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Must-knows concerningWrecker Monthly Report 2011 Form

good morning everyone I'm Lance French.I'm the marketing director for dubbing.him environmental and I would like to.welcome to I like to welcome you to our.webinar on hazardous waste management I.want to take a minute to introduce to.you our speakers to everyone dr. heather.frost and dr. laurie siegelman from WM.environmental good morning guys good.morning good morning yes no I don't have.a PhD that's only Heather just there up.front okay.go ahead and I guess I need to make it.clear I don't either so there you go so.before we get started I want to go over.a few housekeeping items this is an.interactive webinar so you can ask.questions and please type them through.the chat tab on your GoToWebinar window.we do have a lot of information to go.through so if we don't get to your.questions right away still send them.through I'll make sure that Lori or.Heather sees them and answers them as.quickly as possible we are recording.this webinar and it will be available to.rewatch later this afternoon along with.the slides that Lori and Heather are.using so I will send you a link later.this afternoon so that's enough out of.me.Lori we'll start with you so take it.away all right thanks Lance I'm during.today's webinar we just want to give you.guys a high-level overview of the rules.related to hazardous waste management.we'll start with a brief introduction to.rick rough for the benefit of any.listeners that may be new to waste.management then we'll discuss some.applicable regulations the waste.classification process and why that's.such an important first step then we'll.get into a little bit about the.generator requirements for management of.the hazardous waste and finally a.summary of the recent regulatory updates.that have occurred say the way we're.going to split this up is I am going to.talk about the first part just has waste.management in general and then Heather.is going to get on and talk about the.recent regulatory updates that have.occurred so I want to start with the.history and purpose of Micra the.resource and Recovery Act commonly refer.to.requires the primary law governing the.disposal of solid and hazardous waste so.it's not only related to hazardous waste.it was originally passed by Congress in.1976 to combat the growing volume of.municipal and industrial wastes the.primary goal that that program is to.protect human health and protect the.environment from the hazards or.potential hazards of waste disposal also.some goals were to conserve energy and.natural resources and reduce the total.amount of waste that was generated.making sure the waste was managed well.next slide so a little more about the.history and the purpose to achieve the.goals that we just listed Rick Rowe.established as a servant in that to.encourage and encourage recycling and.reduction of waste and then the waste.that we've generated if you couldn't.reduce it or we use it or recycle it it.developed the system for managing that.waste from the first time it's generated.until its ultimate disposal and so that.that system has become known as the.cradle to grave responsibility so once.yours always yours once you generate it.just because it goes out the door does.not mean it's not still your.responsibility Rick or authorization.next slide it's there you know so Rick.or authorization what that means is that.the Rick restate authorization it's the.rule making process where EPA delegates.the responsibility for implementing the.rules or the Ricker House waste program.to the individual states in lieu of the.EPA implementing that or enforcing it.there's currently 50 states and.territories that have been granted this.authority state programs have to be at.least in stringent of the federal.requirements but states have the option.to adopt more stringent requirements if.they want to and then the hazardous and.solid waste Amendments of 1984.significantly changed the way that new.Rick relations are enforced at the state.level EPA does amend the rules pretty.regularly and therefore the authorized.states have to their it's mandatory that.they adopt the mandatory amendments but.there are some optional amendments that.EPA puts forth where the states have a.choice whether they want to adopt them.or not so if you're looking at a federal.role change for instance if it's.considered an optional amendment then.the states don't necessarily have to.adopt it for instance in Texas if texas.chooses not to adopt a rule just because.epa has amended that role doesn't mean.you can automatically go by the federal.rule when it's changed you need to wait.and check with your state most of you.guys I suspect are in Texas you would.need to check with Texas to see have.they adopted that rule yet Texas has.amended the hazardous waste rules its.rules thirteen different times and they.did show they did choose to adopt the.latest Riccar amendments so these.amendments this is what Heather's going.to be talking about a little bit later.in the presentation while Rick Rowe is.an approach to manage solid and.hazardous waste at facilities that are.currently in use so these active.manufacturing manufacturing facilities.or whomever is currently in actively.generating waste and disposing of it.after implementation of the Ricker.program Congress in in the government.realized that it only was applicable to.existing facilities that only partially.addressed all the problems of hazardous.waste so CERCLA comprehensive.Environmental Response compensation and.Liability Act otherwise known as.Superfund was enacted or implemented and.it's focused on the management and.remediation of all of the abandoned non.operating sites where you have to tan.and risks to human health in the.environment.this is an important aspect of waste.management an important thing to be.aware of because combined with the.cradle to grave provisions of Rico if.your waste ends up being identified as a.Superfund site then you will or can be.considered a potentially responsible.party and then the