ERG delivered! 

Our clients asked if we could expand our products and services.  ERG services a wide range of industry and segments of business, but they wanted the ability to shop online with ERG!

ERG Environmental Services is excited to announce our new online shop!

Visit our new online shop!      https://ergenvironmental.com/products

Shop By Category:

Aqueous Cleaning Systems

https://ergenvironmental.com/product-category/aqueous-cleaning-systems/

Drain Guards

https://ergenvironmental.com/product-category/drain-guards/

HazMat Spill Kits

https://ergenvironmental.com/product-category/haz-mat-spill-kit/

Loose Absorbents

https://ergenvironmental.com/product-category/loose-absorbents/

Oil Only Absorbents

https://ergenvironmental.com/product-category/oil-only-absorbents/

Oil Only Spill Kits

https://ergenvironmental.com/product-category/oil-only-spill-kit/

Universal “Waste To Energy” Absorbents

https://ergenvironmental.com/product-category/universal/

Solvent Recyclers

https://ergenvironmental.com/product-category/solvent-recycling-systems/

Universal Spill Kits

https://ergenvironmental.com/product-category/universal-spill-kit/

Download our catalog

https://ergenvironmental.com/download-absorbent-catalog/

Coming Soon!

Industrial Chemicals                       

Environmental Supplies

March 2, 2018

Compliance Training Classes RCRA/DOT & HAZWOPER

Filed under: Uncategorized — Kelly Sherwood @ 3:47 am

Are you compliant?  img

img

HAZWOPER

ERG is now in open-enrollment for a HAZWOPER 8-hour refresher training course.  This course will provide our clients with affordable training that (1) meets/exceeds regulatory requirements, (2) focuses specifically on issues of interest in industrial operations, and (3) provides an enjoyable, informative experience.  Our trainers are experts in their fields; have extensive experience working with industrial companies and work hard to make their courses interesting.

We are offering the following class that is required of virtually all hazardous waste generators and many other companies as well.

This course meets the requirements outlined in OSHA 29 CFR 1910.120 for 8 (eight) hours of annual refresher training for workers at hazardous waste sites. This course is designed for general site workers who remove hazardous waste or who are exposed or potentially exposed to hazardous substances or health hazards. The course may include topics such as topics pertaining to workplace hazards associated with Hazardous Waste Operations and Emergency Response (HAZWOPER). Topics include HAZWOPER regulations, site characterization, toxicology, hazard recognition, personal protective equipment, decontamination, medical surveillance, confined space entry and emergency procedures. Upon successful completion of the course, you will receive a certificate of completion.

Enrollment is open to those who have already completed the 40-hour or 24-hour HAZWOPER training.

Attendees (Per Company)            One Day Rate

1-2                                                                                         $150.00

3+                                                                                          $125.00

ERG is ready and able to help you establish, improve and/or maintain a safe workplace and a successful regulatory compliance program.  If you are interested in other ERG EH&S services, including (but not limited to) on-site training courses, integrated contingency planning, permitting and environmental/safety/hazardous waste compliance audits, please contact us.If several people/group at your facility need training, ERG recommends on-site training that can be tailored to address specific operations, plans, and procedures at your facility.

For Further Information: (855) 459-0021

 

RCRA / DOT

img

ERG is now in open-enrollment for an all-inclusive training course.  This mandatory course will provide our clients with affordable training that (1) meets/exceeds regulatory requirements, (2) focuses specifically on issues of interest in industrial operations, and (3) provides an enjoyable, informative experience.  Our trainers are experts in their fields; have extensive experience working with industrial companies and work hard to make their courses interesting.

We are offering the following class that is required of virtually all hazardous waste generators and many other companies as well.

The training course will include:

  • RCRA Hazardous Waste Management Training, which is required annually for employees of hazardous waste generators who work in any position related to hazardous waste management as defined by 40 CFR 262.34(a) and 40 CFR265.16.
  • DOT Hazardous Materials Training, which is required every three years for all hazmat employees, which are defined as “a person (including a self-employed person) who loads, unloads, or handles hazmat; tests, reconditions, repairs, modifies, marks, or otherwise represents packaging as qualified for use in the transportation of hazmat; prepares hazmat for transportation; is responsible for safety of transporting hazmat; or operates a vehicle used to transport hazmat” as defined by 49 CFR 172.700- 172.704.
  • The rates for the listed training courses are based on the number of attendees from each company.

