How Toxic Is Your Company

How Toxic Is Your Company?
A step by step guide
For companies in the USA
© 2009 All Rights Reserved.
http://www.TheWestVirginiaLawFirm.com

Does your company produce
hazardous chemicals?
If you don't know check the lists at
http://www.atsdr.cdc.gov/

Do you produce less than 100 Kg
per month?
100 Kg = 220 lbs.
Production of less than this amount
and you can register as a CESQG (a
Conditionally Exempt Small Quantity
Generator) under CERCLA.

Do you produce more than 100 Kg
and less than 1000 Kg per month?
100 Kg = 220 lbs
1000 Kg = 2200 lbs
Production in this range means you
have to register as an SQG Small
Quantity Generator under CERCLA

Do you produce more that 1000 Kg
per month?
1000 Kg = 2200 lbs
Then you have to register as an LQG
Large Quantity Generator under
CERCLA

The Key is Traceability
CERCLA legislation means that
hazardous chemicals must be
traceable from the “cradle to the
grave”. From the moment of creation
of the chemical to the final disposal or
destruction

BEWARE
When you Merge with or Acquire
another company you must look into
their production of hazardous waste
Will their production and yours mean
you need to change your registration?

BEWARE
In a Merger or Acquisition
● Check the history of hazardous
chemicals and their disposal.
● Check any storage of hazardous
chemicals

Are we trying to frighten you?
No, we are trying to get you to think of
the implications of toxic waste
legislation for your current company
and the results of any Merger or
Acquisition activity.

How Toxic Is Your Company

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