Ladder Safety - Environmental Compliance Alert

Ladder Safety - Environmental Compliance Alert

Avoiding RCRA Mistakes 1 Copyright 2014 Progressive Business Publications Violations are Costly Federal and state crackdowns Cradle-to-grave liability for wastes

Avoid mistakes Avoid fines 2 Copyright 2014 Progressive Business Publications Waste Determinations What type of waste is it? How do we know if its hazardous?

Conduct hazardous waste determination Is it a listed hazardous waste? Is it a characteristic hazardous waste? 3 Copyright 2014 Progressive Business Publications Waste Determination (Part 2) Use process knowledge

Check MSDS Test the waste 4 Copyright 2014 Progressive Business Publications Label and Mark Containers Label as hazardous waste Identify contents by:

Chemical name Hazardous characteristic Listed hazardous waste code DOT HazMat Placards 5 Copyright 2014 Progressive Business Publications Waste Accumulation Dates Critical because:

Shows we know RCRA rules Date triggers 90-day storage limit Lack of date triggers fines 6 Copyright 2014 Progressive Business Publications Tank Condition Say no to: Rusting drums and containers

Open containers Incompatible wastes Crowded storage areas 7 Copyright 2014 Progressive Business Publications Keep Containers Closed Containers must be closed at all times Know where the lids are

Do they fit the container? Replace lid immediately 8 Copyright 2014 Progressive Business Publications Are Buckets Our Enemy? Buckets are handy for small spills, but Theyre problems because they also need:

Covers Labels Accumulation Dates 9 Copyright 2014 Progressive Business Publications Routine Inspections Containment medium in good condition? Close all storm drains

Spill mats nearby? In good condition? 10 Copyright 2014 Progressive Business Publications Hazardous Waste Training Sign attendance logs (name, title) Proves youve received training Raises awareness

11 Copyright 2014 Progressive Business Publications Contingency Plan Where are spill containment materials? Are contact names current? Exits marked? Evacuation route marked? Who to call?

12 Copyright 2014 Progressive Business Publications Used Oil Used oil is also regulated under RCRA Containers must be labeled used oil, not waste oil

Keep containers closed Ship with RCRA manifest 13 Copyright 2014 Progressive Business Publications Proper RCRA Manifest Record of waste shipment Generator ID number Correct waste codes or DOT descriptions

LDR notifications to receiving facility 14 Copyright 2014 Progressive Business Publications Site Security Access to hazardous waste storage areas must be restricted Are they fenced and locked? Are warning signs

clearly posted? Is an attendant on duty? 15 Copyright 2014 Progressive Business Publications Summary We can avoid RCRA penalties

Hazardous waste determination Label containers Check storage areas Log all waste activities 16 Copyright 2014 Progressive Business Publications

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