Attendees (Per Company)            One Day Rate

1-2                                                                                         $300.00

3+                                                                                          $250.00

ERG is ready and able to help you establish, improve and/or maintain a safe workplace and a successful regulatory compliance program.  If you are interested in other ERG EH&S services, including (but not limited to) on-site training courses, integrated contingency planning, permitting and environmental/safety/hazardous waste compliance audits, please contact us.If several people/group at your facility need training, ERG recommends on-site training that can be tailored to address specific operations, plans, and procedures at your facility.

For Further Information: (855) 459-0021

Enroll Today:  Training@ERGenvironmental.com

 

 

 

January 5, 2018

Happy Holidays ! Thank You! HHW Season Wrap Up!

Happy Holidays! Happy New Year!

Thank You For Another Great HHW Season!

As the New Year unfolds, another successful household hazardous waste community collection season is wrapping up.  Since 2003, ERG has been conducting HHW collection events for municipalities and private organizations throughout Michigan and Ohio.   We maintain a large network of specialized team members experienced to perform these events, many events running simultaneously across multiple sites. We have a fantastic team!  We are efficient, safe, well organized and friendly.  It has been our pleasure to interact with residents from communities around the state while recycling their household hazardous waste.  ERG appreciates the participation of residents; this activity not only helps our business grow but also reduces the amount of toxic and hazardous materials going into the landfill. ERG maintains a full schedule of HHW events, corporate recycling events as well as permanent service locations and drop off locations in Livonia, MI, and Bowling Green, OH.

2017 HHW Waste Processed:

4,573,231 lbs total household hazardous waste processed in 2017.

This includes HHW events, permanent service locations, and drop-offs.

 

If you would like more information about dropping hhw off throughout the year, click the link.

https://ergenvironmental.com/services-listing/household-hazardous-waste-drop-off/

If you would like more information about ERG and our full spectrum of environmental services, call toll free 1.855.459.0021

From all of us at ERG, Happy Holidays and Happy New Year!

We look forward to serving your corporate recycling event, county, city or community events in 2018.

December 12, 2017

Lab Packs Chemical Packing: It’s that time of Year

Filed under: Chemical Packing,Compliance Support,Waste Management — Kelly Sherwood @ 9:13 pm

Lab Packs – It’s THAT time of Year!

The end of the year brings re-organizing and industrial cleaning projects.  Every industry that generates hazardous and non-hazardous waste cleans out storerooms, flam cabinets and the like to start the new year fresh.  Companies usually find small amounts of miscellaneous chemicals throughout their facility, sometimes unidentified.    ERG Environmental Services provides a Lab Pack service to properly handle these chemicals.

WHAT IS A LAB PACK/CHEMICAL PACKING?

Lab Packs are small containers of unwanted, expired, or out of date chemicals which are ready to be removed from a facility or lab.

These containers are then inventoried, segregated and packed together with other compatible chemicals in the same outer container.

WHY SHOULD LAB PACKS BE DONE BY TRAINED PROFESSIONALS?

Lab packing must follow specific rules, regulations, and exceptions as outlined by DOT and RCRA. Improper packaging or handling could lead to dangerous conditions, health hazards, or substantial fines.

WHY USE ERG ENVIRONMENTAL SERVICES FOR YOUR TURNKEY LAB PACK SERVICES?

  • ERG offers a unique blend of highly knowledgeable, experienced, and trained team members that work as a group to deliver the best services to our customers.
  • ERG will take inventories, segregate, stabilize, package, label, and transport the chemicals following all regulations and laws.
  • ERG offers an extensive network of vendors to meet your needs and offer the best pricing available. Our services include incineration, fuel blending, stabilization, WTE, neutralization, recycling and landfill options.
  • In addition to our lab pack services, ERG offers: recycling, remediation, sampling, industrial cleanings, and waste management services to meet all your needs.

