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Pollution Prevention and
Hazardous Waste Training:
In-Briefing
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 1
The Team’s Background...
Developed the pollution prevention
protocol for National Park Service.
Conducted over 30 assessments in 4
states.
Covered millions of acres and thousands
of employees.
Developed computer-based tools to
In-Briefing assist agencies in green purchasing.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 2
A Program To Assist You
Forest Service Rocky
Mountain Region technical
assistance, training, and tools
available.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 3
The Forest Service Protocol...
On-site visit, training, environmental
references, pollution prevention
assessment, and environmental
compliance assistance.
A follow-up report of findings and
recommendations for each surveyed
forest/district.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 4
Today’s Survey Visit...
Begins with the In-Briefing and training.
Followed by “roundtable” dialogue and
information exchange.
Includes visits to selected areas of
potential environmental concern.
Ends with the Out-Briefing
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 5
Our Team’s Approach...
We will use checklists and “fill-in-the-
blank” data collection forms.
We may take photographs to help
construct the final report.
We will talk with selected management
personnel and workers.
We will look in buildings, boneyards,
In-Briefing cabinets, closets, lockers, and other
USDA Forest Service
Rocky Mountain Region places for hazardous products.
Summer 1999
MES-FSCO-990524A
Slide 6
Searching for “Trouble”
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 7
Searching for “Trouble”
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 8
Environmental Compliance Protocol
Primary focus will be hazardous waste
and hazardous products.
Compliance improvements will be
offered for deficient areas.
Observed compliance deficiencies will
be recorded in the final report.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 9
Your Participation is Critical
We are here to assist you in improving
compliance, increase worker and
facility safety, and identify pollution
prevention opportunities.
Tell us your environmental concerns.
This is your forest/district, so take
advantage of this dedicated effort.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 10
Forest Service:
Environmental Tool Kit
The Environmental Tool Kit for the USDA Forest
Service identifies 15 common waste streams and
functions with pollution prevention and
compliance recommendations. In addition, it
addresses 11 important
environmental laws.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 11
Forest Service:
Resource Manual
The Environmental Resource Manual for the
USDA Forest Service includes environmental
contacts, vendors and service providers, and
special reviews of hazardous waste management.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 12
Forest Service: Out-Briefing
The Environmental Survey Visit Out-Briefing for
the USDA Forest Service contains a summary of
the findings of the survey visit with specific
recommendations.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 13
Critical Background
Hazardous materials and
hazardous products: What
are they and who cares.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 14
What is a Hazardous Product?
A hazardous product is one that can be
dangerous to humans and the
environment if it is not handled correctly.
Special federal and state laws have
been established to protect workers and
the environment.
You may not see, smell, or feel the
In-Briefing
offending chemical(s) if you are
USDA Forest Service
Rocky Mountain Region
exposed.
Summer 1999
MES-FSCO-990524A
Slide 15
How Is a Product Hazardous?
A product could be hazardous because
of its chemical composition.
It might be hazardous because it has a
low flash point.
There are products that are hazardous
because they are acids or bases (as
indicated by their pH).
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 16
How Can You Be Injured?
A human can be exposed through
physical contact with the skin, breathing
the air, or ingested through the mouth.
Affects to humans can be varied, from
damage to the nervous system, lungs,
liver, heart, and blood.
Some affects are known immediately,
In-Briefing
others may take years before they are
USDA Forest Service
Rocky Mountain Region
detected.
Summer 1999
MES-FSCO-990524A
Slide 17
Who is Responsible?
The first level of protection is YOU!
Know what you are dealing with and
what is in the area around you.
You can quickly discover the level of
danger by reading the Material Safety
Data Sheets (MSDSs), area signs, and
In-Briefing
container labels.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 18
What About the Forest/District?
Every organization is REQUIRED to
provide information to employees on
every hazardous product they may come
in contact with.
These requirements are fulfilled through
MSDSs, storage requirements, labeling,
In-Briefing
product control, and training.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 19
OSHA Hazard Communication
The federal government requires
organizations to protect their employees
through a Hazard Communication
Program.
Annual training must be provided.
MSDSs of hazardous products must be
quickly available to all workers.
In-Briefing Lists of hazardous products must be
USDA Forest Service
Rocky Mountain Region developed.
Summer 1999
MES-FSCO-990524A
Slide 20
Personnel and Facility Safety
Flammable cabinets, secured lockers,
and proper containers must be used.
