DEQ Misinterprets Used Oil

Federal regulations promulgated at 40 CFR 260.10 and at 40 CFR 279.1 define “used oil” as “any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities.”  Oregon’s...

Ask Not for Whom the All Appropriate Inquiry Standard Tolls…

Did you know that the All Appropriate Inquiry (aka “due diligence” or “innocent purchaser”) standard now applies to persons who purchase land for any “commercial” purpose? That includes residential properties purchased as investment rentals or for development. Before...

Do you “designate as” dangerous waste?

What’s in a name? Did you know that, according to the Department of Ecology, anything you “designate as” a dangerous waste is regulated as a dangerous waste? It has long been the practice of generators of solid waste to label certain wastes as “dangerous” (or...