Department of Justice.and EPA will come to you with their hand.out looking for some monetary.compensation to help clean the site up.and there's also state level cleanup.programs very similarly structured to.CERCLA so now that we've got that kind.of history in introductory information.out of the way the applicable.regulations at a federal level that are.mainly applicable just to the generators.of hazardous waste now there's many more.regulations that aren't listed here that.would apply to the transporters to the.disposal facilities and other specialty.kind of facilities but unsolicited here.that are primarily applicable to the.generators of hazardous waste which I'm.assuming are the majority of the people.on the call today most of the time the.federal regulations are adopted by.reference into the state rules with no.further requirements but also they can.be changed in attitude by the state when.the state adopts them so long as the.state rules are at least as stringent so.in Texas for instance then here is a.similar list only that's the state level.regulatory citations again just for the.waste generators there are other.subchapter subchapters and parts that.would be applicable to like the.municipal landfills and the disposal.companies and the transporters but this.list here is specific to waste.generators so you would as a generator.would want to be familiar with all of.these different roles.and in in Texas again the applicable de.generators of hazardous and also.industrial waste Texas does have more.stringent in more broad requirements for.generators as you'll see later in the.presentation because we're going to talk.a little specifically about Texas regs.so the very first step briefly I want to.go over the just the basic steps of.hazardous waste management and this is.just a very high-level things that we.can cover in just a you know 45 minutes.or so the but the basic steps of has de.waste management as it pertains to.generators the very first step needs to.be identifying your waste streams if you.don't know what your waste streams are.then you can't be sure they're being.managed properly and that includes.always not just your hazardous waste so.you know step one identify what is all.of the different what are all of the.different waste streams that your.facility generates so brings us to our.first question.what is a Rick run solid waste when.identifying and evaluating shiri waste.streams you need to understand that the.term solid waste as it is it's defined.in the regulations because this is going.to dictate which waste streams may be.exempt from their rules in which waste.streams will be defined as and regulated.as a hazardous waste only the wastes.that meet the definition of solid waste.are subject to the Ricker rules in the.term solid waste is very broad it.includes not only traditional non.hazardous solid waste such as garbage.but also hazardous wastes in the.definition of solid waste also includes.or the broad definition is any discarded.material not specifically excluded by.regulation or variants and it can be a.solid a liquid or gaseous and there's a.number of exemptions written into the.definition of solid waste certain things.are considered to be exempt and are not.solid waste and the definition of solid.waste and sometimes you'll see it by the.acronym.DSW is one of the major revisions.recently adopted by TCEQ that heather is.going to talk about shortly so the next.question we need to ask her ask.ourselves are the next thing that you.need to be familiar with is what is a.hazardous waste what would be defined as.a hazardous waste once you determine.your waste is a solid waste or not then.the next thing to do is determine.whether or not it meets the definition.of and is regulated as a hazardous waste.and if it is what is its waste code or.codes any particular hazardous waste has.the potential to have more than one.hazardous waste code depending on what.it is and this this next slide is a.chart that kind of visually represents.the different categories of waste and.you can follow it from the top down and.use it as a flow chart as well for.example if you have a material we start.at the top of the chart you have a.material that you're evaluating whether.or not it would be regulated as solid.waste and then is it a hazardous waste.check all of the exemptions and.exclusions contained in the definition.of solid waste for instance the two the.two top blocks above the red line that.would not be subject to rick rrah 40 CFR.261 point 4 contains a list of materials.that are specifically excluded things.such as domestic sewage or wastewater.discharges that are permitted under the.Clean Water Act another set of.exclusions would be under 40 CFR 261.point 2 and that particular part or.paragraph is is where the definition of.solid waste is contained it contains the.broad definition plus a list of.materials that would be excluded under.certain circumstances for instance.paragraph e contains a list of materials.that would not be considered a solid.waste when they're recycled so if you.determine that your waste is indeed.regulated as a solid waste.none of the exemptions or exclusions.apply then the next step would be to.determine if maybe it's exempt or.excluded from being regulated as a.hazardous waste so hazardous waste being.a subset of solid waste if your waste.isn't the solid waste then it can't be.regulated as a hazardous waste so a lot.of generators want to want to get those.exclusions for solid waste and if it's.excluded for solid waste you're pretty.much done and you don't have to go any.further to figure out if it's hazardous.or not hazardous hey Laurie I have a.question from somebody really quick how.concept of green and safe chemicals can.be incorporated in the new laws and.regulations in the new laws and.regulations so that would be like then.I'm not sure new laws and regulations.with that okay I'd say we'll make sure.that you see this one later and when I.get clarification and do these rules and.regulations are they designed by looking.at cradle to cradle to cradle or.circular economic