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Previous by Date: Subject: Re: [DCHAS-L] Evolution of chemical law and toxicology... Date: Wednesday, May 22, 2019 at 8:41:10 AM Author: MN Cooper <00000313ede34dce-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> |
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>I don't know of an easy to understand guidance available. The rules are not that difficult to follow.
While I do agree that there is no easy to understand guidance available, I'm not sure that your explanation of the example given suggests that the rules are not difficult to follow. And this logic of RCRA codes, permits and other requirements can vary from state to state, for example when specific states have established their own waste codes or practices to address issues of local concern.
> If you are having problems, I would encourage you to clarify your classifications with your regulator. Utilize the free resources that are available. I've worked in this field for awhile and honestly don't believe the regulators are there to 'burn you' and have found that if you have asked for clarifications and received responses in writing (even e-mail) the regulatory peers significantly recognize that when they come on-site for an inspection.
I would inject a note of caution on this comment. This has not been my consistent experience with RCRA regulators and I have seen significant disagreements arise between individual regulators as well as between state and federal interpretations of the same situation. While specific state regulators, and some state agencies as a whole, do try to work with waste generators in a partnership approach, this is not always the case. And if you are visited by a federal inspector, all bets are off.
Also, my experience with free advice is that it often turns out to be worth what you paid for it. I'd consider relying on waste disposal contractors or consultants who have significant experience in the state I'm working in. Their field staff have much more experience with the variety of regulations and chemicals than a generator is likely to have and they have a commercial interest in understanding regulators' expectations. For this reason, their services are not free, but they are worth it.
Good luck!
- Ralph
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859
ralph.stuart**At_Symbol_Here**keene.edu
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