The HWGIR = EPA's new "Hazardous Waste Generator Improvement Rule".
It is the biggest change in the waste management regulations for 35 years.
VSQG's = Very Small Quantity Generators of Hazardous Waste.
All across America, VSQG's are now subject to the HWGIR, and if you haven't adopted the new requirements, your facility is way out of compliance.
The HWGIR has changed everything you do as a waste manager and it's time to face the music.
So, Here's What You're Up Against
>> All New Rules <<
For many years, the hazardous waste management rules remained the same ... Until Now.
VSQG facilities have a lot of catching up to do.
The HWGIR brought SEVEN BIG CHANGES to the waste management regulations, including:
a. Four Major Regulatory Changes
b. One Major Addition to the rules, and
c. Two Major Process to Include
It's going to take some work to get all this taken care of, but once it's done, you can get back to your other responsibilities.
>>Lack of Time<<
Almost every VSQG Waste Manager has more than one hat to wear at work and you know that keeping up with EPA rules is not at the top of the list.
When you became the new Waste Manager everything looked like it was going just fine. You had lots of more important things to do, so you put the whole waste management thing on the back burner.
>>Lack of Experience<<
You were probably not hired to be the Hazardous Waste Manager.
At some point, you were assigned the role, or you volunteered for it, or it fell in your lap some other way even though you had very little experience with hazardous waste.
You don't know the EPA regulations, you don't know the technicalities of waste management, and your understanding of chemistry is most likely very low.
>>The Threat of Inspections and Fines<<
Almost every Waste Manager I've ever worked with expressed their concerns about being fined, and for good reason.
That lingering fear of an unannounced inspection is always in the back of your mind, because you know it would not end well.
If this happened, you would be called on the carpet to explain why the violations were allowed. You would not look good in the eyes of your supervisors, and it could reflect badly on your future job advancement.
>>Rising Disposal Costs<<
I would guess that your waste disposal costs have increased by at least 20% in the last few years. If you haven't already been asked to find cost reductions, you probably will be soon.
There are ways to do it, but you're not sure how because it takes knowledge of more advanced waste management techniques.
Some of the Regulatory Changes for VSQG's
There are many changes you need to be aware of:
Two New Terms - "Independent Requirements" and "Conditions for Exemption".
Your Legal Status - As a VSQG you are exempt from many of the rules for hazardous waste generators. But if you're found in violation of your "Conditions for Exemption", your exemption can be stripped away and you can be fined as if you are a hazardous waste storage and disposal facility that is operating without a permit.
Hazardous Waste Determination - All wastes at your facility, even non-hazardous wastes, must be subjected to a rigorous Hazardous Waste Determination. It's a 5-step process to identify all EPA Hazardous Waste Codes that apply to the waste. Under the new rules, you must fully document your decisions.
Generator Categories – The old CESQG status is replaced with Very Small Quantity Generator (VSQG).
Waste Quantities – You are now required to have records that back up your Generator Category Determination, every month.
Episodic Events – You can now maintain your VSQG generator category even if you exceed your waste amounts under certain conditions.
The bottom line is that the entire game has changed, and you need to adjust your operations accordingly.
Time to Face the Facts -
You are Vulnerable
The HWGIR has made it easy for an inspector to tell if you are a soft target. All he has to do is ask One Question: "Can I see your written Hazardous Waste Determinations?"
If you look at him with a blank expression and say, "What's that?", he will know you're a sitting duck and in just a little while he can rack up thousands of dollars in fines for you.
And you won't have a leg to stand on because you are not in compliance with the Hazardous Waste Generator Improvement Rule.
Option 1 - The HWGIR Compliance Course for VSQG's
The HWGIR Compliance Course for VSQG's.
>> Focused on just the hazardous waste regulations that apply to your facility. No fluff and no BS.
>> Gives you a thorough understanding of what you need to do to bring your facility into compliance with the HWGIR.
>> Test all the assumptions you have inherited from the waste managers before you.
>> The EPA regulations for VSQG facilities explained in Plain-English.
>> Course correction for long-neglected Waste Departments.
