What is a hazardous waste?
A hazardous waste is any waste, or combination of wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may either:
- Cause or significantly contribute to an increase in mortality or an increase in a serious irreversible, or incapacitating reversible illness, or
- Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
Hazardous wastes can be liquids, solids, or contained gases. They can be the by-products of manufacturing processes, discarded used materials, or discarded unused commercial products, such as cleaning fluids (solvents) or pesticides.
How do I determine if the waste I generate is hazardous?
RCRA, the Resource Conservation and Recovery Act, established the framework for the proper management of non-hazardous and hazardous waste. This law describes the waste management program mandated by congress that gave the EPA authority to develop the RCRA program. Hazardous waste regulations are found in Title 40 CFR parts 260 through 273. The process of determining if a waste is a hazardous waste is called the "hazardous waste determination”. Although they may meet the definition of hazardous waste, some wastes are specifically excluded or exempted from regulation as hazardous waste (e.g., chlorofluorocarbon (CFC) refrigerants that are reclaimed for reuse). Endpoint Waste Solutions has experts on staff that can assess your waste stream and assist you with your waste determination process.
How do I determine if my business is a hazardous waste generator and what is my generator status?
There are three categories your facility can fall into. Very Small Quantity Generator (VSQG) generates 220 pounds (100 kilograms) or less of hazardous waste per month.
Small Quantity Generator (SQG) generates more than 220 pounds (100 kilograms) but less than 2200 pounds (1000 kilograms) of hazardous waste per month.
Large Quantity Generator (LQG) generates 2200 pounds (1000 kilograms) or more of hazardous waste per month.
There are things that can impact what wastes or materials are counted toward your generator status. Recycling and reclamation, for example, MAY reduce what gets counted toward generator status. The generation of 2.2 pounds (1 kilogram) of an acute hazardous waste* in a calendar month will place a generator in LQG status. Contact Endpoint Waste Solutions personnel for assistance determining your status if you have questions.
*An acute hazardous waste is a waste that carries a P-code, which is found in 40 CFR 261.33.
Endpoint Waste Solutions can help you evaluate what generator status category you fall into.
Who needs to get an EPA ID Number?
Large Quantity Generators and Small Quantity Generators need to acquire an EPA Identification (EPA ID) number using EPA form 8700-12. The below link has information and forms needed to obtain an EPA ID number. Very Small Quantity Generators are not required to obtain an EPA ID Numbers.
https://rcrapublic.epa.gov/rcrainfoweb/documents/rcra_subtitleC_forms_and_instructions.pdf
Endpoint Waste Solutions experts can help guide you through the process of obtaining an EPA ID number.
As a hazardous waste generator, what are my training obligations?
For Large Quantity Generators, all “Hazardous Waste Personnel” that is, “all persons who work at, or oversee the operations of, a hazardous waste facility and whose actions or failure to act may result in noncompliance with the requirements (of the RCRA regulations)", need training. RCRA training must be completed within 6 months of hiring or assignment to the facility. Personnel must also complete an annual RCRA refresher training and cannot work unsupervised until completed.
For Small Quantity Generators, hazardous waste personnel, must be “thoroughly familiar” with proper waste handling and emergency procedures. Annual refreshers are recommended.
For Very Small Quantity Generators, no specific training is required, but personnel should be able to keep hazardous waste in compliance with State and Federal Laws.
Endpoint Waste Solutions can provide all the required training your company needs.
Are there limits on how much waste I can store or how long I can store it?
Large Quantity Generators can store any quantity of waste onsite for up to 90 days. Small Quantity Generators can store up to 13,200 pounds (1,500 to 1,620 gallons) waste onsite for up to 180 days (or 270 days if transporting greater than 200 miles). Very Small Quantity Generators May accumulate up to 2,200 pounds (about 270 gallons) for an indefinite period of time. Many Small Quantity Generators choose to dispose of their hazardous waste annually.
What are the requirements for containers storing hazardous waste?
