Daniels Training Services
February/March 2016

As you can tell from the date of this Newsletter, I'm a little behind.  My January Newsletter was merely late.  February's was non-existent.  And now I'm struggling just to get a combined March/February Newsletter out the door.  I've been busy providing training (a good thing), traveling to the CalCUPA Forum in Orange County, CA (learned a lot!), and then had a bunch of my articles disappear from my WordPress blog (don't you just love technology?)  I was able to recover most but some, I am told, are gone forever.  In this Newsletter you're seeing those that survived.  I hope you enjoy reading them.
Common Mistakes to Avoid on the Uniform Hazardous Waste Manifest

I intend to provide more direction in the future about completion of the Uniform Hazardous Waste Manifest.  But for now, try to avoid these common mistakes.  More...

Unknown Solid Waste The 2015 Definition of Solid Waste Rule

 

No new additions on this topic.  The article I wrote on non-waste determinations and solid waste variances was lost (see my introduction).  I'll either recover it or have to write a new one for the next Newsletter.

Conditional exclusions created or revised by the 2015 DSW:

New regulations created by the 2015 DSW for the above conditional exclusions:

 

Training Options

  1. Onsite Training
  2. Learning Management System (LMS)
  3. Webinar Training

Contact me for a free consultation of your training needs.

Quick Links

Brief explanations of complicated subjects

 

What is Hazardous Waste Personnel Training?

   

What is HazMat Employee Training?

  

Survey: What is your hazardous waste generator status?

  

Be sure you're using the correct edition of the IMDG Code

 

Survey: Must you register as a Shipper or Carrier of HazMat?

   

Survey: Do you need a Hazardous Materials Safety Permit?

What is a D003 Reactive Hazardous Waste?

Inspired by a question about aerosol cans at the 2016 CalCUPA Forum, I researched 40 CFR 261.23 and came up with a clear description of the a reactive hazardous wase.  Though, I must admit, clarity is elusive when describing the characteristic of Reactivity.  Read here to see if you agree with me.  More... 
Are State-Certified Labs Required for the Hazardous Waste Determination? - Recently Updated!

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.

I don't just write articles!

     View our videos on YouTube       View our photos on flickr     SlideShare

 

YouTube is something I am looking to use more.  Especially since I got a Galaxy Samsung 5.  Wow!  It's so easy to shoot videos and even do a little editing.  Now I have no excuse for not posting more videos of HazMat and Hazardous Waste issues.

 

What's Coming Down the Pipeline for February?

The Regulatory Pipeline

 

EPA added to its list of non-categorical fuels...but not much else from them or PHMSA, FAA, FRA, or FMCSA in February.  Of course, I'll need to hustle to review March and get that published.  But for now: Federal Register Publications for February 2016.

Selecting Your Hazardous Waste Transporter

            

As a generator of a hazardous waste, you are responsible for its management 'Cradle-to-Grave'.  That means that what happens to it during transportation - and final disposal - is your responsibility.  For that reason you must select your hazardous waste transporter with great care.  This article contains some tips to help you with that process.  More...

 

Package Orientation ___ - This Way Up - labels
IATA Requirements for the use of Package Orientation Arrows  

Similar but not exactly the same to those of the PHMSA/USDOT.  If you read my earlier article on the use of orientation arrows in the HMR, you should also read this one for some perspective.  More...

Authorized Packaging and the Hazardous Material Regulations

            

If you've ever thought that any packaging will do for HazMat.  And that authorized packaging required by 49 CFR 173.24(c) is just a myth created by Big Brother...take a look at this article and the video it contains of a cargo tank exploding!  More...

 

State-Specific Regulations.  This Month:  Texas! Texas
Though Texas regulations can be more strict than those of the EPA.  When it comes to waste management, the TCEQ has a very good program available to businesses who may only generate a waste once or infrequently.  It's known as the One-Time Waste Shipment Program.
I know this is a hold-over from the last Newsletter, but the one I wrote about Conditionally Exempt Small Quantity Universal Waste Generator status in California was lost.  Hopefully I'll retrieve it or rewrite it for the next Newsletter. Stay tuned.

Do you have a question?

Man with Question Mark

 

I receive a lot of questions.  Some come from past customers.  Some from - I hope! - future customers.  And some come from others who are in the business of transporting HazMat or managing hazardous waste and just need a little help.  Here's a sample of some of those questions with my answers:
UN3170 Aluminum Smelting By-products
HazMat on the Highway

 

815.821.1550

www.DanielsTraining.com 

Info@DanielsTraining.com

 

2016 CalCUPA Forum
2016 CalCUPA Forum

Upcoming Webinar Training
 
Want site-specific training for your employees but can't schedule Onsite Training?  Then consider site-specific Webinar Training scheduled at your convenience without all the challenges of travel.
 

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"Little Bird, in the world to come, you will not be asked 'Why were you not George?' or 'Why were you not Perkin?' but 'Why were you not Catherine?'" - Karen Cushman in Catherine Called Birdy

Three hours and $189 to compliance!

A Testimonial from
Webinar Training
 
"This training was presented well and Presenter was very knowledgeable of all the topics discussed. This is the 2nd time using Daniel for our training needs."
 
- Jeff Spencer with MAT Industries in Jackson, TN

in Your Area
 
Contact me now to schedule Onsite Training in 2016!
 
February 9 in Morris, IL
March 16 in Oakland, CA
March 23 in Benson, MN
March 31 in Painesville, OH
April 8 in Tampa, FL
April 21 in Monroe, WI
April 26 & 28 in Portland, OR
 
...and more to schedule.
Archive of Past Newsletters 
New to my Newsletter?  Want to see what you've missed?  Thanks to Constant Contact I now have an archive page for all of my past newsletters.
Please feel free to include a link to them from your website or blog.
Logo of the International Air Transport Association
If you ship HazMat/Dangerous Goods by air (Domestic or International) you will require training every two years per IATA DGR 1.5.0.

Logo of the International Maritime Organization 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!
Miscellaneous
Brief articles. Important information. Check this out.
Try Sonix Studio's free CSV Builder app for Hootsuite or Postcron.  It's a great tool for randomly selecting dates and times when using the bulk uploader.

Environmental Trade Fair & Conference Attend the TCEQ Environmental
 Trade Fair & Conference with me May 3 & 4

 

It's been a few years since I was able to attend this conference so I'm really looking forward to this one.  It's a great opportunity to learn about the Texas regulations of the TCEQ and to meet with hundreds of other EHS professionals.  Don't miss this opportunity to attend the 2016 TCEQ ETFC.

Training Question  If you generate a waste, the type and frequency of training you require varies by the type and amount of waste you generate - and the state(s) you do business.

The HazMat regulations of the USDOT/PHMSA are simpler:  Anyone involved in the transportation in commerce of a hazardous material must receive triennial training.

 

Not certain what training regulations apply to you?  Or how to get the training you and your employees need?  Contact me for a free consultation.

 

 

Daniel Stoehr

Daniels Training Services
815.821.1550