Brittany Massaro leads New Pig’s marketing automation team. She works with marketers to create and disseminate information to help customers comply with regulations, select the appropriate products for their applications, stay safe and protect their environments.
angela zwisslersays:05/23/2017 at 2:29 pm
Great form; thanks! We are a CESQG, do we need to have a “communication system” present? We have several areas on our university campus where haz waste is generated, and there are telephones nearby. Is that adequate? phones in chemistry labs and maintenance shops. Thanks.
Brittanysays:08/18/2017 at 12:50 pm
In November 2016, the EPA revised some of the hazardous waste rules for all types of generators. Conditionally Exempt Small Quantity Generators (CESQGs) are now called Very Small Quantity Generators (VSQGs). Under the new rule, VSQGs still need to make hazardous waste determinations and do recordkeeping, but many of their other management requirements have been revised and collected into 40 CFR 264.14. This paragraph does not contain a provision for VSQGs to have communication systems.
However, there may be other reasons to have robust communication systems throughout your campus. For example, communication systems may be an important component of your campus Emergency Action Plan, required by OSHA [29 CFR 1910.38].
It is important for both the environmental and safety managers to review the specific hazards and risks in the chemistry labs, maintenance shops and other areas where hazardous wastes are generated on campus to ensure that there are adequate communication systems that can be used by anyone to report spills, fires or other emergencies. Depending upon the severity of the risks, phones may be sufficient – but it is best for the specific hazards and risks to be reviewed locally before that type of determination can be made.
Hope this info is helpful!
Gene Sanderssays:05/11/2019 at 8:42 pm
Don’t forget to meet the UN specification requirements, too. DOT rules apply to Hazardous Waste shipments.
Isabella Andersensays:07/02/2019 at 11:56 am
Excellent point! When a container of hazardous materials will be shipped, it needs to be properly marked and labeled according to DOT requirements. A properly marked container will include all required labels and markings, such as: hazard class symbols, orientation arrows (when appropriate), proper shipping name and the four-digit UN Identification number.
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