Sunday, November 27, 2016

When Are The New EPA Hazardous Waste Generator Rules Effective?

The final Hazardous Waste Generators Improvement Rule was published in the Federal Register on November 28, 2016. The effective date for the rule is May 30, 2017.


Click here to review a summary of key new requirements for very small quantity generators (VSQG), small quantity generators (SQG) and large quantity generators (LQG).


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Friday, November 25, 2016

New Rule On Episodic Hazardous Waste Generation For VSQG & SQG Facilities

One of the persistent issues for hazardous waste generators has been when short term spikes in hazardous waste generation elevate facilities to a higher generator class, resulting the requirement to meet additional generator requirements. The Hazardous Waste Generator Improvements Rule addresses this issue by creating another type of waste generation – episodic hazardous waste generation. Because large quantity generators are not limited be monthly generator, these rule only affects VSQG and SQG generators.

Two types of episodic hazardous waste generation are created – planned and unplanned. Planned episodes, as the name suggests, can be planned ahead of time and include activities such has facility cleanups, obsolete inventory disposal, demolition projects, etc. Unplanned episodes include spills, fires, and other emergency incidents. Under the new rule, hazardous waste generated during these events will not count against monthly waste total and will not change generator status, if conditions are met.

Generators taking advantage of this option will be limited to one event per calendar; with opportunity to petition for one additional unplanned event in the same year.

For planned events the generator must:
  • notify agency at least 30 days prior,
  • identify start/end dates (60 day max),
  • have EPA ID #, and
  • ship within 60 days using a hazardous waste manifest.
For an unplanned event the generator must notify agency within 72 hr after incident. For either type of episode, the generator must label wastes “Episodic Hazardous Waste” and identify hazard characteristic (example, corrosive, flammable). Episodic waste totals are not added to monthly facility total; separate records must be kept of episodic wastes.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Thursday, November 24, 2016

EPA Hazardous Waste Generator Improvements Rule - What States Are Affected?

The Hazardous Waste Generator Improvements Rule is now signed and  published in the Federal Register on November 28, 2016. This leaves hazardous waste generators to sort out how this will affect them, and when.


Immediate Affect of the Hazardous Waste Generator Improvements Rule
The Generator Improvements Rule modified the Federal rules under RCRA and therefore has direct affect on hazardous waste generators located in States that have not been delegated RCRA authority (Iowa and Alaska) and some other areas, including Tribal lands. However, many States have incorporated portions of the RCRA rules by reference into their authorized programs – therefore, in these States revisions to Federal RCRA rules can have an immediate affect on State rules. This can significantly increase the population of hazardous waste generators that will be affected by the Hazardous Waste Generator Improvements Rule s ix months after publication in the FR - on May 30, 2017.

For generators located in States that have not incorporated generator requirements by reference, the impact of the rule revision will be uncertain. Rule changes will only become effective when States modify their own hazardous waste generator requires. To add to the uncertainty, States will only be required to modify their rules to incorporate portions of the Hazardous Waste Generator Improvements Rule that are MORE stringent than current rules. Other portions of the new EPA rules that add flexibility, are less stringent, or are incorporate clarifications to the rule would not need to be addressed by States to maintain their authorized programs under RCRA.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Friday, September 16, 2016

MPCA Rules On Puncturing and Venting Spent Aerosol Cans Changes January 1, 2017

In Minnesota, generators can puncture waste aerosols or gas cylinders that have been shown to be empty or that have been evaluated as non-hazardous, as long as any unavoidable liquid residuals are collected and properly managed.


However, hazardous waste aerosols and gas cylinders may no longer be punctured or vented in Minnesota after January 1, 2017, unless all hazardous waste propellant gases, product gases, and liquids are captured and properly disposed. MPCA does not allow charcoal and activated carbon filters to be used to capture hazardous waste propellants or gases for disposal.


The deliberate release of hazardous waste propellant or compressed gas to the atmosphere has been prohibited by the Minnesota Hazardous Waste Rules for many years, but MPCA chose not to enforce this prohibition. This allowed generators and collection sites to puncture hazardous waste aerosols and dispose of ignitable hazardous waste to the atmosphere. This practice is not allowed after 1/1/2017.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

New Rules Allow Handling Aerosol Cans As Universal Waste In Minnesota

A handful of States allow spent aerosol cans to be handled under State Universal Waste rules (email Caltha LLP if you would like to know if your State is included), although this waste stream is not a Federal universal waste under 40 CFR 273. The Minnesota Pollution Control Agency has finalized rules that will allow generators to manage aerosol cans as universal wastes.



Because documenting that an aerosol container or gas cylinder meets “RCRA Empty” standard can be impractical, MPCA allows generators to assume that an aerosol container is empty when both the following conditions are met:
· No liquid is felt or heard when the container is shaken by hand; and
· No gas or liquid is released when the spray/discharge valve is activated and the container rotated through all directions, as long as the valve is not observably or known to be clogged.



Hazardous waste aerosols and gas cylinders that are not empty can be managed under rules equivalent to universal wastes in Minnesota. Generators must accumulate hazardous waste aerosols and gas cylinders in closed containers labeled with one of these phrases:
· Universal Waste Aerosols/Gas Cylinders (whichever is appropriate)
· Waste Aerosols/Gas Cylinders
· Used Aerosols/Gas Cylinders



Accumulated hazardous waste aerosols/gas cylinders can be stored on-site for no more than one year and must be dated to verify how long they have been stored. Generators can ship hazardous waste aerosols/gas cylinders without a hazardous waste manifest to any site that has agreed to accept and properly manage them.





Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Saturday, August 27, 2016

DOT Certification Training - Initial and Triennial Training For Minnesota HazMat Employees

Caltha LLP offers training services to HazMat Employers who need to have initial or reoccurring triennial training for their designated HaMat employees. Training is tailored for each facility and is based on specific DOT hazardous materials actually shipped or handled. Training is provided at your location or can be provide "live" through a webinar format. Caltha provides training exams and issues training certifications.

In addition to training services, Caltha offers a wide range of compliance support services to operations that periodically ship and/or handle DOT regulated HazMat, including RCRA hazardous waste:
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

Safety Training In Minnesota - OSHA Compliance Training

Caltha LLP provides a range of OSHA required training programs for OSHA regulated operations located in Minnesota. This includes:
  • OSHA safety awareness training
  • Hazard communication training / HazCom training
  • GHS training
  • Incidental spill response training
  • PPE training
  • Lock out tag out LOTO training
Training is tailored for each facility and can be provided in-person or through "live" webinar sessions. To request more information, including cost information, contact Caltha LLP at info@calthacompany.com



Caltha LLP also provides:
  • Safety program auditing
  • OSHA compliance audits
  • PPE assessments
  • Safety program development
  • Written plans
  • Employee exposure assessment


 Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website