Course Details

Hazardous Mixture Rule: How To Document, Manage And Dispose Of Waste Without Breaking Rules Or The Bank

Webinar: ID# 1023991
Recorded On-Demand
About This Course:
Managing hazardous waste can be a headache for organizations and they may resort to mixing hazardous and nonhazardous waste in an attempt to dispose of it. But if it is not done correctly, mixing waste could lead to fines and legal action from the EPA.

The Resource Conservation and Recovery Act (RCRA) articulates what is considered hazardous waste and outlines strict requirements for managing it, including what it can and cannot be mixed with during the disposal process. Since hazardous wastes are subject to much more complex and costly requirements than nonhazardous solid wastes, understanding your compliance obligations in this area is critical.

Ensuring compliance with this rule requires that you understand four key elements:
  • the key definitions involved such as characteristic waste, listed waste, ignitability, corrosively, reactivity, and toxicity
  • how to test and determine whether a given waste stream is hazardous or nonhazardous
  • how to document your testing and analysis properly to be successfully demonstrate to results to regulators
  • how to make sure that the waste stream remains consistent over time
These regulations can seem complicated but, if you follow a proven process, you can properly and cost-effectively identify and manage your waste and avoid expensive penalties.

Join us when our presenter David J. Scriven-Young will analyze the rule’s specific provisions and applications and address the mixture rule and its relationship to other regulations such as the land ban rule. In addition, you’ll learn how best to interpret and apply this mixture rule when managing used oil.

You’ll learn:
  • How to evaluate the requirements of the mixture rule to determine how it applies to your management of hazardous and nonhazardous waste
  • How to approach analysis and testing given a particular waste stream to determine whether it should be handled as a hazardous or nonhazardous waste and how often you need to retest
  • Strategies for ensuring that once waste streams are evaluated, the determination is correct going forward
  • How to document your analysis of a given waste stream so you can demonstrate to regulatory agencies whether it is hazardous or nonhazardous
  • Tips for managing “mixture rule” waste streams in the most cost-effective and compliant manner
  • How to determine and apply potential e exemptions when applying the mixture rule
  • Typical citations and violations associated with the mixture rule to avoid
About Your Presenter:

David J. Scriven-Young
Senior litigation council
Peckar & Abramson

David J. Scriven-Young is a senior counsel primarily in the Environmental Law, Construction, and Commercial Litigation Practices at Peckar & Abramson. Mr. Scriven-Young’s environmental expertise includes handling Superfund cases and wrongful death, personal injury, and property damage claims arising out of underground storage tank leaks, spills of chlorinated solvents, and other chemical releases. He has represented clients before the Environmental Protection Agency and state environmental agencies in enforcement matters. He has counseled clients on compliance and/or permitting issues under the Clean Air Act, Clean Water Act, Emergency Planning and Community Right-to-Know Act, Resource Conservation and Recovery Act, and Toxic Substances Control Act. He has also helped clients take advantage of state and federal audit policies. In addition, he has advised clients on mergers and acquisitions concerning environmental liability and permitting issues, and conducted due diligence and prepared representations and warranties for corporate transactions.

Mr. Scriven-Young is an Illinois Super Lawyer and was previously listed as a “Rising Star” from 2011 to 2013. He was also selected by DePaul University to a list of 14 successful alumni under 40 years old and profiled in DePaul Magazine. Mr. Scriven-Young’s bar association awards include the David C. Hilliard Award for Outstanding Committee Service from the CBA Young Lawyers Section and a Star of the Quarter Award from the ABA YLD. He has been listed in Who’s Who in America and Who’s Who in American Law.
Hazardous Mixture Rule: How To Document, Manage And Dispose Of Waste Without Breaking Rules Or The Bank
or via On-Demand
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