models yeah I'll get.more clarification on this later yeah.economic yeah I just added horrible and.economic so no I'm kidding.I I'm not sure I understand the details.of either those questions I think that.maybe would require a little bit more of.a conversation but the first one related.to green chemicals and chemistry as it.relates to the new regulations if if by.referencing the new regulations they.made the changes that have just been.adopted the changes that were adopted.mainly relates you the definition of.solid waste which does try to.incorporate more of a clarification and.a little more leniency I guess for.recycling and reclamation of your waste.so that in it also provides some.clarification and regulations meant to.prevent or eliminate sham.recycling so I'm not sure if that's what.the person asking the question is is.meaning or not but I know there's some.other things related to solvent.remanufacturing that may apply as well.so when you're talking about but green.green chemistry and maybe doing some.type of screening or new chemical.evaluation before you choose your.chemicals is is a little bit different.but we can we can visit with those.questions later after the presentation.so I make sure I do address what the.what the people are asking is that is.that it for now well first question yeah.that's what I'm gonna do is I'll just.email them and we'll get more.clarification and then I'll see you okay.cool so then we get to to Texas now so.we texas follows the same rules for.solid and hazardous waste as far as.classification and what is a solid waste.and what is a hazardous waste but then.they go one step further by requiring.generators to evaluate the non hazardous.waste into either class one class two or.class three categories based on the.toxicity and some other other things so.this is specific to industrial waste.generators so that's yet another term to.become familiar with what is an.industrial generator whether or not you.are an industrial waste generator or not.I'm in for instance if you're a retail.store and you wouldn't be considered an.industrial generator yet you may.generate the same type of waste that a.manufacturing facility down the street.generates well you're you as a retail.store would not fall into regulation.under this particular rule that requires.you to to categorize your non hazardous.waste so there's a little nuances there.for Texas generators related to non.hazardous waste so when you're.identifying your way all of your waste.streams the comment.that I see among generators and a lot of.our clients and one of the most commonly.cited violations that I've seen ccq and.also at the federal level is that not.all of the waste streams have been.identified there's a lot of waste.streams that are forgotten not addressed.by the generator as far as proper waste.classification or documenting that often.the only ways they're considered are the.ones associated with directly with the.manufacturing process but there's many.other typical wastes that need to be.considered such as your used oil your.waste paint even in in maintenance I see.this a lot all of the waste paint and.waste maintenance type of chemicals in.brake cleaners and solvents and things.use their wastes absorbents batteries.for sweeping there's a lot of different.things to consider so it's very.important to look across all of your.different departments not just focus on.your your manufacturing processes so in.summary the steps again going from left.to right your high-level summary of the.requirements for managing your wastes in.this applies to pretty much all.generators even those that are.conditionally exempt and we'll get into.what is conditionally exempt in just a.second.first identify all your wastes which.that's what we've been talking about.determine which ones if any of them are.regulated as hazardous or non hazardous.industrial wastes if you happen to be in.Texas classify those accordingly then.after you've done all that you're.required to you need to store them.properly you don't want them spilled all.over the place or mishandled keep.documentation of your waste processes.especially if you've determined some of.our exempt or excluded train your.employees any reporting that's required.such as annual or biennial reporting and.then emergency response procedures and.now not all of that list would be.applicable by regulation to.conditionally exempt small quantity.generators prints.but it's still a really good idea to do.or a best practice to do all of these.things even if it's not required by.regulation so getting into just a little.more detail on some of these items we've.been talking about probably the most.important thing you can do is complete.the documentation package for each of.the waste streams that you identified.you want documentation that details.whether or not it's a solid waste and if.it is a solid waste is it a hazardous.waste if it's a non hazardous waste in.your in Texas you want to document what.class what class is at class 1 class 2.class 3 include in your documentation.and in your rationale for the waste.determination in a process flowcharts.safety data sheets analytical data.regulatory citations save you've decided.it's exempt because you recycle it you.want to cite that regulatory citation.and you know write down file memo to.file or something that we recycle it we.do this with it and here's the.regulatory citation that says it's not.regulated as a solid waste or is.excluded from definition of hazardous.waste or whatever the case may be also.that's very useful information to share.with your waste hauler or your vendor.say they can properly profile your waste.for disposal if you're a and I see this.over and over if you're conditionally.exempt small quantity generator and.you're not paying much attention to your.vendor you just say here hold it off.more often than not they're going to.over classify that waste stream if it's.questionable whether it's hazardous or.non hazardous they're going to profile.it as hazardous and if it's non.hazardous and that's pretty clear-cut.then they're