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Greetings!
Well, November and December 2013 was a busy time for me. So busy that I am just getting my newsletter out for the last two months of the year. One reason for my busyness was a need to prepare a training presentation in December to meet the requirements of the USDOT and the International Air Transport Association (IATA) and the International Maritime Organization (IMO).
Look for more information on the international transportation of dangerous goods to be included in this newsletter. And, of course, please contact me for your IATA/IMO/USDOT training in 2014!
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Recordkeeping: The RCRA Contingency Plan
If an LQG you're required to maintain a contingency plan documenting the specific measures you must take in the event of an emergency. But what record must you keep of the contingency plan itself? And what of the documentation of arrangements agreed to by emergency responders? More...
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Significant Changes and Amendments to the 55th Edition (2014) of the IATA DGR
If you ship HazMat by air, whether domestically or internationally, you will likely have to comply with the Dangerous Goods Regulations (DGR) of the International Air Transport Association (IATA) in addition to those of the USDOT. Since the IATA DGR is updated every year, you will have to annually review the regulations for changes that may impact your compliance. This article summarizes the big changes from the 2013 regulations to those in effect for 2014. More... |
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What is the Operating Record?
It is referred to, but never explained, in the regulations pertaining to both large and small quantity generators of hazardous waste. Read here to learn what RCRA means by the Operating Record.
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State Specific Regulations
This Month: Ohio!
Until recently, the Ohio EPA required the hazardous waste report to be submitted annually. Now biennial, the report for 2013 is due March 1st of 2014. The Ohio EPA has some information for hazardous waste generators that must report. More...
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The Content of The Contingency Plan
40 CFR 265.52 details the required content of a contingency plan required of a Large Quantity Generator of hazardous waste. This isn't the end of it, however. Later articles in this series will address other requirements of 40 CFR 265, Subpart D that will need to be mentioned in the RCRA contingency plan. This article: 40 CFR 265.52 - Content of Contingency Plan.
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The RCRA Contingency Plan and Emergency Procedures FAQs
While I work my way through 40 CFR 265, Subpart D Contingency Plan and Emergency Procedures one section/article at a time, I've developed this list of FAQs. Read them and let me know if you have any questions I can answer and add to the list.
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Training Options
- Seminar Training (see my schedule above).
- Onsite Training
- Self-Guided Training
- Web-Based Training
- Hosted Training
Contact me for a free consultation of your training needs.
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 Check this out!
Communities, emergency responders, and other responsible parties should be interested in the updates USEPA recently made to its Incident Waste Assessment and Tonnage Estimator (I-WASTE). It is to be used as a tool during the clean-up of natural disasters, terrorist attacks, and chemical, biological, or radiological incidents. More...
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Exclusions from regulation as a Solid Waste or Hazardous Waste
The USEPA views the danger from trivalent chromium as significantly less than that from hexavalent chromium. As a result, most waste from the leather-working industry is excluded from regulation as a hazardous waste if it contains only trivalent chromium.
40 CFR 261.4(b)(6) - The RCRA Exclusion for Trivalent Chromium Waste
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Inspection Requirements (Pre-Trip & Post-Trip) for Commercial Motor Vehicles
A carrier of HazMat by motor vehicle is also subject to the regulations of the Federal Motor Carrier Safety administration (FMCSA). Their regulations require vehicle inspections, but it is important for a carrier to know just what kind of inspection is required, and when. More...
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What's Coming Down the Pipeline?
It's a good idea to be aware of the projected activities of the PHMSA and the USEPA that impact the transportation of hazardous materials and the management of hazardous waste.
A good way to do this is to review the Federal Register for Rules and Regulations, Proposed Rules, and Notices from these agencies. Take a look at what information was published in the FR for November 2013 and December 2013 that may impact your operations.
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Required Emergency Equipment on all Power Units
These regulations of the Federal Motor Carrier Safety Administration (FMCSA) apply to the operation of a Commercial Motor Vehicle (CMV), which will include most carriers of HazMat. Be sure you have this emergency equipment on your power units. More...
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 From the Archives: F-Listed Spent Organic Solvents
Common throughout industry, but commonly mis-applied. This article was written in January of 2012 but I received a question on this topic just recently and felt it a good time to reissue this article. More...
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Upcoming Training Seminars in your area
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"Your calling is found when your deep gladness meets the world's deep need."
- Fredrick Beuchner
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Three hours to compliance!
Click on the link to learn more or to register for Web-Based Training. |
A Testimonial from
Webinar Training
"This was a great introductory training class on DOT (PHMSA) regulations. There is ample time to ask questions so you can personalize the class as much as you need to."
- Scott Barker, Koch Nitrogen Co. in Beatrice, NE
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Something New for Some Old Things!
I am now archiving my old newsletters. Feel free to browse past volumes for more helpful information.
October-13
September-13
August-13
July-13
June-13
May-13
April-13, vol. 2
April-13, vol. 1
March-13, vol. 2
March-13, vol. 1
February-13, vol. 1,2
January-13, vol. 2
January-13, vol. 1
December-12, vol. 1,2
November-12, vol. 1
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Do you Need a Speaker for the Next Meeting of Your Organization?
I'm available to speak on a variety of regulatory topics at the next meeting of your professional organization.
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Violations of the Regulations
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in Your Area
Onsite Training has been keeping me very busy the past few months. There's no onsite training job too big, too small, or too remote for me to handle.
December 4 in Fayetteville, TN
December 11-12 in Sparks, NV
December 21 in Des Plaines, IL
February 4-6 in Spring Hill, KS
...and more to schedule.
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