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Frequently Asked Questions

How OSHA Workplace Rules Affect My Hazardous Waste Plan?

OSHA is concerned with the protection of workers within the workplace, and companies whose workers are nearby hazardous waste need to ensure that they are taking the necessary steps to comply with OSHA’s industrial hygiene rules.

OSHA defines industrial hygiene as the “science and art devoted to the anticipation, recognition, evaluation, and control of those environmental factors or stresses arising in or from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort among workers or among the citizens of the community.” With this in mind, companies must ensure that their industrial waste plan takes all necessary steps to anticipate, mitigate, and control safety issues that may arise from the handling of hazardous waste products.

The best way to do this is by scheduling an industrial hygienist to evaluate your workspace. Out of all the compliance officers working for OSHA, over 40% of them are industrial hygienists. These industrial hygienists will conduct a worksite analysis for potential issues relating to air contaminants, chemical hazards, biological hazards, physical hazards, and more. It is better to be proactive about workplace safety than reactive.

Does State Environmental Regulations Mirror Federal Regulations?

Every state must comply with federal environmental regulations, but they are free to create their own regulations that are more strict than their federal counterparts. For example, the EPA publishes a list of hazardous waste on their website, but states may consider some substances hazardous even if they are not specifically mentioned on the EPA’s list. States may also require more frequent reporting for activities related to hazardous waste.

Although the EPA has regional offices that direct the activities of several states each, it is most often the state-level agencies that carry out the directives from the EPA. The EPA acts as a regulating body, but companies must comply with the more demanding state agencies.

What is the EPA E-Manifest?

As per the EPA, the EPA e-manifest is “a national system for tracking hazardous waste shipments electronically.” For wastes that must be manifested (according to federal and state laws), this can now be done electronically. In the future, the e-Manifest system will be mandatory, as it is a more efficient method of tracking shipments of hazardous waste. This tracking system may also combine with the manifest reporting under the Resource Conservation and Recovery Act (RCRA).
Although paper manifests are still accepted, as of June 30, 2018, companies can no longer use the old 6-copy manifest forms. They must instead use the new 5-copy manifest form
Within the e-Manifest system, the EPA will only be collecting manifests and continuation sheets related to the waste shipments that are federally- and state-required to have them. Other non-manifest documents will not be processed.
For more information and resources regarding the EPA’s new E-Manifest requirement, visit the EPA’s FAQ page or contact us at (866) 909-6483.

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