All containers storing hazardous waste must be:
- In good condition (i.e., no rusting, bulging, and structurally sound)
- Compatible with the stored waste
- Properly labeled
- Located at least 50 feet from property lines for ignitable or reactive wastes
- Kept closed unless you are adding or removing wastes, and
- Inspected weekly for leaks and deterioration
Flammable wastes:
- Flammable wastes must be stored in containers that are electrically grounded. Bonding connections must be made when transferring flammable liquids between metallic containers.
- You should contact your local Fire district for more information on grounding and storage requirements for flammable wastes.
Reactive/incompatible wastes:
- Reactive wastes must be stored separately, or be separated by a dike, berm, wall, or other barrier to prevent any reactions with other wastes.
If hazardous waste is being stored in a damaged container, or begins to leak, it must be immediately transferred into a container that is in good condition. The container must be compatible with the waste it contains i.e. not react with the waste.
Endpoint Waste Solutions experts can provide the appropriate containers for your waste.
What are some common examples of hazardous wastes produced in businesses?
Here are some common examples of hazardous wastes:
- Acid Solutions: battery acid, metal plating waste, etching residue, pickling liquor
- Alkaline Solutions: metal plating and cleaning waste, soda ash, sodium or calcium hydroxide
- Asbestos: friable and/or crumbling forms of asbestos from insulation products, old pipe lagging, asbestos pipe waste.
- Ashes: oil ash, kiln and oven residue
- Miscellaneous: Drilling mud, explosives, chemical toilet waste, printing ink, bag house wastes, fly ash, waste chemicals, dyes, out dated stock, and mine tailings.
- Monomer Waste/Polymeric Resin: Incompletely reacted resin, resin rinse water.
- Organic Liquids/Solids: Fuel, paint thinner, paint remover, paint, dry cleaning fluids and filters.
- Pesticides: Unusable portion of active pesticides, unrinsed empty containers, rinse water.
- Photo Processing Waste: Developer, fixer, hypo solutions.
- Polychlorinated Biphenyls: contaminated electric capacitors, ballasts, transformer fluids.
- Sludges: Paint, degreasing, caustic, paper, metal pickling, acetylene, lime, metal machine coolant, tanning sludges.
- Solids & Solutions: Cyanide, azide, hypochlorite, sulfide, fluoride, anti-corrosion fluids, antifreeze, metal and equipment cleaning solutions, heavy metals in powdered or solution form including antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium and zinc.
- Solvents: Acetone, methylene chloride, methyl ethyl ketone, benzene, Stoddard, perchloroethylene, dry cleaning fluids, trichloroethylene, styrene, xylene, unspecified solvent mixtures.
- Waste oil / mixed oil: Motor oil, cutting oil, lube oil, bunker oil, sulfonation oil, oil and water, hydraulic fluid, transmission fluid mixtures.
Below are wastes are often incorrectly disposed of as non-hazardous but are still considered hazardous waste:
- Metal dusts/grindings
- Finely divided metal grindings may be toxic because they can contain heavy metals (like barium, cadmium, chromium, copper, lead, nickel, zinc, etc).
- Cannot be disposed of to the trash.
- Are presumed to be hazardous wastes unless proven otherwise by state certified lab analysis.
- Metal sludge, dusts, fine powders with a diameter of less than 100 microns (about the diameter of a human hair), or semi-solids are potentially hazardous waste.
- Metal workings, cuttings, shavings or grindings with a diameter of more than 100 microns (about the diameter of a human hair) are considered to be scrap metal and are not hazardous waste.
- Paint booth filters
- May be toxic because they can contain heavy metals (like barium, cadmium, chromium, copper, lead, nickel, zinc, etc).
- Cannot be disposed of to the trash.
- Are presumed to be hazardous wastes unless proven otherwise by state certified lab analysis.
- Paint sanding dusts
- May be toxic because they can contain heavy metals (like barium, cadmium, chromium, copper, lead, nickel, zinc, etc).
- Cannot be disposed of to the trash.
- Is presumed to be hazardous wastes unless proven otherwise by state certified lab analysis.