going to make it a class 1.hazardous waste and if you haven't gone.to the trouble to to catch that and talk.to him about it and properly classify it.you could find yourself in the position.of of shipping off-site class 1 waste.that really wasn't class 1 possibly and.then you get pulled into more.regulations under under the state of.Texas than you need to be.because now you're a class 1 generator.if you pass a certain threshold it kind.of throws you into some reporting.requirements you wouldn't necessarily.have to have to be and if you had gone.to the trouble to communicate with your.vendor the appropriate information next.slide.yes sure did you want to launch the.Polar's at the next slide oh yeah I.forgot about that sure so let's go ahead.and do that right now okay so let me.give him a few more minutes to.I'll go ahead and close the poll right.now or can you see the results no okay.so it says so the question was how many.have how many of you have documented on.file for every waste stream that you.generate and 76% said yes and 24% said.no okay.well 76% that said yes is it surprising.because I I would my experience with the.clients that we have and just in general.just general industry it's more 50/50 or.even less but that's good then that that.means the participants on our caller.managing their waste very well we have a.sharp so moving on to the two next slide.then once you make all of your waste.determinations then you know which rules.need to be followed so that that's very.important figuring out what's hazardous.what's not what's excluded what's not.document the heck out of that but then.you know what your generator status that.combined with some more information will.help you determine your generator status.the generator status is dictated by how.much hazardous waste is generated each.month not by how much is shipped on a.manifest during a single month that in.during during one month how much is.actually generated so you want to count.the waste that's generated in your.settlement accumulation areas and also.other manufacturing points in your in.your storage areas then your generator.status is then going to dictate how long.you're allowed to store your waste on.site and other requirements such as well.training you have to train your.employees to the details of your.emergency planning among other things.the first step was to identify your.waste streams and classify those or make.waste determination then step 2 watch.your generator status step 3 then manage.it appropriately while while it's on.site two more questions our recycled.materials not considered solid waste and.if so do we not need to fill out the rgo.22 forms for those materials recycled.materials may or may not be considered.solid waste and you would need to look.at the specific exclusions in the solid.waste rule depending on what the.material is whether it's like a spent.solvent or a sludge specifically in the.rules that you're recycling and then.depending on how exactly you're.recycling it it could be a solid waste.but exempt from hazardous waste or it.could be excluded from solid waste.altogether so there's many there's quite.a few different exclusions and.exemptions that you would have to read.through to make that determination but.just because you recycle it doesn't.automatically mean it's not a solid.waste you have to find a specific.exclusion and now whether or not you'd.have to fill out the rgo 22 I believe is.that the checklist in the in the TCEQ.guidance document that helps you.determine or make that documentation I.think that's what that is I'm not 100%.sure I don't remember the right guide.number but just documentation in general.if you're looking at a waste train and.you're deciding oh we're recycling it.therefore it's excluded from being.regulated as a solid waste and here's.why I would go ahead and document that.whether or not you fill out a specific.checklist or not I don't think would be.necessary to do a checklist per se but.at least some kind of document that says.that that contains that rationale and if.you are recycling it then may.some information about where are you.recycling it and some documentation that.it was shipped to a certain person or a.certain company for recycling and if.they provide any certificate of.certificates of recycling it would be.helpful to keep that as well okay and.one more question is so she looks like.she's asking the question on something.you said earlier shows but what is the.proper and she had proper in all caps.what's the proper way to document our.waste streams the proper way to document.a waste stream there are very specific.requirements that are called out in the.TCEQ regulations specific pieces of.information that you're supposed to.document they have the checklist within.their regulatory guide that will help.you document those specific pieces of.information but the proper way that.would be either to use that checklist.and combine that checklist with any.other data you're using to fill in the.checklist so for instance in that.checklist and you don't have to use the.checklist but you can it's a good it's a.good guide so for instance one of the.decisions are going to make is you know.is it a hazardous waste.well is it a characteristic hazardous.waste from a toxicity standpoint isn't.below all of these different levels for.chromium for lead for cadmium and in on.and on if you have analytical results.that prove that yes it's full otos.limits didn't attach the analytical.results to the checklist or to the other.memo to file or whatever you're filling.out that has some information so that.would be the product the proper way from.me as you either fill out a checklist or.you fill out some kind of memo to file.or a form with the specific pieces of.information that TCEQ requires at least.and then supplement that with any data.that you use to answer those questions.or to make that determination via safety.data sheet if you're using any type of.process knowledge maybe a process flow.chart or a narrative of the process you.know anything that you use.to make that determination