>> 9 Lessons, 94 minutes of videos, 18 documents and forms, all downloadable.
>> 30 days of email assistance.
Price: $357 (tax not included)
A self-directed online course that covers all of the new requirements for VSQG facilities under EPA's Hazardous Waste Generator Improvement Rule (HWGIR).
Option 2 - The Waste Manager Support Package
The HWGIR Compliance Course for VSQG's plus
the Waste Manager Support Package.
First, you get the HWGIR Course for VSQG's to familiarize you with the new rules. Then, for One Full Year you will have unlimited email and phone support - putting my 40 years of hazardous waste experience to work for you.
Essentially, you will be putting an expert hazardous waste manager on your staff for a tiny fraction of the cost of hiring a consultant.
Email Support - You may ask as many questions as you wish for one year. I will reply with an answer for you within 24-hours.
Coaching-by-Phone Support - You will be given access to my Laser Coaching Program, where you can schedule 15 minute phone call with me. We will be laser-focused on providing a direct and Plain-English answer to your questions about hazardous waste management.
EMERGENCY ASSISTANCE - You will have lifetime access to me, 24 hours per day, in the event of an actual hazardous material emergency at your facility. I will do my best to be of assistance.
Regulatory Updates - As I become aware of changes in the rules that affect your facility, I will pass that information along to you.
Pro Tips - You will receive occasional messages about waste management topics that are applicable to many facilities. It a type of continuing education in the form of case studies.
Price: $870 (tax not included)
You get the VSQG Course and ONE FULL YEAR of the help you need to bring your facility into compliance at the cost of just $3.36 per day.
Curriculum for The HWGIR Compliance Course for VSQG's
Below you can see all of the content for the entire course:
9 Lessons
Almost 94 minutes of video - All Downloadable
18 documents, forms and written explanations - All Downloadable.
Lesson 1 - Introduction to the Haz Waste Gen Improvement Rule
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Lesson 2 - Purpose, Scope and Applicability
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Lesson 3 - VSQG Independent Requirements
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Lesson 4 - Voluntary Compliance with Other Requirements
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Lesson 5 - The Generator Category Determination
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Lesson 6 - Mixing Hazardous Waste with Solid Wastes
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Lesson 7 - Conditions for Exemption for VSQG's
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Lesson 8 - Episodic Events
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Lesson 9 - The Wrap Up
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Do you need authorization to buy the course?
Show This to Your Boss
I know that some of you will need to get permission from your manager or supervisor to purchase this course.
With this in mind, I prepared the following document for you to give to your boss.
DOWNLOAD it and send it to your boss when you mention the HWGIR Compliance Course for VSQG’s.
Go to this link: http://ehstips.com/show_your_boss_VSQG
It contains all the information needed to show your boss how the course can help you become a better Waste Manager.
It would be best if you email the document so that the links therein are clickable.
Value Guarantee
With this course, you will be given all the tools needed to:
1. Learn all the rules that apply to the management of hazardous wastes at your facility.
2. Bring your facility into compliance with the new requirements of the EPA’s Hazardous Waste Generator Improvement Rule (the HWGIR).
3. Make sure that any improper decisions of the past are corrected before an inspector finds them.
You may cancel your Waste Manager Support Package at any time. You will be refunded for each whole month remaining in the subscription period at the rate of $102.25 per month.
You will be presented with a Certificate of Completion at the end of the course.
You get to keep all the course materials and the document handouts.
Your Guide: Ron Harvey
I have been a hazardous waste chemist in the hazardous waste service industry for 40 years.
I have personally handled more than 400,000 drums of waste, cleaned up hundreds of chemical spills, and removed hundreds of illegal drug labs.
But what's important to me is helping the hyper-regulated business owners and managers of America.
I have been inside thousands of businesses just like yours. I have seen waste managers at every level struggling to keep up with the EPA regulations. I have also seen facilities get fined into oblivion.
The VSQG Course was developed to show you the fundamentals of the new rules for hazardous waste management and give you a foundation upon which you can build a fully compliant waste management program.