- Used absorbents
- Spent absorbents used to soak up hazardous materials or hazardous wastes:
- Cannot be disposed of to the trash.
- Are presumed to be hazardous wastes unless proven otherwise by state certified lab analysis.
- Used fabric rags
- Are not hazardous waste as long as they are not overly saturated and are picked up regularly by an industrial laundry.
Endpoint Waste Solutions experts can help you determine which wastes are hazardous.
What recordkeeping is required for my waste streams?
Recordkeeping requirements for LQGs are found at 40 CFR 262.40-262.43. 40 CFR 262.44 codifies the requirements for SQGs. Conditionally Exempt Small Quantity Generators have very few record keeping requirements. However, keep in mind that a state, county or local jurisdiction may have more stringent requirements. The summary table on this EPA webpage (https://www.epa.gov/hwgenerators/hazardous-waste-generator-regulatory-summary#table) is a good starting point.
What is the difference between universal waste and hazardous waste?
Universal waste is commonly generated hazardous wastes that don’t present a high level of hazard (when properly managed). The EPA instituted the universal waste program to ease the burden of management of these types of wastes. Four types of waste are covered by the universal waste program. They include:
- Batteries-Intact batteries (except spent lead acid batteries and other batteries specifically managed under other regulations).
- Lamps-Bulbs that contain mercury i.e. fluorescent bulbs, high intensity discharge (HID), neon, mercury vapor, high pressure sodium and metal halide lamps.
- Mercury-containing equipment-any device that contains mercury, such as thermometers and thermostats.
- Pesticides-Products used to prevent, destroy, repel or mitigate pests.
Wastes that are managed as universal waste can be stored for up to a year and are not required to be shipped with a manifest. Also, universal wastes do not need to be counted towards the hazardous waste total for the purpose of determining whether it is a VSQG, SQG, or LQG. Universal wastes should still be managed in a way to prevent releases to the environment, have proper labeling, and they should be transported to a facility that is permitted or otherwise designated for receiving hazardous waste.
What are e-Manifests?
E-Manifests are simply electronic manifests. The EPA instituted the e-manifest system nationally to make tracking hazardous waste easier, cheaper and more efficient. The program was launched on June 30, 2018. The e-Manifest program has been estimated to reduce hours that would have been associated with paper manifests by between 175,000 and 425,000 hours, thusly saving state and industry users more than $50 million annually.
What is Waste Minimization?
Waste minimization refers to using source reduction (i.e. using less hazardous materials in the process’s feedstock or reorganizing a work flow to reduce the number of cleaning operations) and/or environmentally sound recycling methods prior to the treatment or disposal of waste. US EPA’s preferred hierarchy for waste management is: 1. Source Reduction 2. Recycling 3. Energy Recovery 4. Treatment 5. Disposal
https://www.epa.gov/trinationalanalysis/pollution-prevention-and-waste-management
What are the benefits of Waste Minimization?
Simply put, money and time. The reduction of the quantity and toxicity/hazard of waste protects the environment along with the people, plants and animals that live in it.
Waste minimization practices can help you change the RCRA regulatory status of your business from that of an LQG down to an SQG or even an CESQG. Each step down the generator status hierarchy reduces the regulatory burden on your business.
Waste minimization can potentially reduce liability and it can increase production efficiency and profits. Environmental performance, overall environmental sustainability, and perception by neighbors and others within industry can also be improved with effective waste minimization measures.
How do I properly handle/dispose of a container with unknown contents?
The storage, transportation or disposal of waste with unknown contents are prohibited by federal, state and local regulations. All waste generated must be accounted for from “cradle to grave”. There are very significant penalties for submitting hazardous waste for transportation or disposal without an accurate identification. Waste disposal companies will not accept waste with unknown contents without proper testing and analysis. Types of testing on unknown waste include:
- Ignitability: If the unknown is liquid, this should include a flash point test.
- Corrosive: If the unknown is liquid, this should include a pH test. (pH paper can be used for an approximation but it is not a definitive method.)
