Questions?

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Do State Environmental Regulations Mirror Federal Regulations?

Individual states have the power to adopt hazardous waste management regulations that are more stringent than those of the federal government—and a number of them have done so. In fact, in matters of hazardous waste disposal, the face of the EPA is likely that of your state—not the federal government. Perhaps most significantly, individual states can differ from federal guidelines about what constitutes a hazardous waste per se, as well as how it should be handled. Examples might be an industry-specific waste in a state where that industry is common; or a unique military waste in a state with a large military facility; or where the federal government allows certain waste to be placed in landfills, some states do not. Also, different states might have different regulations about “lethality” or “severe toxicity” characteristics when determining if something is a hazardous waste; or they might add to the characteristics already in place per the EPA.

How do OSHA Workplace Rules Affect My Hazardous Waste Plan?

Proper hazardous waste management falls under the control of the EPA, but it’s also an integral part of industrial hygiene (occupational hygiene or workplace health), which is the central concern of OSHA.

According to OSHA, industrial hygiene “is the science of anticipating, recognizing, evaluating, and controlling workplace conditions that may cause workers’ injury or illness.” And your responsibility thereto is assessed by “industrial hygienists,” who use “environmental monitoring and analytical methods to detect the extent of worker exposure” and “employ engineering, work practice controls, and other methods to control potential health hazards.”

OSHA develops and enforces mandatory occupational health & safety requirements across more than six million U.S. workplaces. If you handle hazardous waste, your enterprise is certainly among them. So do you need access to an industrial hygienist in advance of a visit from OSHA?

Our advice is an absolute yes, because when you read OSHA materials related to workplace hygiene (let alone hazardous waste removing), the language and tone therein are emphatically regulatory—definitely not consultative. In sum, you want to discover violations (real or perceived) before OSHA does.

What is the EPA E-Manifest?

The EPA has launched a national system for tracking hazardous waste shipments electronically. This will be in lieu of the paper manifest that has heretofore done the job.

Per the EPA, the e-Manifest “will modernize the nation’s cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states.”

However— somewhat ominously—one of the other listed benefits is for increased effectiveness of compliance monitoring of waste shipments by regulators.

The e-Manifest will eventually be required in all states, whether a state is presently authorized to run the RCRA program or not; and currently-authorized states will be required to amend their rules to fit the program.

Affected materials include not only the usual federal RCRA hazardous wastes codes but also any so-called “state-only” hazardous wastes, e.g. “paint production waste” for Massachusetts.

You can still use a paper manifest, but it must be accompanied by a check for $20, while filing with an e-Manifest will only set you back four dollars. But bear in mind that the EPA intends to eliminate paper manifests completely within the next five years.

New technology can help you. The first of its kind—and the only comprehensive application for hazardous waste generators of all types and sizes—the PegEx Platform is a new purpose-engineered PC- and mobile-based tool for organizing your hazardous waste management within & across your marketing, sales, managerial, and reportorial data.

For more information and resources regarding the EPA’s new E-Manifest requirement, contact us at (866) 909-6483.

Do you provide services for households?

Generally speaking, Clean Management only provides services to commercial and industrial clients.  On occasion, we come across a household that has a significant quantity of regulated material, or a situation where hazardous material has spilled on the site.  If you have hazardous materials in your home and are looking for a place to dispose of those materials, please contact your local waste management authority to find out how to do so.