    For Free Estimate:   https://ergenvironmental.com/services-listing/lab-pack-services/

    #LabPacks #ChemicalPacking #LabPack #EnvironmentalServices #HazardousWasteDisposal #HazardousWaste #Waste #ShipWaste #LabPacking #ShippingWaste #Regulations #WasteDisposal #disposal #Manifests #WasteManagement #ExpiredChemicals #UnusedChemicals #UnidentifiedChemicals #UnknownChemicals #Inventory #Collection #Compliant #Compliance #Industrial #environmental

    ABOUT ERG:

    ERG Environmental Services is a full-service environmental management company with facilities located in Ohio and Michigan. Our facilities serve the Indiana, Michigan, and Ohio states along with additional work as needed in adjoining states

    In Ohio ERG operates a RCRA Part B license universal waste recycling facility. This location specializes in recycling batteries mercury lamps, PCB liquids, e-waste, airbag recycling, and PCB transformers.

    Each commodity specialist vendor we contract with is R2 certified and has been reviewed and audited by our company to ensure the products are being handled and managed in accordance with all laws and regulations.

    Our knowledge of the waste industry and the ability to handle any waste your facility generates will minimize your organizations’ exposure to liabilities and leave you knowing you have made a good decision for your company and the environment.

    Call Us Today For A Free Estimate: 1.855.459.0021

     

     

October 3, 2017

October 7, 2017: 3 Household Hazardous Waste Recycling Collection Events

RRRASOC HHW Recycling Collection Event: Novi

 

Bloomfield Township HHW Recycling Event

Leelanau County Household Hazardous Waste Collection Day!

ERG has HHW drop off service times year round:

https://ergenvironmental.com/services-listing/household-hazardous-waste-drop-off/

#HouseholdHazardousWasteRecycling #Batteries #Lightbulbs #Recycling #chemicals #Aerosols #Gasoline #UsedOil #antifreeze #paint #ewaste #pesticides #herbicides #mercury #FireExtinguishers #Solvents #Kerosene #NailPolish #sharps #OilBasedPaints #Electronics #UsedMotorOil #Propane #TransFluid #thermometers #SmokeDetectors #Insecticide #Acid #CarBatteries #Fertilizer #BrakeFluid #Disinfectants #DrainCleaners #Recycle #KeepYourWorldClean #KeepYourWorldBeautfiul #NoviMichigan @NoviMI #BloomfieldTownshipMI @BloomfieldTwpMI #RRRASOC @RRRASOC #LeelanauCountyMI @LeelanauCountyMI @FarmingtonMI @FarmingtonHillsMI @MilfordMI @MilfordTwpMI @SouthLyonMI @SouthfieldMI @WalledLakeMI @WixomMI

September 28, 2017

3 Community Household Hazardous Waste Collection Events September 30, 2017

 

3 Community Household Hazardous

Waste Collection Events

September 30, 2017

 

White Lake Township

 

Macomb Township

Print/Download flyers-Use links

White Lake Township – GFLServices – Acceptable Unacceptable Wastes – 2017

Household Hazardous Waste Flyer_201702070910339202 Macomb Twp 9.30.17

Clinton County Household Hazardous Waste Collection Event Information:

https://www.clinton-county.org/315/Clean-Community-Events

Be sure to review your community flyer for specific details.

Each community has specific items on the accepted/unaccepted items lists.

#Recycle #Batteries #Lightbulbs #Chemicals #UsedOil #HouseholdWaste #Sharps #ThinkGreen #ActGreen #KeepYourCommunityClean #Ewaste #ElectronicsRecycling #Paint #PaintRecycling #Mercury #WasteDisposal #HazardousWaste #Aerosols #Solvents #Acids #FluorescentLamps #FireExtinguishers #SmokeDetectors #PCBBallast #AutoBatteries #Propane #Pesticides #Herbicides #SprayPaint #Gasoline #Antifreeze #WeAreERG #WeAreHereToHelp @ClintonCountyMI @MacombTownshipMI @WhiteLakeTownshipMI #EnvironmentalServices #AcommunityThatRecyclesTogetherStaysTogether

We look forward to serving you and your community.  ERG Environmental Services participates with communities around Michigan and Ohio with their recycling and household hazardous waste disposal efforts to keep their communities clean and beautiful.