I would.append to the checklist or the memo and.then put that in the file very good.thank you.these next few slides are just a a.summary table and I think this table.originally came out of one of the EPA.guidance documents or or training or.training documents it's just a.comparison of the different generator.statuses you're either conditionally.exempt small quantity generator small.quantity generator or a large quantity.generator and as your generator status.increases so the amount of the waste.hazardous waste that you're generating.increases beyond these thresholds then.the amount of regulatory requirements.increases or the the stringency that you.have to manage that waste increases.there are not many restrictions for for.the conditionally exempt generators such.as the time limit but there is a maximum.quantity that can be stored on-site.that's another thing I see quite often.is people companies assume that they're.conditionally exempt therefore there's.really no requirements so they're not.really training their folks they're not.paying attention to how much waste they.have in storage they're not documenting.their generation rate like how much they.generated per month and so so really.they're out of compliance with a lot of.the different rules because they can't.prove anything to getting to the next.slide then again conditionally exempt.small quantity generators they don't.have any specific storage requirements.the best practices to limit liability.would be to go ahead and manage the.wastes appropriately and to fill out a.manifest as far as reporting.requirements again not much required for.conditional exempt as far as reporting.training emergency planning small.quantity generator everything's required.but kind of it a.lower level than large quantities.generator you need a full-blown.contingency plan a full-blown emergency.procedures biannual reporting now in.Texas they have annual reporting which.fulfills the biennial report requirement.and then the last thing the DoD rules.they're a little different as they apply.across the board to all the generators.equally hazardous waste is considered.and defined as a dangerous good under.the DoD rules and so when you're.transporting dangerous goods it has to.be done so important accordance with the.DoD rules and specific training for.shipping this waste is required so if.you're signing manifests or helping.prepare those shipments and labeling.drums and things like that then there.are DoD training requirements that you.have to meet even if you're.conditionally exempt small quantity.generator and then finally as a final.thought proper waste management and this.is another especially important thing to.do in addition to documenting your waste.identification or your waste.determination process is to track your.monthly waste generation rates so that.you can demonstrate your generator.status this is especially important for.the small and the conditional exempt.small quantity generators not so much.important for a large quantity generator.for large quantity generators unless.you're doing some waste minimization and.pollution prevention where you want to.track your waste generation it's really.not not that big of a deal but for.conditionally exempt in small quantity.you really need to have a handle on what.your monthly generation rate is and be.able to to demonstrate that whether it's.a log sheet like what's shown on the.screen or from process information you.can demonstrate that G on a daily basis.the most of this waste stream wicked.generators is X pounds and if we're.operating you know 20 to 30 days a week.then here's as much as we can generate.we can't generate it anymore you.wouldn't necessarily need to log it on a.log sheet like this but at least you.have that information you've thought it.through and you know.generator statuses and can demonstrate.that lorry we have a question where can.we where can we get copies of the.tracking charts and the checklists you.mentioned these are charts and.checklists that we've developed for our.clients over the years and it's like a.continual effort they change as as we.see changes and revisions are needed but.you know we're happy to provide that to.anybody who is is interested in having.it they just email me and let me know.and I'll have happily email that to them.great thank you.okay we're going to take just a like a.15-second break here and I'm gonna let.Heather Frost take over she is the.division manager for industrial.compliance with our group and she's.going to talk to you guys about the.recent rule adoptions in some other.proposed rules that are still out there.at the federal level hang on one second.I feel like we I feel like we said music.and this on this break and I will now be.discussing some of the revised federal.and state rules so this is just sort of.a transition slide of what we're going.to talk about today but there have been.numerous changes recently to the.definition of solid waste and these.rules collectively represent the most.significant changes to the regulation.since 1985 so these rules are important.to you as a waste generator because the.the new and proposed rules affect the.waste classification process so in some.cases we've seen the new regulations are.a little more lenient but in other cases.we've seen that these regulations go in.a direction that we have not seen in.quite a while with retro and that.that they've become a little more.stringent so Laurie spoke briefly about.retro authorization because states are.authorized to implement the retro.program implementation of these new.regulations and proposed regulations.might vary amongst the states so we'll.discuss a few of the regulations but.keep in mind that it's important to.evaluate evaluate the regulations in.your own state so a few of the specific.new rules and proposed changes that.we'll introduce today are the you.manifest final rule and that was.published in 2014 which authorizes the.use of electronic hazardous waste.manifest and we'll talk a little bit.about a little bit more about that in a.minute we also have this