All containers, large and small, must be
properly labeled.
Special storage areas must be marked.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 21
Personnel Protection
The forest/district must provide personal
protection equipment (PPE) to anyone
that must work with hazardous products.
PPE could be gloves or eye protection,
breathing apparatus, or full body suits.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 22
What About Hazardous Waste?
When a hazardous product has
exceeded its manufacturer specified
shelf-life, it becomes a hazardous waste.
When a hazardous product is or has
been used, its by-products may be
hazardous waste.
If the product is hazardous, the container
In-Briefing
must also be treated as containing
USDA Forest Service
Rocky Mountain Region
residual hazardous product.
Summer 1999
MES-FSCO-990524A
Slide 23
Should You Care?
YES. Again, federal and state laws
REQUIRE the forest/district to KNOW if
a waste is hazardous.
If a waste is hazardous, it MUST be
handled, stored, managed, and disposed
of in a prescribed manner.
This is a facility responsibility.
In-Briefing Large fines and civil legal action could
USDA Forest Service
Rocky Mountain Region result if not properly managed.
Summer 1999
MES-FSCO-990524A
Slide 24
How Do You Know its Hazardous?
First, it is the responsibility of the
forest/district to determine if any waste
they generate is hazardous.
Making that decision can be from prior
knowledge of what the product is/was,
or from laboratory analysis.
Use EPA information to assist your
In-Briefing
determination.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 25
EPA Criteria Should Be Used
EPA defines a waste to be hazardous IF
it meets one or more of their criteria:
A flash point equal to or less than 140 degrees
Fahrenheit (F).
A pH less than 2 or greater then 12.5
It is unstable, or reactive
It contains “toxic” chemicals
It contains one or more of several hundred
chemicals that are “listed” by EPA
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 26
So What If It Is Hazardous?
If a waste has been determined to be
hazardous by the forest/district...
It must be labeled properly and stored in an
acceptable container
Stored in a properly prepared secure area and
frequently inspected
Shipped to a permitted disposal facility using a
permitted transporter
With all records of the waste being kept for
In-Briefing many years
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 27
If You Are A Generator...
Just generating hazardous waste places
an immediate requirement on you and
your forest/district. You must...
Have a special storage area, making sure that
labeling and signage is proper, and records are
maintained
Store, handle, ship, and dispose of the waste
in accordance with the law
Obtain an EPA Hazardous Identification (ID)
In-Briefing Number against which everything is tracked
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 28
Varying Levels of Requirements
There are increasingly more restrictive
and costly requirements depending on
the “generator” size:
Conditionally Exempt Small Quantity
Generator (CESQG)
Small Quantity Generator (SQG)
Large Quantity Generator (LQG)
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 29
Some Key Documents
There are some key documents you may
want to obtain...
EPA’s “Title III List of Lists”.
“NIOSH Pocket Guide to Chemical Hazards”.
Notification of Regulated Waste Activity (EPA)
“Generator Requirements of the Colorado
Hazardous Waste Regulations”.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 30
Some Important Contacts
If you have any questions regarding
employee protection, contact your unit
safety officer.
If you have any questions regarding
hazardous waste, contact your unit
hazardous waste coordinator, or:
Robert C. Steckley, FS Rocky Mountain
In-Briefing Regional Office: (303) 275-5173
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 31
Minimizing Compliance
What is pollution prevention
and how can it help reduce
your environmental
compliance exposure,
improve worker and facility
safety, and reduce operating
In-Briefing
USDA Forest Service
cost.
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 32
Pollution Prevention Beginning
“Environmental Programs that focus on the end of
the pipe or the top of the stack, or cleaning up
after the damage is done, are no longer adequate.
We need new policies, technologies, and
processes that prevent or minimize pollution – that
stop it from being created in the first place.”
President George Bush
October 1990
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 33
What is Pollution Prevention?
Using source reduction techniques...
Reduce or eliminate hazardous waste
Reduce or eliminate hazardous air pollutants
Reduce or eliminate hazardous water
pollutants
Conserve water
Conserve energy
Conserve other natural resources
In-Briefing Important Point!
USDA Forest Service
Eliminate waste before it is generated,
Rocky Mountain Region
Summer 1999 not after. Control technologies are not P2!
MES-FSCO-990524A
Slide 34
What is Source Reduction?
The U.S. Environmental Protection
Agency has defined Source Reduction
as…
Improved “housekeeping”
Material substitution
Process changes
Product changes
Important Point!
