Universal Waste Aerosol Cans - Final Rule Summary
The Aerosol Cans Universal Waste Final Rule (UW Rule) incorporates aerosol cans containing hazardous waste that are generated and accumulated by various entities into the EPA’s Federal Universal Waste Rules found in Title 40 of the Code of Federal Regulations (40 CFR) Part 273. …
read moreThe US EPA’s View on - Legitimate Recycling of Hazardous Secondary Materials (HSM)
The Novesis white paper explains the U.S. EPA’s 2018 Definition of Solid Waste (DSW) Rule legitimacy factors and the Generator-Controlled Exclusion (GCE) and Transfer-Based Exclusion (TBE) that allow hazardous secondary materials to be recycled without being regulated as solid or hazardous waste, when specific conditions are met. …
read moreTCLP vs SPLP and the Proper Applications for Each
Questions frequently arise within the regulated community regarding the differences between the TCLP and SPLP laboratory tests, and the proper applications for each. TCLP is an abbreviation of Toxicity Characteristic Leaching Procedure and SPLP is an abbreviation of Synthetic Precipitation Leaching Procedure. Both procedures are laboratory tests used to analyze leachate. …
read moreThe US EPA’s View on Solvents Used As Ingredients
Explains EPA’s distinction between solvents used for their solvent properties (e.g., degreasing, cleaning) and the same chemicals used as reactants or ingredients in manufacturing. Relying on 50 FR 53315 and RCRA Online guidance, the paper shows that materials used as ingredients are not “spent solvents,” so the F001–F005 listings do not apply to those materials or to related process wastes when the ingredient concept is met. …
read moreSatellite Accumulation Area (SAA) Changes after HWGIR
Explains the Hazardous Waste Generator Improvements Rule (HWGIR) reorganization of satellite accumulation area requirements and seven substantive updates, including incompatible-waste rules under 40 CFR § 265.17(b), container-closure standards, the three-day excess-waste removal deadline, limits on where excess waste may be moved, acute hazardous waste quantity limits, mandatory “Hazardous Waste” marking plus a hazard identifier, and inclusion of all SAA locations in the facility Quick Reference Guide. …
read moreLarge Quantity Generator (LQG) Closure Requirements after the HWGIG (2019)
The Novesis white paper outlines the new, more stringent Large Quantity Generator (LQG) closure notification and performance requirements introduced by the Hazardous Waste Generator Improvements Rule (HWGIR) under 40 CFR §262.17(a)(8). …
read moreHazardous Waste Determinations after the HWGIR (2019)
The Novesis white paper explains how the Hazardous Waste Generator Improvements Rule (HWGIR) significantly expanded and codified the requirements in 40 CFR §262.11 for making accurate hazardous waste determinations, including stricter timing, knowledge/documentation standards, and record-keeping. …
read moreChanges to HW Contingency Plans after the HWGIR (2019)
The Novesis white paper details the HWGIR changes to RCRA preparedness, prevention, emergency procedures, and contingency plan requirements for Large and Small Quantity Generators, including the new Quick Reference Guide obligation for LQGs. …
read moreThe USEPA's “Continued Use” Policy Discussion
The Novesis white paper explains the U.S. EPA’s long-standing “continued use” policy, under which solvents, degreasers, and similar materials remain products (not solid or hazardous wastes) so long as they continue to be used as-is for their purpose without intermediate reclamation or processing. …
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