solvent.containing wipes rules that have been.authorized in some states the cathode.ray tube regulations that impact export.and export tracking of CRTs we'll talk.about the steel slag rules and that's.that's specific to the state of Texas.and then get into the most significant.change and that's the changes in the.definition of solid waste DSW or the.definition now includes hazardous.secondary material so we'll talk a.little bit about that and then proposed.pharmaceutical rule rules that are just.built on the rules that were proposed in.2008 and then talk a little bit about.some proposed changes as well so first.the e manifest rule this gives.generators the option to complete sign.transmit and store their manifest.information electronically this would.extend to all federally and state.regulated waste that currently require.manifest and the EPA is authorized to.collect user fees for this program so.the effective.date was this summer doing of this.summer and currently a see schedule is.being evaluated and in the near future a.system will be online but right now we.don't have that system right now we just.have the rule authorizing the use of.these manifests once the program has.been established the solvent containing.wipes rule became effective federally in.January of 2014 however the solvent.containing wipes rules are less.stringent than the previous requirements.under Accra therefore the APA has.indicated that the solvent containing.wipes rule was optional for states with.authorized retro programs so each state.must determine whether or not they would.like to adopt this final rule or certain.provisions of the rule into the.regulations the tcq did adopt this rule.in January of 2015 so this rule excludes.wipes that are contaminated with.solvents from certain hazardous waste.requirements the rule also modifies.regulations for solvent containing wipes.solvent contaminated wipes that are.cleaned and reused and those that are.sent for disposal the purpose of the.rule was to provide a regulatory.framework for these wipes that's.appropriate not only to the level of.risk in a way that maintains protect.protection of human health in the.environment but also reduces compliance.cost for so the new rule accomplishes.that goal by by allowing manna-fest to.be disposed of without a manifest when.they're sent off-site they can also be.sent to non hazardous waste handling.facilities to be eligible for the.conditional exemption both the reusable.and the disposable wipes have to be.managed in accordance with some rules.and those rules are that all solvent.contaminated wipes must.captain non-leading closed containers.those containers must be labeled.excluded solvent contaminated wipes the.wipes cannot be accumulated longer than.180 days and the accumulation start date.has to be barked on the container to.verify that and at the point of.transport the wipes may not contain free.liquids so generators must maintain.documentation that they're managing the.wipes in accordance with these.regulations the CR P rule became.effective December 26th of 2014 and this.revised export provisions of the 2006.rule it provides for better tracking of.CRTs that are exported for reuse and.also recycling so the rule only affects.export provisions of the CRT rules.it does not affect any regulations that.are applicable to the domestic.management of these materials this rule.does have five main parts they've.defined CRT exporter they have now.required annual report from exporters.revised notification when these.materials are sent for recycling also.revised notification when they're.exported for reuse and normal business.records are maintained by the exporters.and that those can be translated into.English upon request.next slide here is the steel slide rule.and this is specific to generators in.the state of Texas this new rule or this.new exclusion from regulation as a solid.waste has been codified in the Texas.Health and Safety Code it prevents the.Commission from regulating steel slag as.a solid waste if this deal slag has not.been discarded it is not intended for.output or the result of the use of an.electric arc furnace to make steel so.this material is exempt from regulation.if the solid waste is not discarded if.it's introduced into the stream of.Commerce and it's managed as an item of.commercial value the the most major.element of these new regulations is the.new definition of solid waste so we now.have a formal definition of solid waste.and hazardous secondary material that.will promote recycling while still being.protective of human health and the.environment the centerpiece of this new.rule is three new exclusions from the.definition of a solid waste that applies.specifically to hazardous secondary.materials and these are defined as.listed by products listed sludges and.spent materials that are all recycled by.being reclaimed these exclusions are.referred to specifically as the.generator controlled exclusion can you.go to the next slide Lancer here the.generator is controlled exclusion.they're verified recycler exclusion in.the remanufacturing exclusion you need.to go ahead you're on the slide and.they're way.one more there you go.the generator a controlled exclusion.applies to hazardous secondary materials.that are generated and legitimately.reclined by the generator of the.material the verified recycler exclusion.was formerly referred to as transfer.based exclusions and to take advantage.of these exclusions the generator must.satisfy very specific criteria which is.to notify the executive director of your.recycling activity to ensure that the.hazardous secondary materials are.properly contained to prevent release.the criteria for evaluating the.legitimacy of the recycling operation is.now evaluated we have specific.record-keeping requirements we have to.avoid speculative accumulation and the.facility that does the reclamation must.have either a retro permit or a solid.waste of variance and all persons.managing that has the second material.must maintain proper financial assurance.the third major element there is