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I am sure we have all dealt with these in the past , but this what we stumbled upon a week ago, on deserted private driveway .

More and more people are doing this today. Who knows what you may come across.

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Good you sure know the reg! I think oil follows under a different Reg. i would quote it but I left it at the firehouse.. Sorry! With waste it starts to fall under generators , if I remember correctly. There is some things different in the oil reg because it can be regenerated (cleaned) and reused. I sure wish I had that book! Great points and your right on with the regs. This picture to me seems to be not from a DOT Approved cargo truck but from someone hauling it in the back of a truck, like a small repair business or something. Great stuff! I would love to know more details .
Todd
Lane Sekavec said:
A couple of thoughts on this incident and the comments.

First, rather than "blue canary," the latest term is "copological indicator."

Second, it's important that fire departments not get in the business of handling and managing other people's waste. Anything beyond the required mitigation of the incident can lead to some significant legal issues and fines.

Once a material has been identified as a waste, it has to be characterized. If it's determined to be hazardous waste (as defined by the feds) either because of toxicity, reactivity, flammability or corrosivity or because it's a listed waste, there is a whole raft of regulations that kick into place.

Suffice it to say that fire departments don't want to be in the business of packaging, transporting, or especially improperly disposing of haz waste (such as in the dumpster behind the station). Putting a label on drums/barrels that advises the contents are awaiting disposal pending analysis may be as far as the responding agencies are able to go without running into potentially significant liability.
At this point nothing more to report, I do know the owner of the property has been billed by DEC for clean up

Todd McKee said:
Good you sure know the reg! I think oil follows under a different Reg. i would quote it but I left it at the firehouse.. Sorry! With waste it starts to fall under generators , if I remember correctly. There is some things different in the oil reg because it can be regenerated (cleaned) and reused. I sure wish I had that book! Great points and your right on with the regs. This picture to me seems to be not from a DOT Approved cargo truck but from someone hauling it in the back of a truck, like a small repair business or something. Great stuff! I would love to know more details .
Todd
Lane Sekavec said:
A couple of thoughts on this incident and the comments.

First, rather than "blue canary," the latest term is "copological indicator."

Second, it's important that fire departments not get in the business of handling and managing other people's waste. Anything beyond the required mitigation of the incident can lead to some significant legal issues and fines.

Once a material has been identified as a waste, it has to be characterized. If it's determined to be hazardous waste (as defined by the feds) either because of toxicity, reactivity, flammability or corrosivity or because it's a listed waste, there is a whole raft of regulations that kick into place.

Suffice it to say that fire departments don't want to be in the business of packaging, transporting, or especially improperly disposing of haz waste (such as in the dumpster behind the station). Putting a label on drums/barrels that advises the contents are awaiting disposal pending analysis may be as far as the responding agencies are able to go without running into potentially significant liability.
LOL.....you're being way more charitible with my knowledge of the regs that I give myself credit for. Luckily for me, one of our environmental managers sits right next to me and she's a wealth of RCRA (haz-waste) knowledge. I know enough to keep me and my company out of trouble.

You're correct, Todd, about it being the responsibility of the generator of the haz waste to characterize their waste and dispose of it properly. Haz waste has a "cradle to grave" responsibility and can get pretty detailed depending on the characteristics/listing of the waste.

You're also correct about the oil regs being different depending on whether something is going for disposal or for reuse/recycling.

One other little twist to keep in mind. If you have a release of diesel fuel from a transportation vehicle (semi-tractor, railroad locomotive), you're basically able to have pretty much anyone clean up the release (won't address disposal particulars right now). If you have the same amount of diesel fuel released from a placarded transport vehicle (tank trailer, tank car), the clean-up crew has to be qualified under OSHA 1910.120.

Same material but different clean-up qualification requirements due to the status (placarded shipment or fuel for vehicle operation) of the material involved.

Just when you think you've got it figured out, you find another page in the regulations book.

Todd McKee said:
Good you sure know the reg! I think oil follows under a different Reg. i would quote it but I left it at the firehouse.. Sorry! With waste it starts to fall under generators , if I remember correctly. There is some things different in the oil reg because it can be regenerated (cleaned) and reused. I sure wish I had that book! Great points and your right on with the regs. This picture to me seems to be not from a DOT Approved cargo truck but from someone hauling it in the back of a truck, like a small repair business or something. Great stuff! I would love to know more details .
Todd
Lane Sekavec said:
A couple of thoughts on this incident and the comments.

First, rather than "blue canary," the latest term is "copological indicator."

Second, it's important that fire departments not get in the business of handling and managing other people's waste. Anything beyond the required mitigation of the incident can lead to some significant legal issues and fines.

Once a material has been identified as a waste, it has to be characterized. If it's determined to be hazardous waste (as defined by the feds) either because of toxicity, reactivity, flammability or corrosivity or because it's a listed waste, there is a whole raft of regulations that kick into place.

Suffice it to say that fire departments don't want to be in the business of packaging, transporting, or especially improperly disposing of haz waste (such as in the dumpster behind the station). Putting a label on drums/barrels that advises the contents are awaiting disposal pending analysis may be as far as the responding agencies are able to go without running into potentially significant liability.
What are some of the Lessons here;
We take for granted that this will never happen to us , but it does

Keep a Safe distance, if unable to Identify call in the experts , they have the tools to do the job.

Always be on the lookout

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