- Reactivity: The unknown will be tested for air and water reactivity.
- Toxicity: The Toxicity Characteristic Leaching Procedure (TCLP) for chemical analysis used to determine whether or not a material is hazardous (D-List). The method simulates the process of leaching through a landfill and is one of the more common hazardous waste tests. If any of the waste tested using the TCLP method fails the test for one or more of the compounds listed in 40 CFR 261.24, the waste is considered hazardous, unless there is an exemption that may be applied.
Endpoint Waste Solutions can perform all the needed testing on unknown wastes.
What should I do with used oil?
Used oil management standards are outlined in CFR part 279. Oil (crude or synthetic) is considered used when it has been “contaminated by physical or chemical impurities.” Contaminates can be anything including, dirt, water, metal dust, or chemicals. Used oil can be collected, filtered and recycled repeatedly.
- The EPA estimates that 380 million gallons of used oil are recycled each year.
- About one-third the energy is required to re-refine used oil compared to refining crude oil.
- It only takes one gallon of used oil to produce 2.5 quarts of high-quality lubricating oil, as opposed to 42 gallons of crude oil to produce the same amount.
- 140,000 (BTUs) of energy are created from one gallon of used oil.
Used Oil Storage: Mark containers, tanks, drums, totes, etc. as “Used Oil”. Keep all containers in good condition. If they start to deteriorate, replace to avoid leaks and spills. Containers do not need to be RCRA rated, but do need to be in good condition and labeled as Used Oil.
Used Oil Leaks and Spills: Take care to prevent leaks and spills at your facility by:
- Keeping containers, tanks and machinery in good condition
- Carefully transfer used oil and have sorbent material available onsite in case of an accidently spill while transferring
- Store your used oil separately from hazardous materials (i.e. solvents and chemicals) and don’t mix the used oil with anything to help prevent it form becoming contaminated
- Facilities may be subject to Spill Prevention, Control and Countermeasures (SPCC) requirements (40 CFR part 112)
Endpoint Waste Solutions can pick up and recycle your used oil, help interpret used oil regulations, supply sorbent materials, and even put together an SPCC plan for your facility.
What about SDSs, profiles and waste manifests?
SDSs-Safety Data Sheets (previously called MSDSs) communicate the hazards of a material/product. The Hazard Communication Standard (HCS) developed by OSHA requires chemical manufacturers, distributors, or importers to provide SDSs. SDSs are extremely helpful when creating a hazardous waste profile, so please save them even after you have finished using the hazardous material. Having an SDS can help avoid additional testing in many cases.
The EPA requires facilities to create a Hazardous Waste Profile, aka waste characterization profiles for any of hazardous waste removal and it must be presented to the disposal facility. Hazardous Waste Profiles, requires you to list the chemical properties of the waste you intend to transport or dispose of, which is why an SDS is so useful.
Hazardous waste manifests (whether paper or e-manifests) track hazardous waste from the time it leaves the generator facility, until it reaches the off-site waste facility that will store, treat or dispose of the hazardous waste, a “cradle-to-grave” system.
Hazardous Waste Manifests, are required by the EPA and the Department of Transportation (DOT) for all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage or disposal.
What about waste transportation, hauling, packaging and waste containers?
Endpoint solutions can help your facility with all waste transportation, waste hauling, waste packaging, and waste containers needs.
What if I don’t know where to start when it comes to my waste needs?
Endpoint Waste Solutions experts can come onsite and do an inspection of your entire facility to help determine the best solutions for your all solid waste, recycling, hazardous waste, pharmaceutical waste, and waste reduction/beneficial reuse needs. We can tailor any plan to your project is too big or too small for Endpoint Waste Solutions. We can also do environmental reporting (Hazardous Waste Reporting, Air Emissions Reporting, Form R, Tier II) and put together other plans needed at your site (Spill Prevention, Control and Countermeasure, Storm Water Pollution Prevention, Process Safety Management, Risk Management Prevention) and more!