If you would like to drop HHW off at our facility in Livonia, MI–Click this link for details and fees:

https://ergenvironmental.com/services-listing/household-hazardous-waste-drop-off/

More about our HHW program:

https://ergenvironmental.com/services-listing/household-hazardous-waste-disposal/

ERG is a highly respected leader in the HHW industry, providing 65+ municipal and corporate events each year.
ERG’s sorting, bulking, packaging, loading and transport personnel have many years of HHW management experience, providing confidence and assurance all waste is managed safely and correctly.

ERG’s record for a one (1) day collection events stands at 105 experienced individuals coming together to service almost 3,000 vehicles, including unloading, sorting, packaging and removing 400,000 pounds (that’s 200 tons!) of waste over a one (1) day collection event.

Our friendly personnel are exceptionally careful when removing waste from participant’s vehicles to protect against spills or damage.

Since 2003 ERG has conducted over 600 HHW collection events for local municipalities and private organizations. We maintain a large network of experienced personnel and inventories of equipment and supplies to seamlessly perform simultaneous events across multiple states on the same day. We are organized, safe, efficient and friendly to everyone involved, ensuring a relaxed and enjoyable event atmosphere.

ERG also provides HHS collection events for private companies, which may include participation for employees or also for local residents not otherwise serviced by their local municipality. Please contact ERG for more information about your company or organization sponsoring a HHW collection event.

September 21, 2017

5 Household Hazardous Waste Collection Events September 23rd

Filed under: Household Hazardous,Universal Waste — Tags: , , , — Kelly Sherwood @ 4:17 pm

Join your community to recycle household hazardous waste!

Check the flyer for the details for your community!

 

The Village of Franklin

Berrien County

Commerce Township

Mid Michigan Waste Authority/ Saginaw

Jackson County

https://ergenvironmental.com/services-listing/household-hazardous-waste-disposal/

ERG is a highly respected leader in the HHW industry, providing 65+ municipal and corporate events each year.
ERG’s sorting, bulking, packaging, loading and transport personnel have many years of HHW management experience, providing confidence and assurance all waste is managed safely and correctly.

ERG’s record for a one (1) day collection events stands at 105 experienced individuals coming together to service almost 3,000 vehicles, including unloading, sorting, packaging and removing 400,000 pounds (that’s 200 tons!) of waste over a one (1) day collection event.

Our friendly personnel are exceptionally careful when removing waste from participant’s vehicles to protect against spills or damage.

Since 2003 ERG has conducted over 600 HHW collection events for local municipalities and private organizations. We maintain a large network of experienced personnel and inventories of equipment and supplies to seamlessly perform simultaneous events across multiple states on the same day. We are organized, safe, efficient and friendly to everyone involved, ensuring a relaxed and enjoyable event atmosphere.

ERG also provides HHS collection events for private companies, which may include participation for employees or also for local residents not otherwise serviced by their local municipality. Please contact ERG for more information about your company or organization sponsoring a HHW collection event.

ERG also offers residential household hazardous waste drop off service.

Local residents may drop off “accepted materials” 

https://ergenvironmental.com/services-listing/household-hazardous-waste-drop-off/

#Recycle #Recycling #HHW #HouseholdHazardousWaste #Environmental #Saturday #chemicals #ewaste #sharps #ThinkGreen #ActGreen #KeepYourCommunityClean #EnvironmentalServices #IndustrialServices #Remediation #HazardousWaste #Batteries #Aerosols #Antifreeze #Gasoline #MedicalWaste #Herbicides #OilBasedPaint #Stain #Electronics #CellPhoneRecycling #Mercury #CarBatteries #UsedOil #Community #Solvents #Cleaners #acids #oil

September 19, 2017

ERG participates with S.T.E.M. in the Park

https://youtu.be/Wz0S0ln95Qo

 

Visit the website for more info at https://www.STEMinthepark.org

#Education #Science #Technology #Engineering #Mathematics #FamilyFun #GirlPower #GirlsInStem #STEM #STEMchat #YoungAchievers #MathChat #SciChat #BowlingGreenOH #BGU #EdChat #GetYourSTEMon

Press Release: ERG

Press Release

ERG Environmental Services

Household Hazardous Waste

Recycling Collection Event

 

www.leelanaunews HHW 7-15-17