In-Briefing Only certain approaches qualify as
USDA Forest Service pollution prevention.
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 35
Pollution Prevention is Also...
Multi-media, meaning that it is equally
concerned with:
Air, water, and land
Do not lessen the burden in one media at the
expense of another
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 36
What is Housekeeping?
Housekeeping is the simplest and most
effective of all changes, and includes:
Keeping lids tight on volatile liquids
Buying only what you need
Keeping equipment in good repair
Stop leaks, drips, and spills
Segregate waste
1+1=2
These changes are
In-Briefing inexpensive and lasting
USDA Forest Service
Rocky Mountain Region changes
Summer 1999
MES-FSCO-990524A
Slide 37
Making Housekeeping Changes
These are changes that everyone can
make on their own:
Most are just common sense ideas
Individual workers often come up with the best
changes
Usually incorporated into work daily habits
In-Briefing 1+1=2
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 38
Product Substitution
These can be the most effective changes
a forest/district can make:
Replace hazardous products with “green”
products
Replace oil-based paints with
Latex paints and eliminate
Hazardous waste and air
pollutants
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 39
Avoiding Hazardous Products
Always insist on seeing the Materials
Safety Data Sheet (MSDS) before
making and acquisition decision:
Avoid hazardous products whenever possible
Never accept samples that are hazardous
Don’t let researchers or contractors bring
hazardous products into the forest/district
Always obtain the right and latest MSDS on
every product
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 40
Process Changes
This is where a forest/district can make
the greatest, most sweeping impacts:
Look at a function to see if it is really needed
Out-source tasks that are not critical
Consolidate activities to minimize resources
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 41
Process Change Example
Out-source your automotive
maintenance to a local
service provider and avoid the liability
Automotive
Maintenance in
Forests/Districts
In-Briefing
USDA Forest Service
Rocky Mountain Region Can Generate Hazardous Waste
Summer 1999
MES-FSCO-990524A
Slide 42
What About “Recycling”?
Pickup Service
Central Processing
Center
Replace With
Recycled Solvent
Service Provider
Possible regulatory issues Parts Cleaner
In-Briefing and probable hazardous
USDA Forest Service
Rocky Mountain Region waste air pollutants
Summer 1999
MES-FSCO-990524A
Slide 43
Can Recycling Work?
Yes, and it can be very effective:
It must be an “in-line” recycling technology
Often found in degreasing and paint cleaning
operations
Primarily used to extend the useful life of
cleaning solvent
Typically found in solvent, antifreeze, and
Freon® recycling units
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 44
Making P2 Work
Why is pollution prevention
important to forest and district
operations?
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 45
The Forest “Squeeze”
Disposal Costs
Executive Orders
Compliance Costs
National Forests
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999 “Trust” Responsibility
MES-FSCO-990524A
Slide 46
The Rising Cost of Disposal
In the 1970s, hazardous waste
disposal costs were $10-15 per metric
ton.
In the 1980s, it rose to $240 with
incineration costs ranging from $400-
1200.
In the 1990s, it is now running up to
In-Briefing
$2000 with incineration up to $2100.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 47
Management Commitment
Senior management commitment is
essential!
A Forest policy is critical.
Available personnel and financial
resources are a must.
Forest goals translate into focused
results.
Important Point!
In-Briefing Management actions are the most telling
USDA Forest Service
Rocky Mountain Region Indicator of organizational response!
Summer 1999
MES-FSCO-990524A
Slide 48
Technology Limited?
No. Pollution Prevention is no longer
limited by technology. Thousands of
products are available with…
Well researched health and safety issues
Supporting documentation and training
Competitive pricing
Multiple sources
Quick delivery
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 49
Pollution Prevention...
Is not just another activity, it...
Is integral to environmental protection
Is inseparable from environmental compliance
Is integral to all functions and operations
Involves employees at all levels
Usually reduces operating expenses
Often becomes a strategic consideration
Improves worker and facility safety
In-Briefing
Is required by Forest Service Manual
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 50
A 9-Step Plan for Pollution
Prevention
Management commitment
Form teams, set goals
Identify waste streams
Prioritize waste streams
Identify pollution prevention options
Define costs
Select pollution prevention option
Implement option
In-Briefing Evaluate results
USDA Forest Service
Rocky Mountain Region
Summer 1999 See your Forest Service tool kit for more details
MES-FSCO-990524A
Slide 51
So Why The Reluctance?
