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Introduction
Welcome to our second edition of the Hazardous Waste Newsletter from the Montana DEQ Hazardous Waste Program. In this semi-annual publication, we hope to provide program updates, spotlight new or commonly missed regulations, and let you get to know our staff. Please feel free to contact us anytime with questions or comments!
-Denise A. Kirkpatrick, Section Supervisor
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Acronyms and Definitions
LQG - Large Quantity Generator: Hazardous Waste Generators that generate greater than 2,200 pounds of hazardous waste or greater than 2.2 pounds of acute hazardous waste in a calendar month
SQG - Small Quantity Generator: Hazardous waste generators that generate between 220 and 2,200 pounds of hazardous waste in calendar month
Check out our website for more detail on generator categories! -------->
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VSQG - Very Small Quantity Generator: Hazardous waste generators that generate less than 220 pounds of hazardous waste in a calendar month
CFR - Code of Federal Regulations. Hazardous waste regulations are found at 40 CFR 260-279. Montana incorporates the federal regulations by reference in the ARM.
ARM - Administrative Rules of Montana. Hazardous waste rules can be found at rule chapter 17.53.
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What's Up
Invoices were emailed May 1 to all sites registered as small and large quantity generators or sites that had an episodic event in 2022. Included in the invoice is an annual registration fee and a fee based on how much waste was generated at your site in 2022. Fees may be paid electronically using the link on the invoice. After July 1, unpaid fees will be subject to a 10% late fee.
May 14, 2023 marked the first anniversary of Montana’s adoption of the Generator Improvements Rule, the Pharmaceuticals Rule, aerosol cans as Universal Waste, and several other rules.
Note: DEQ incorporates by reference the Code of Federal Regulations (CFR) in the Administrative Rules of Montana (ARM). For ease of reading, we are not noting the ARM citations in this newsletter. Please call or email us if you have any questions.
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Get to Know Our Staff
Phil Nyhof is our Regulatory Specialist for eastern Montana. He has been with DEQ since May 2021 and is based in the Helena office. He is very familiar with all things RCRAInfo and the e-Manifest system. Originally from Michigan, he spent time in South Dakota before moving to Montana 12 years ago. He has held numerous different occupations across a variety of industries and non-profits. In his free time, he enjoys spending time with his wife and dog, playing video games, and running He can be reached at Phillip.Nyhof@mt.gov or (406) 444-2891
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By the Numbers...
As of May 19, 2023 :
- LQG - 32
- SQG - 106
- VSQG - 1341
- TSDF - 9
- New Generators in 2023 - 8
- Inspections since 12/1/22 - 13
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Now You Know...
Training Requirements and Resources
Small and Large Quantity Generators of hazardous waste are required to provide their employees with hazardous waste training. As with most hazardous waste regulations, the more waste you generate, the more rules there are to follow. Lack of training and proper documentation of that training is a common violation found during inspections. Don’t let it be a violation for you! Below is a brief summary of the training requirements and some suggestions for meeting those requirements.
Small Quantity Generators
40 CFR 262.16(b)(9)(iii) states: The small quantity generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.
So what does that mean for you and your business?
Employees that handle hazardous waste must be trained both for managing hazardous waste during normal operations and for emergency procedures in case of a fire or spill. This can either be through formal training from a training vendor or training developed and given in-house. It may also be informal on-the-job training. It is important to note that if training is provided from a third party, some on-the-job training is needed to familiarize employees with procedures specific to your site.
No formal documentation or records retention is required. However (you knew there was going to be a however!), if you don’t document it, can you prove it happened?
Large Quantity Generators
The training requirements for LQGs can be found at 40 CFR 262.17(a)(7). Where the requirements for SQGs are only 29 words, the LQG training requirements and associated training record requirements are over 500 words. The following are some highlights of the training requirements for LQGs. See the regulations for a complete list and contact our office if you need help.
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At a minimum, training must ensure personnel are able to respond to emergencies.
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Employees must be trained within 6 months of hire and at least annually.
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Training records must be kept for at least three years after the employee leaves employment. Records for current employees must be kept until the closure of the facility. Training records must include the items listed at 40 CFR 262.17(a)(7)(iv).
Very Small Quantity Generators
There are no training requirements in the regulations for VSQGs, but it’s never a bad idea to get some training or do some reading on your own.
You have several options to choose from when seeking training.
Is your industry group having a meeting in Montana? We have staff that can come talk about hazardous waste classification and management. Contact our office for more information.
We're Hiring!
Our program has an opening for a hazardous waste specialist. The position will be advertised in late-June or July. If you or someone you know is interested in joining our awesome team, click the button below.
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Important Dates to Remember
- July 1 – Annual maintenance fee and waste generation fees due to DEQ
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