the.remanufacturing exclusion and that.allows for the transfer of certain spent.solvents from one manufacturer to.another for remanufacturing which is.defined as extending the useful life of.the original solvent the secondary.material in this case must be one of 18.specified solvents and the goal of this.particular exclusion is to keep.materials in commerce so it does not.apply to solvents that have been sent to.commercial recyclers rather we have a.question here really quick the steel.slag exemption does that apply to flag.that has reused as road base or.incorporated into material that will be.applied to the land this still I'd have.to look more into that but I have seen.some information indicating that that.would be applicable.okay major elements of the new.definition of solid waste this broadens.the exclusions from the definition of.solid waste force materials such as.spent materials of solvents spent acids.listed sludges and this is very.important I know that many waste.generators in the metals industry have.looked forward to this being included we.also have listed byproducts spent.petroleum catalyst another one that's.very important to the metals industry.and metals that are part of listed.sludges so metals that have been in.smelting melting refining furnaces as.well and regarding the verified recycler.exclusion in the requirements to.maintain financial assurance our FAA.estimates required to be submitted to.the state so that those documents are.required for facilities that are.managing that material so I know part of.the rec report B permit is that you hold.financial assurance and when you do hold.the record Part B permit that's an.annual requirement you have to submit.that documentation to the state so major.elements of the new definition we have.four factors that have been codified for.determining if the hazardous secondary.materials were being legitimately.recycled so this 2015 rule expands on.the application of this criteria and now.applies this to all recycling so this.means that the legitimate recycling.provision applies to all hospitals.second during the materials that are.excluded or exempted from retro which.are the materials were talking about now.but also this legitimacy provision.applies to all recyclable hazardous.that remains subject to partial or total.hazardous waste regulation so this would.include when we're talking partial.hazardous waste regulation that would.include things such as the precious.metals now we can move on a little bit.to the hazardous waste pharmaceuticals.this is a proposed rule it's a set of.regulations for the management of.hazardous waste pharmaceuticals by.healthcare facilities and reverse.distributors.it will provide standards to ensure the.management of hazardous waste.pharmaceuticals is safe and also.workable in the healthcare setting so we.have seen some of the hazardous waste.rules aren't really practical in these.healthcare settings so hopefully this.will make things a little bit more.manageable this proposed rule is built.on the 2008 EPA proposal to add.pharmaceuticals to the types of.hazardous waste that could be managed as.universal waste that a lot of commoners.supported the idea of those new.regulations but there were numerous.concerns over the lack of notification.requirements the lack of tracking.requirements for shipping of those.wastes and other things.therefore the agency decided not to.finalize that 2008 proposed rule but.rather develop another proposal for new.standards for the management and.disposal of these ways so now we see in.2016 we have this new proposed.rulemaking that will pertain to those.pharmaceutical waste that meet the.current definition of a retro hazardous.waste that are generated by these.healthcare related facilities in this.new proposed rule we do not have a.provision for flushing of.pharmaceuticals this proposed rule would.ban all sewer of pharmaceuticals.so we also have some proposed hazardous.waste generator rules that we're looking.that we're evaluating for the fall of.2016 we're expecting that there will be.an overhaul of the rules some becoming.more stringent some less stringent some.of the things that we're looking at.becoming more stringent are the.hazardous waste determinations the.labeling requirements the less stringent.a parts of these rules would be episodic.generation for one the waiver of the.50-foot rule and some of the satellite.accumulation rules on the next slide we.can talk more specifically about a few.of these proposed rule examples so one.of the big things here some companies.would like to be able to consolidate.their ways from several conditionally.exempt small quantity generators sites.for more efficient shipping and.hazardous waste management so what.they're looking at is consolidation at a.large quantity generator under the.control of a single person currently a.wrecker also the rules lack flexibility.to address an episodic change in the.generators regulatory category it's a.very difficult to manage episodic waste.generation under the current rules the.proposed changes would allow generators.to maintain their existing category.provided that they comply with a.streamlined set of requirements so once.a calendar year they would allow an.episodic generation of waste without.jumping into a higher category you would.also have the ability to petition for a.second annual event and this is.important two generators that have tank.cleanouts or or activities such as that.so into summarize I think some of the.things that Laurie talked about earlier.and that I talked about it's important.to know what is your waste and some of.these new regulations claims that as.well you really have to understand and.be able to classify your waste streams.and based on that determine how much you.generate and what your generator status.is after you do that you can properly.manage those ways so keep in mind that.you need to be aware of your excluded.materials special ways your Universal.wastes and of course your hazardous and.your non hazardous waste and as Laurie.stressed it's very important to document.document