Organizations are resistance to change.
Decisions are often made on cost
without the full cost picture.
Pride and tradition.
Perceived barriers of funding, time,
unique situations, authorization.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 52
The Real Challenge!
Pollution prevention is voluntary! Forests
and districts must be motivated to make
the change, otherwise any change is only
temporary or transient.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 53
And Remember This...
Pollution prevention is a process of people
who...
Might make mistakes, so be tolerant
Tend to resist change
Need encouragement, motivation, and
recognition
Are subject to peer and vendor pressure to
return to “traditional” ways
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 54
Managing Hazardous
Materials and Waste
Some pointers on managing
hazardous materials and
hazardous waste at your
forest/ district
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 55
What is a “Characteristic”
Hazardous Waste?
Corrosive:
pH > 12.5 or pH <2
Flammability:
Flash Point ≤140 F
Toxic:
Listed by EPA
In-Briefing
USDA Forest Service
Rocky Mountain Region Reactive
Summer 1999
MES-FSCO-990524A
Slide 56
“Listed” Hazardous Waste
This is a hazardous waste that contains
one or more of over 400 chemicals that
are included on four EPA lists.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 57
Flash Point
The flash point listed in Section IV of a
product MSDS provides information on
how to…
Determine if the product is a “characteristic”
hazardous waste
Store the product in case it is flammable
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 58
Identification of Hazardous Waste
All generators regardless of size MUST
determine if their waste(s) are hazardous.
Use prior product knowledge
If necessary, conduct a laboratory analysis
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 59
EPA Identification Number
If you generate hazardous waste, you
must get an EPA Identification Number:
Use EPA Form 8700-12 and apply to state
EPA Identification Numbers are site-specific (a
particular address)
If you’re in Colorado, contact the Hazardous
Materials and Waste Management Division,
Colorado Department of Public Health and
Environment, (303) 692-3300
In-Briefing Questions, call Robert C. Steckley, Rocky,
USDA Forest Service
Rocky Mountain Region (303) 275-5173
Summer 1999
MES-FSCO-990524A
Slide 60
Hazardous Waste Generator Size
Conditionally Exempt Small Quantity
Generator (CESQG): Less than 100 kilograms
(220 pounds, 25 gallons) per month
Small Quantity Generator (SQG): More than
100 but less than 1,000 kilograms per month
Large Quantity Generator (LQG): More than
1,000 kilograms (2,200 pounds) per month
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 61
Weights and Volumes
Understanding how to convert liquid
volumes to weights is important...
Find the “specific gravity” (sg) value in Section V
of the MSDS and calculate the weight
Weight (pounds) = sg x 8.4 (pounds)
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 62
Quick Conversion for HW
One kilogram is approximately 2.2
pounds.
100 Kilograms is approximately 220
pounds.
1,000 Kilograms is approximately 2,200
pounds.
100 Kilograms of liquid is approximately
In-Briefing 25 gallons.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 63
Note About LQGs
The requirements for Large Quantity
Generators (LQG) are very significant
and will not be addressed in this
training.
If you think you are a LQG, contact Mr.
Steckley at (303) 275-5173 for
In-Briefing
guidance.
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 64
Maximum HW Storage Limits
A hazardous waste generator is
classified by the total weight of
hazardous waste stored at the EPA
Identification number site:
CESQG – no more than 1,000 kilograms
SQG – no more than 6,000 kilograms
If you store more than your generator
size limit, you must up-grade your
In-Briefing
USDA Forest Service
generator size.
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 65
Maximum HW Storage Duration
As a hazardous waste generator, you
cannot store hazardous waste at your
site (particular address) longer than...
CESQG – no time limit
SQG – no more than 180 days if disposal
facility is within 200 miles, otherwise no more
than 270 days
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 66
Counting Your Hazardous Waste
For purposes of determining your
generator size, you must count ALL
hazardous waste generated at your site
(particular address) during the calendar
month.
Remember, you must count all
hazardous waste in storage throughout
your site to determine if you exceed
In-Briefing
USDA Forest Service storage limits.
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 67
Hazardous Waste Log
The SQG and CESQG Hazardous Waste Storage
Record forms can be used to track quantities
generated monthly and how much you have in
storage. Post a new one in each storage location
monthly, use it, file it!
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 68
Hazardous Waste Containers
Containers used to store hazardous
waste at your facility must be...
