From: Ralph Stuart <Ralph.Stuart**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Waste storage question (DCM & Hexanes / EPA Waste Determination)
Date: Fri, 6 Aug 2021 11:38:10 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 216A2C73-F1F6-4D28-8DB7-1788F2010A05**At_Symbol_Here**

>> Failure to perform appropriate Hazardous Waste Determinations is the #1 current EPA RCRA violation (40 CFR 262.11).

Thanks for pointing this out, but I‰??m not sure that is useful information to share with lab workers when addressing their legitimate waste storage questions. I would also note that many EPA staff people disagree what "appropriate Hazardous Waste Determinations‰?? are in specific lab situations, not to mention the differences between state level regulators‰?? interpretations of this in 48 out of the 50 states.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


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