Field notes

Questions facility managers
actually ask.

Plain answers first. Regulatory basis, practical tests, and important nuance below.

Current field notes

Maricopa County

Does My Facility Have to Comply with the Maricopa County Travel Reduction Program?

A practical guide to Maricopa County Travel Reduction Program thresholds, annual surveys, plan deadlines, response rates, Task Force review, and enforcement.

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Arizona RCRA

Arizona Is Updating Its Hazardous-Waste Rules. Here Is What to Watch.

A five-minute guide to ADEQ's 2026 rulemaking, the federal updates in scope, and the unanswered question that could affect future fees.

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RCRA air emissions

When Do RCRA Subparts AA, BB, and CC Apply?

Three separate applicability tests for process vents, equipment leaks, tanks, surface impoundments, and containers, including the thresholds and unit-status questions that matter.

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RCRA air emissions

Does a Control Device Simplify RCRA Subpart BB or CC Compliance?

What a closed-vent system and control device replace, what they add, and why the answer differs under Subparts BB and CC.

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Fire code

HMIS vs. HMMP: What's the Difference and Which Does My Jurisdiction Require?

The Hazardous Materials Inventory Statement lists and classifies materials; the Hazardous Materials Management Plan shows where and how they are stored, used, controlled, and accessed.

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RCRA

Is My Wastewater Treatment Unit Exempt from RCRA Permitting? The Three-Part Test and the Dedication Question

The federal wastewater treatment unit exemption depends on a three-part definition, plus EPA's interpretation that the tank system must remain dedicated to an on-site wastewater treatment facility.

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