Daniels Training Services
January/February 2014

This volume has an article about a company owner who feels unfairly persecuted by the Connecticut DEEP.  His story shows what can happen to the best intentioned person if they run afoul of a regulatory agency.  I've also included some opportunities for you to help yourself and other EHS Professionals nationwide by aiding in the construction of databases of useful environmental regulatory information.  As always, it includes well-researched articles on a variety of issues related to the management of hazardous waste and the transportation of hazardous materials.

Recordkeeping:  Primary Exporters of Hazardous Waste & More

 
Learn here the specific recordkeeping requirements for primary exporters of hazardous waste, universal waste, and hazardous secondary materials.  More...

General Packaging Requirements of the HMR

Do you ship hazardous materials (including hazardous waste) from your facility?  Then you must read this short article about the general requirements for the type and condition of the packaging used.  These are in addition to any specific packaging requirements of the HMR.  More...

General Requirements for Hazardous Waste in Tanks at an LQG

 

A Large Quantity Generator of hazardous waste must comply with all of 40 CFR 265, Subpart J - Tank Systems, as applicable.  But along with all the specific requirements, an LQG must also comply with the general requirements of 40 CFR 265.194.  More...

State Specific Regulations

This Month:  Kansas!

Hazardous Waste Regulations in Kansas

 

Kansas has a unique off-shoot of the satellite accumulation container regulations all its own. Limited in its application, it may not be of use to you, but if you require the freedom of satellite accumulation containers in a restricted space, you may be interested in the Kansas Day Accumulation Container.

Options for the RCRA Contingency Plan

 

40 CFR 265.52(b) of the USEPA regulations provides options for a TSDF or a Large Quantity Generator of hazardous waste to incorporate their RCRA Contingency Plan into a pre-existing plan such as the SPCC or to create a whole new document known as the Integrated Contingency Plan or "One Plan".  More...

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.

Training Options

  1. Seminar Training (see my schedule above).
  2. Onsite Training
  3. Self-Guided Training
  4. Web-Based Training
  5. Hosted Training

Contact me for a free consultation of your training needs.

The Description of a DOT Special Permit or Exemption on a HazMat Shipping Paper 

 

The use of a Special Permit (aka: Exemption) when transporting a hazardous material requires the description of the Special Permit/Exemption identification number on the shipping paper.

 

   49 CFR 172.203(a) Additional Description for Special Permits and Exemptions

Check this out!

Funding Available for Training Through the Workforce Investment Act 

 

The Workforce Investment Act (WIA) provides funding in the form of grants to businesses and individuals who require training to enhance their job skills.  That includes the HazMat Employee and Hazardous Waste Personnel training I provide.  I encourage you to look into these sources - Federally provided but locally administered - to off-set your training costs.  I'll be glad to assist you in any way.  More...

What's Coming Down the Pipeline?

The Regulatory Pipeline

 

A conditional exclusion from regulation as hazardous waste for carbon dioxide?
Electronic manifests?  What else does USEPA have planned for RCRA regulations in the months ahead?  Read about them - and more - in the Federal Register.  More...

 

Free Training Provided by the PHMSA

 

The PHMSA of the USDOT regulates the transportation of hazardous materials in commerce.  They also provide free instructional training courses for the regulated industry to increase awareness of the Hazardous Material Regulations.  Please consider attending one of the following in 2014:

From the Archives:  USEPA Exclusion for Solvent Contaminated Wipes (Updated) 

 

Announced in July and published in the August 2013 Federal Register, the exclusion became effective January 31, 2014.  Read here to learn what you need to know to comply with the USEPA exclusion.

Are State-Certified Labs Required for the Hazardous Waste Determination?

Here is a great opportunity for all of us to work together to build a database of useful information. I've just begun to identify the state environmental agencies that require the use of a state-certified lab for the analysis of samples in the hazardous waste determination. Inform me of what you know about your state and I'll update my information.

 

815.821.1550

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Info@DanielsTraining.com

 

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"The whole problem with the world is that fools and fanatics are always so certain of themselves, and wiser people so full of doubts."

- Bertrand Russell
Three hours to compliance!
Click on the link to learn more or to register for Web-Based Training.
A Testimonial from
OnsiteTraining
 
"He was very knowledgeable and made the training specific for our facility. Fantastic presentation!"
 
- Alicia Hardacre, Tyler Pipe and Coupling in Marshfield, MO

 

Something New for Some Old Things! 
I am now archiving my old newsletters.  Feel free to browse past volumes for more helpful information.

November/December 2013
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
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.
Miscellaneous
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.
 
February 4-6 in Spring Hill, KS
February 7 in Marshfield, MO
February 11 in Rolling Meadows, IL
 
...and more to schedule.

Training Photo 3

One thing that separates our profession from others is that EHS professionals are not in competition with each other.  It is in our best interest to share non-proprietary information with our peers in order to improve safety, environmental protection, and regulatory compliance. Take advantage of the opportunities in this volume to share information in order to create tools that can be of use throughout the regulated community.

 

Daniel Stoehr
Daniels Training Services
815.821.1550