The HWGIR = EPA's new "Hazardous Waste Generator Improvement Rule".
It is now in effect and it's the biggest change in the waste management regulations for 35 years.
SQG's = Small Quantity Generators of Hazardous Waste.
All across America, SQG'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 35 years, the hazardous waste management rules remained the same ... Until Now.
SQG 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 <<
>80% of SQG Waste Managers have more than one hat to wear at work. With all the daily tasks to do, you know that keeping up with EPA rules is not at the top of the list.
When you inherited the Waste Manager hat, you just assumed that everything was just fine, and you put the whole thing on the back burner.
Now you know that your waste management plan must be completely rebuilt, but you're not sure where to start.
>>Lack of Experience<<
Many people in charge of an SQG facility were not hired to become the Hazardous Waste Manager.
At some point, you were appointed the role, or you volunteered for it, or it fell in your lap some other way, even though you didn't have any experience.
You didn't know the EPA rules, you didn't know the technicalities of the regulations, and your understanding of chemistry was most likely very low.
>>The Threat of Inspections and Fines<<
Almost every Waste Manager I've ever worked with has 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 couple years. If you haven't already been asked to find cost reductions, you probably will be soon.
There are ways to do it, but without the knowledge of more advanced waste management techniques, you're not sure how.
Some of the Regulatory Changes
There have been many changes and additions to the rules you need to be aware of:
Two New Terms - Independent Requirements and Conditions for Exemption.
Your Legal Status - If you violate the regulations, 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 must be subjected to a rigorous Hazardous Waste Determination.
Re-Notification - You now must re-notify to your state agencies on a regular basis.
Satellite Accumulation – There are several new requirements, including documented weekly inspections.
Waste Quantities – You are now required to have records that back up your Generator Category Determination.
Episodic Events – You can now maintain your generator category if you exceed your waste amounts under certain conditions.
The simple fact is that the entire game has changed, and you need to realign your operations accordingly.
The Bottom Line
You Are Vulnerable
The HWGIR has made it easy for an inspector to tell if you are a soft target. He only has to 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 knows you are in the bag 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 didn't implement the New EPA Regulations - the HWGIR.
But, there is hope ...
Together, WE CAN SOLVE YOUR
HAZARDOUS WASTE
COMPLIANCE DILEMMA
Summary of Your Options
1. The HWGIR Compliance Course for SQG's. A self-paced, on-demand, online course that will give you a thorough understanding of the new EPA rules for hazardous waste management at your facility.
2. The Waste Manager Support Package. You get the SQG Course + the UNLIMITED email and phone support you've always needed as a waste manager - for One Full Year.
Option 1 - The HWGIR COMPLIANCE COURSE FOR SQG'S
The HWGIR Compliance Course for SQG's.
>> Gives you a thorough understanding of your requirements as a Waste Manager,
>> Test all the assumptions you have inherited from the waste managers before you,
>> The HWGIR regulations explained in Plain-English
>> Course correction for long-neglected Waste Departments,
>> 16 Lessons, 200 minutes of videos, 36 documents and forms - all downloadable,
>> 30 days of email assistance
Price: $497 (tax not included)
A self-directed online course that covers all of the new requirements for Small Quantity Generator facilities under EPA's Hazardous Waste Generator Improvement Rule (HWGIR).
Option 2 - The Waste Manager Support Package
The HWGIR Compliance Course for SQG's + the Waste Manager Support Package.
First, you get the HWGIR Course for SQG's to get you up to speed with the new rules. Then, For One Full Year you will have unlimited email and phone support - putting my 39 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.
Phone Support - You will be given access to my phone call scheduling system where you can set up a 15 minute meeting. We will be laser-focused on providing a direct and Plain-English answer to your questions.
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 form of continuing education in the form of case studies.
Price: The SQG course for $497 + One Year of support for $1,070 = $1,567 (tax not included)
You get the SQG Course and ONE FULL YEAR of the help you need to bring your facility into compliance at the cost of just $4.29 per day.
Curriculum for The HWGIR Compliance Course for SQG's
Below you can see all of the content for the entire course:
16 Lessons
More than 200 minutes of video
36 documents, forms and written explanations
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- Snapshot of Lesson 1
- Lesson 1 Video (11:30)
- The HWGIR Adoption Map
- The HWGIR Summary and Outline
- The Full Text of the Regulation
- Text of Subpart G - Farmers
- Text of Subpart H - Waste Importers and Exporters
- Text of Subpart K - Eligible Academic Institutes
- Text of Subpart P of 40 CFR 266 - Healthcare Facilites that Generate Acutely Toxic Waste
- Test your learning
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