document and have these waste.classification forms so if you are.managing waste under an exclusion or an.exception that is still documented in.your waste classification and always.think about that long-term liability and.the cradle to grave management of those.materials so if anybody has any.questions that we covered go ahead and.send them in now and if not we're kinda.coming to the close of our time if you.don't if you have a question and that.you didn't want to get added onto the.webinar you can always email us and we.can absolutely get those answered for.you so as of right now Lori and I would.be happy to answer any questions that.anyone might have by email so it's an.exciting time in retro regulation right.now a lot of changes so it's nice to be.able to talk through some of these.changes with people and make sure that.you're managing the waste appropriately.okay and here's our content here's.Laurie and Heather's contact information.for you guys if you do want to send in.your questions and or if you are looking.for some of those charts or forms that.Lori was talking about earlier so.I just wanted to bring up the next event.that we are going to be having it's it's.the actual hazardous waste management.training we're having one in Dallas and.Houston next month and Laura Heather can.you tell give us what the importance of.this training this is an eight-hour.training of course we went to a webinar.what's the importance of the eight-hour.training compared to to this.introduction to some of the regulations.and not really a training course when we.offer the training we really get into.how to identify your waste how to.classify those ways what tests you need.to run how to document those materials.you'll get some examples of some of.these tracking spreadsheets that we've.created you'll be trained on the.internet waste container labeling how to.store the waste satellite accumulation.it's just much more in-depth than what.we went through today and it's important.to keep in mind that as a waste.generator or someone that signs manifest.ship hazardous waste you have a training.requirement so need to check and make.sure that you you keep up to date on.your retro training as well as your DoD.training to be able to sign those.documents excellent and we do have a.price reduction on these classes if you.sign up before September August 16th.which is I'm sorry yeah August 16th or.that is I need to look at my calendar by.the 19th he said by 90 there's a hundred.dollar deduction on there and we are.going to be including a special.registration gift as well so and if you.have any you can get you restaurant at.our website on the events page and then.also here's some other upcoming events.in San Antonio we're having a stormwater.qualified personnel training in San.Antonio Dallas.on the 20th 22nd and the 27th and then.our next webinar is on the 22nd is on.the SPCC plans the five-year updates and.you can also register online at our on.our events page or contact me lance.print l french at wh m calm and i can.help with any questions you have and.just a reminder i'm going to be sending.the recording out probably later this.afternoon so I will send everybody an.email with the link and it'll also.include the slides that we use today so.Heather and Lori thank you so much for.your time today and I just appreciate it.and then thank you for giving us this.great information.thank you have a great day guys.

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Wrecker Monthly Report 2011 Form FAQs

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Am I supposed to report income which is earned outside of the US? I have to fill the 1040NR form.

If you are a US citizen, resident(?), or company based within the US or its territories, you are required by the IRS to give them a part of whatever you made. I'm not going to go into specifics, but as they say, "the only difference between a tax man and a taxidermist is that the taxidermist leaves the skin" -Mark Twain

What tax forms do I need to fill out for reporting bitcoin gains and loses?

IRS 1040 and 1099 forms. “For instance, there is no long-term capital gains tax to pay if you are in the lower two tax brackets (less than $36,900 single income or less than $73,800 married income). The capital gains rate is only 15% for other tax brackets (less than $405,100 single income) with 20% for the final bracket.” Reference: Filing Bitcoin Taxes Capital Gains Losses 1040 Schedule D Other References: IRS Virtual Currency Guidance : Virtual Currency Is Treated as Property for U.S. Federal Tax Purposes; General Rules for Property Transactions Apply How do I report taxes? Filing Bitcoin Taxes C Continue Reading

Do military members have to pay any fee for leave or fiancee forms?

First off there are no fees for leaves or requests for leave in any branch of the United States military. Second there is no such thing as a fiancée form in the U.S. military. There is however a form for applying for a fiancée visa (K-1 Visa)that is available from the Immigration and Customs Service (Fiancé(e) Visas ) which would be processed by the U.S. State Department at a U.S. Consulate or Embassy overseas. However these fiancée visas are for foreigners wishing to enter the United States for the purpose of marriage and are valid for 90 days. They have nothing to do with the military and are Continue Reading

How do I fill out a 1120 tax report?

Are you aware of the many first year elections that you will be making that will effect the future taxation of your business? Carl Heintz has great advice. SEEK YEA A CPA. The form may look innocent enough but this is NOT a DIY project.

I need to pay an $800 annual LLC tax for my LLC that formed a month ago, so I am looking to apply for an extension. It's a solely owned LLC, so I need to fill out a Form 7004. How do I fill this form out?

A2A. FTB extensions are discussed on the FTB website at Page on ca.gov . According to that site, extensions apply to filing but do not apply to making payments.

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