The Regulatory Toolbox

• Picking the right tool for the job (knowing which regulations apply) – the crucial distinction between hazardous materials, substances, and waste and the regulations applicable to each category
• The regulatory software store – tracking down the regulatory references, guidance documents, and clarifying letters you’ll need to do the job right
• Keeping your toolbox current – recommendations for keeping abreast of new or developing regulations
• Incorporating new tools – how new regulations are implemented in authorized states

Hazardous Waste Identification and Characterization

This section delves into the intricacies and complexities of hazardous waste identification and characterization. We’ll explore the basics of waste identification as well as more complex waste characterization issues that are all too frequently misunderstood or misinterpreted.

Hazardous Waste Recycling

RCRA includes a number of exclusions, exemptions, and, in some cases, reduced management requirements for hazardous wastes that are eligible for recycling. Unfortunately, the provisions for recycling are scattered throughout the regulations in no clear manner. We’ll learn where to find and how to apply all the different recycling regulations.

Used Oil Management

The proper management of used oil involves a number of issues. Used oil often has many of the same characteristics or components as hazardous waste but is not subject to the typical hazardous waste regulatory requirements if it is managed properly. The emphasis in this sections will be on the proper management of used oil to avoid regulation as hazardous waste.

Generator Requirements

The time-management, good-housekeeping, safety and security, accounting and training requirements that apply to the accumulation of hazardous waste; we’ll explore them all.

Treating Hazardous Waste

There’s always been some confusion about the extent to which generators can treat their hazardous waste. We’ll identify the conditions under which a permit would be required and the regulatory exclusions that will allow generators to treat their hazardous waste without a permit as long as certain conditions are met.

Shipping Hazardous Waste

The generator requirements are very strict and explicit about how long waste can be accumulated on-site; at some point it will have to be shipped off-site (unless it has been treated and rendered non-hazardous). This section will provide an introduction to the paperwork (manifesting), pre-transport requirements (packaging, labeling, marking, etc.), security, and training requirements applicable to anyone shipping hazardous waste off-site. These topics and others will be explored in much greater detail during the DOT Training and Certification part of the course (optional day four).

Release Reporting

Despite the best of intentions and careful management, accidents happen. This section addresses the critical reporting requirements associated with an unplanned/accidental release of hazardous waste.

The Land Disposal Restrictions

Few aspects of RCRA have created as much confusion or as many misconceptions as the LDRs. For years, one of the most common misconceptions was that the LDRs only applied to wastes that are destined for land disposal. The fact is that the LDRs and the associated paperwork requirements apply to virtually all hazardous waste, regardless of how or where it is to be treated or disposed of. Working through a series of exercises and discussions, participants will develop mastery over this complex topic.

Managing Contaminated Media and Debris

This section will provide an introduction to the many issues and challenges associated with the management of contaminated media and debris.

RCRA Update

The RCRA program is constantly evolving. In this section we’ll review the most recent changes to the regulatory program and new developments expected in the future.

DOT Training and Certification – Manifest Specific (optional, day four)

The Department of Transportation Regulations require training and certification for any hazardous material employee whose duties impact transportation safety. By definition, this requirement extends to anyone who prepares or simply signs a hazardous waste manifest. This section of the course covers the General Awareness, Function Specific, Safety, and Security training requirements applicable to waste manifesting (depending upon one’s duties, additional job-specific DOT training may be required). A comprehensive certification exam is offered at the end of the day. This training and certification must be updated every three years.

Why you should choose this course

The road to mastery is smoother and faster when one has a qualified guide. From experience, we all know that knowledge of subject matter is not enough; a skilled instructor must also know how to teach the material. With years of regulatory and practical field experience combined with a background in education and almost two decades developing and presenting RCRA classes, your instructor is uniquely qualified to guide you down the path to RCRA mastery.

All Attendees Receive a Free Copy of 40 CFR 260-265, 40 CFR 266-299, and 49 CFR 100-185!

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Topics covered include: 

Day One

• The Resource Conservation and Recovery Act - A Historical Overview
• The Regulatory Toolbox
• Hazardous Waste Identification - Part 1

Day Two

• Hazardous Waste Identification - Part 2; additional issues in waste identification
• Recycling Hazardous Waste
• Recycling Exercise
• Managing Used Oil
• Hazardous Waste Generator Requirements
• Hazardous Waste Generator Requirements; continued
• Treating Hazardous Waste and Other Permitting Issues

Day Three

• Reporting Releases of hazardous Waste/Substances
• The Land Disposal Restrictions (LDRs)
• Practical Considerations for Managing Hazardous Waste
• Shipping Hazardous Waste

Day Four

• DOT Training and Certification
• DOT Certification Exam