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Well, once again I'm running a little behind on my monthly newsletter. Between my business and other responsibilities it's been a hectic few weeks. One commitment that cost me an entire business day - but was well worth it - was the time I spent Tuesday, November 4th as an Election Judge in Free
 port, IL's Third Ward (Precincts 1 & 3). It was a great experience with some great people (who brought some great food!) I look forward to my next opportunity to serve in this fashion and recommend if for you as well. But, after the election we get down to business; and that's what I intend to do. There's still time in 2014 to schedule Onsite Training, I have Webinars and Seminars scheduled through 2014 and into 2015, and you can always contact me with questions. |
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Are you Ready for the e-Manifest?
Years in the making, another milestone passed, still more to go; but we are nearly to the point where a paper copy of the Uniform Hazardous Waste Manifest won't be necessary for the transportation of a hazardous waste. "Nearly". Read here to learn about the status of the e-Manifest.
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Categories of Solid Waste
If you generate a solid waste it will belong to one of the five categories identified by the USEPA in Table 1 of 40 CFR 261.2:
- Spent Material
- Sludge
- By-Product
- Commercial Chemical Product
- Scrap Metal
Read here for an explanation of these five categories of solid waste.
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Classifying a HazMat With More Than one Hazard
The classification of a hazardous material is more complex when it has more than one potential hazard. Read here how to classify a HazMat when more than one hazard class or division is present. More...
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Changes to the IMDG Code for 2015
 If you ship HazMat/Dangerous Goods internationally by vessel, you must ensure you are using the correct edition of the IMDG Code and are aware of changes to the Code for the 2014 Edition . |
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RCRA Conditional Exclusion from Hazardous Waste
The OMP Spring House Exclusion at 40 CFR 261.4(b)(17) applied only to a specific waste and it has since expired. However, you may be interested in learning more about this unique conditional exclusion and how you might get one to work for you in a similar fashion.
40 CFR 261.4(b)(17) - The OMP Spring House Exclusion from Hazardous Waste
You may be interested in viewing this and other presentations directly on SlideShare.
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Are State-Certified Labs Required for the Hazardous Waste Determination?
Let's all pitch in to build a nationwide list of the state environmental agencies and their requirement - or lack of a requirement - to use a state certified lab for the hazardous waste determination. Contact me to add your state to the database: State-certified labs for the hazardous waste determination. |
 Transportation of Dry Batteries - Special Provision 130 Special Provision 130 of the Hazardous Materials Table provides for the transportation of dry-cell alkaline batteries. More... |
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Status of the Solvent Wipes Exclusion in Your State 
What will your state do with about this conditional exclusion from RCRA regulation published by USEPA? Read this article to see if your state has taken a position. If you don't see anything for your state, ask me.
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The Transportation of Bakken Crude Oil and the Regulations of the PHMSA & FRA
 The transportation by rail of significant quantities of crude oil from the Bakken shale deposits has posed a serious safety and regulatory issue for the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Association (FRA) Refer to this database for up-to-date information regarding this topic.
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Product v. Waste
This is where compliance with RCRA begins. Quite simply: Products are not subject to RCRA, but wastes are. OK then, what does RCRA consider to be a waste?
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Counting Hazardous Waste
What's in. What's out. Read this short article for guidance on what you should consider when quantifying your hazardous waste generation. More...
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What's Coming Down the Pipeline?
Complying with the current regulations is enough of a challenge. You also must be aware of future regulations that may impact your operations. How? By becoming familiar with the announcements from the regulatory agencies (EPA, PHMSA, FAA, FRA, & FMCSA) in the Federal Register. I've recently expanded and improved the information I provide to better serve you. Please take a moment to look at the following:
And this one. Straight from the headlines: 
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40 CFR Part 264 v. Part 265
They're so similar, you'd be forgiven for confusing them with each other. However, EPA had a reason for creating them separately and understanding their reasoning will help with your overall understanding of the RCRA regulations. More...
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Upcoming Training Seminars in your area
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"I find that the harder I work, the more luck I seem to have."
- Thomas Jefferson
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Three hours and $189 to compliance!
Click on the link to learn more or to register for Web-Based Training. |
A Testimonial from
Seminar Training
"Very complete training. I will highly recommend it."
- Octavio Ortiz, Gannon and Scott, Inc, Phoenix, AZ
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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.
October 29-31 in Temecula, CA
November 13 in Monroe, WI
November 18-20 in Denver, CO
...and more to schedule.
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Archive of Past Newsletters
New to my Newsletter? Want to see what you've missed? 12 months worth of past issues are waiting for you.
Please feel free to include a link to them from your website or blog. More...
September 2014
August 2014
July 2014
June 2014
May 2014
April 2014
March 2014
January/February 2014
November/December 2013
October-13
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If you ship HazMat/Dangerous Goods by air (Domestic or International) you will require training every two years per IATA DGR 1.5.0.
If you ship Dangerous Goods internationally by vessel you must provide training every three years per IMDG Code 1.3.
I can provide this training!
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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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Free Training Provided by the PHMSA
The free workshops and seminars sponsored by PHMSA are done for 2014. Stay tuned for more great opportunities in 2015!
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