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Proposed Rule: EPA Adding Aerosol Cans to the Universal Waste Regulations

Posted by John Nicklin  |  Mar 21, 2018

EPA is proposing to add hazardous waste aerosol cans to those “universal wastes” regulated under title 40 of the Code of Federal Regulations (CFR), part 273. This change in the Resource Conservation and Recovery Act (RCRA) regulations, once finalized, will reduce regulatory costs of a wide variety of establishments generating and managing aerosol cans, including the retail sector, by providing a clear, practical system for handling discarded aerosol cans.

Final Rule: EPA Hazardous Waste Generator Improvements

Posted by John Nicklin  |  Mar 21, 2018

The EPA Administrator signed the final Hazardous Waste Generator Improvements Rule on October 28, 2016 and it was published in the Federal Register (FR) on November 28, 2016.

RX Waste, It’s Time to Reconsider Your Approach

Posted by John Nicklin  |  Jan 29, 2018

Current State

Today’s RX Waste services are very expensive solutions offered by regulated medical waste vendors which leverage their existing capital infrastructure at exceedingly high margins with the promise of convenient compliance. But the promise often falls short of both convenience and compliance. This leaves the customer with a complex matrix of multiple containers, conflicting…

Ebola Waste Preparedness

Posted by John Nicklin  |  Nov 07, 2017

A straight forward plan to deal with an issue that may seem new to many of you however this issue has been successfully addressed for decades. It’s all over the news, landfills that won’t accept ashes from incinerated waste, towns and states that won’t let waste be transported across their borders, special permits, Category A Packaging, warehouses full of drums and 6mil liners. STOP! Realize that all this public backlash and 3rd party noise is due to the fact that YOU do not have a plan. It’s really that simple.

4 Red Flags in an Environmental Management System Audit

Posted by John Nicklin  |  Oct 30, 2017

Is your environmental management system working for you or are you working for it?

An all-too-common approach to running an environmental management system (EMS) is a procedural, documentation-oriented approach where the mere existence of EMS procedures makes an organization falsely believe they have an effective program. In fact, this procedural-documentation approach often does little more that bog down the organization with little in the way of real outcomes.