DOT-approved, closed top
In good condition so there is no risk of leaking
Kept closed at all times except when putting
waste into the container
Properly labeled
You may use used containers as long
In-Briefing as they are clean and all previous labels
USDA Forest Service
Rocky Mountain Region are removed.
Summer 1999
MES-FSCO-990524A
Slide 69
Labeling HW Containers
All hazardous waste containers MUST
be properly labeled, regardless of
generator or container size:
Each container must have placard that says
“HAZARDOUS WASTE”.
Each container must have the date when
hazardous waste was first put into the container
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 70
Disposal of Hazardous Waste
Disposal of hazardous waste from your
facility, regardless of amount or generator
size, you must...
Only use a transporter which is permitted and
has an EPA ID Number
Use a hazardous waste manifest
Select a permitted disposal facility which also
has an EPA ID Number
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 71
Long-Term Liability...
Liability for your hazardous waste does
not end when you ship it off-site. You are
responsible for it from cradle to grave...
Regardless of who is at fault
Regardless of licenses of disposal facility
Regardless of how the laws may change
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 72
Hazardous Waste Manifests
Shipment of hazardous waste from your
facility, regardless of amount or generator
size, must use a standard Hazardous
Waste Manifest:
Use your EPA ID Number
Must be signed by someone from your facility
You must receive a signed copy back from the
disposal facility within 60 days - or file an
exception report with the state
In-Briefing
USDA Forest Service Keep manifests and exception letters indefinitely
Rocky Mountain Region
Summer 1999 in your recordkeeping location
MES-FSCO-990524A
Slide 73
Recordkeeping
Assign responsibility for recordkeeping to
one individual and centralize all records.
Be sure to include:
All hazardous waste manifests, disposal
responses, LDRs, and exception letters
All laboratory analyzes
All HazCom training records
Monthly hazardous waste storage records
In-Briefing
EPA Form 8700-12, change notices, and all
USDA Forest Service related correspondence
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 74
Emergency Coordinator
If you generate hazardous waste, you
must assign an “emergency
coordinator(s)” who/are...
Available 24 hours per day
Responds to hazardous waste spill events
Attempts to contain the spill and clean it up
ASAP, including any residual contamination
Reports off-site spills to the National Response
Center at (1-800) 424-8802
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 75
Emergency Information
If you generate hazardous waste, you
must post emergency information by the
telephone in all hazardous waste storage
areas...
Name and number of “emergency coordinator”
Telephone number of fire department
Location of fire extinguishers, spill control
materials, and fire alarm (if available)
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 76
Emergency Preparedness
If you generate hazardous waste, you
must be prepared for emergency events
(e.g., spills) by...
Pre-positioning proper spill containment
materials and fire-fighting and decontamination
equipment
Installing communication devices at each
hazardous waste storage area
Coordinating with local emergency response
In-Briefing authorities (not necessary for CESQGs)
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 77
Special Wastes: Used Oil
Used oil is exempt from being a
hazardous waste IF it is collected and
made available to a licensed used oil
recycling facility.
If used oil is not recycled, it MAY be a
hazardous waste.
If used oil contains a “listed” hazardous
In-Briefing
waste, the oil must be handled as a
USDA Forest Service
Rocky Mountain Region
hazardous waste.
Summer 1999
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Slide 78
Special Wastes: Used Oil (continued)
You must store used oil in closed
containers which are labeled “USED
OIL”.
You can self-transport up to one 55-
gallon drum of used oil at a time to a
used oil collection center.
Commercial transporters must have an
In-Briefing
EPA ID Number.
USDA Forest Service
Rocky Mountain Region Secondary contaminants must be used.
Summer 1999
MES-FSCO-990524A
Slide 79
Special Wastes: Lead-Acid
Batteries
Used lead-acid batteries are exempt
from being a hazardous waste IF they
are collected and made available to a
licensed lead-acid battery recycling
facility.
If used lead-acid batteries are not
In-Briefing
immediately recycled, they MUST be
USDA Forest Service
Rocky Mountain Region
considered a hazardous waste.
Summer 1999
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Slide 80
Enhanced HW Training
Contact Robert C. Steckley, Regional
RCRA Program Manager for information
on the next Enhanced Hazardous Waste
Training.
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
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Slide 81
In-Briefing
USDA Forest Service
Rocky Mountain Region
Summer 1999
MES-FSCO-990524A
Slide 82
