Hazardous Waste Management
Written by Steve Hudgik February 2013
Hazardous waste management refers to the planning and activities involved in identifying, reducing, handling, recycling, and disposing of hazardous waste.
The EPA uses the amount of hazardous waste generated per month to define three categories of hazardous waste generators:
- Conditionally exempt small quantity generators (CESQGs) are those who generate less than 220 pounds of hazardous waste per month.
- Small quantity generators (SQGs) generate between 220 pounds and 2,200 pounds of hazardous waste per month.
- Large quantity generators (LQGs) generate more than 2,200 pounds of hazardous waste per month.
Organizations in each of these three categories must comply with the hazardous waste rules specific to that category.
Hazardous Waste Management - Which Category Are You In?
The EPA definition of a waste is: any solid, liquid, or contained gaseous material that is discarded by being disposed of, burned or incinerated, or recycled. A waste may be a byproduct of a manufacturing process or it could be a commercial product such as a cleaning fluid or battery acid. In some cases materials that are recycled or reused, such as burning solvents as a fuel, might be regulated as a hazardous waste.
Which wastes are hazardous wastes?
There are two ways to determine if a waste is a hazardous waste. One is if the waste appears on a list published by the EPA. The other is if the waste has any of four characteristics of hazardous waste.
Waste is considered hazardous if it is on one of four lists published in the Code of Federal Regulations (40 CFR Part 261). Wastes are placed on these lists because they have been determined to be harmful to human health or the environment when they are not managed properly. Even when managed properly, some listed wastes are so dangerous that they are called acutely hazardous wastes.
If the waste does not appear on one of the four hazardous waste lists, it may still be regulated as hazardous if it has one or more of the following characteristics:
- It will burn under certain specified conditions. This is known as an ignitable waste. Examples include some paints, degreasers and solvents.
- The waste will corrode metal or has a very high or low pH. This is known as a corrosive waste. Examples include rust removers, acid or alkaline cleaning fluids, and battery acid.
- The waste is unstable, explodes or produces toxic fumes, gases, and vapors when mixed with water or under conditions such as heat or pressure. This is known as a reactive waste. Examples include some cyanides and sulfide-bearing wastes.
- It is harmful or fatal when ingested or absorbed. Or the waste leaches toxic chemicals into the soil or ground water when disposed of on land. This is known as a toxic waste. Examples are wastes that contain high concentrations of heavy metals, such as cadmium, lead, or mercury
If your waste is either listed, or has the characteristics of a hazardous waste, it will need to be managed according to appropriate federal regulations.
What category are you in?
If your organization generates hazardous waste, the next step is to measure the amount of waste produced per month. The amount of hazardous waste generated determines which category applies to your organization.
Some hazardous wastes are liquids and are measured in gallons. These need to be converted to pounds in order to determine the hazardous waste generator category. To make this conversion the density of the liquid must be known. A rough guide is the density of water. About 30 gallons of water weigh 220 pounds. 300 gallons of a waste with a density similar to water weighs about 2,200 pounds.
Hazardous Waste Management - Conditionally Exempt Small Quantity Generators (CESQG)
An organization is in the CESQG category, if it generates less than 220 pounds of hazardous waste per month. Organizations in the CESQG category are exempt from hazardous waste management regulations, provided they comply with some basic requirements.
However, if your organization generates or stores more than 2.2 pounds of acutely hazardous waste, or more than 220 pounds of acutely hazardous spill residues, it must be managed according to the LQG requirements (see below).
Conditionally Exempt Small Quantity Generators must comply with three basic waste management requirements:
- They must identify all hazardous waste that they generate.
- They may not store more than 2,200 pounds of hazardous waste on site at any time.
- They must ensure the delivery of the hazardous waste to an off-site treatment or disposal facility or, if they treat or dispose of the hazardous waste on site, their facility most be:
- A state or federally regulated hazardous waste management treatment, storage, or disposal facility.
- A facility permitted, licensed, or registered by a state to manage municipal or industrial solid waste.
- A facility that uses, reuses, or legitimately recycles the waste. Or a facility that treats the waste prior to use, reuse, or recycling.
- A universal waste handler or destination facility that is subject to the universal waste requirements of 40 CFR Part 273.
Hazardous Waste Management - Small Quantity Generators (SQG)
You are considered an SQG if you generate between 220 and 2,200 pounds of hazardous waste per month. SQGs must comply with EPA requirements, some of which are summarized below.
Hazardous Waste Management - Large Quantity Generators (LOG)
A waste generator is considered an LQG if they generate more than 2,200 pounds per month of hazardous waste. LQGs must comply with more extensive hazardous waste rules than those described in this article.
Hazardous Waste Management - Temporary Storage Of Waste On-Site
Most businesses accumulate some hazardous waste on-site for a short period of time and then ship it off site to a treatment, storage, or disposal facility.
Hazardous waste many only be stored on-site for a short period without a permit. During this time the waste generator is responsible for using proper hazardous waste management practices. This includes safe storage, safe treatment, preventing accidents, and responding to emergencies in accordance with federal regulations.
SQGs can store up to 13,228 pounds of hazardous waste on-site for up to 180 days without a permit. If the waste must be transported than 200 miles away for recovery, treatment, or disposal, the waste may be stored on-site for up to 270 days. Limited extensions of this time period may be granted in special cases by the state director or the regional EPA administrator. If hazardous waste storage limits are exceeded, you'll be considered to be a Treatment Storage and/or Disposal Facility (TSDF) and will need to obtain a TSDF operating permit.
Wastes generated in small amounts throughout a facility may be stored in satellite accumulation areas located at or near the point of generation of the waste. The total amount of waste that may be accumulated at a satellite area is limited to 55 gallons. Once this quantity has been exceeded, it must be transferred within three days to the designated 180-day (or 270-day) storage area. Smaller quantity limits apply to acutely hazardous wastes.
SQGs must accumulate waste in tanks or containers such as 55-gallon drums. Storage containers must be managed according to the following EPA requirements:
- Labels on each container must have the words “HAZARDOUS WASTE” and include the date the waste was generated. DuraLabel printers are commonly used to make these labels.
- The container must be made of, or lined with, a material that is compatible with the hazardous waste to be stored, such that the waste is prevented from reacting with or corroding the container.
- Keep all hazardous waste containers closed, except when adding or removing waste. Do not open, handle, or store containers in any way that might result in a container rupturing, leaking, or otherwise failing.
- Conduct weekly inspections of areas where containers are stored. Look for leaks, deterioration, unreadable or missing labels, and improper storage of containers.
- Maintain all containers in good condition. If a container should leak, put the hazardous waste in another container. Always contain the hazardous waste in a way that complies with EPA regulations. Do not mix incompatible wastes or materials unless all necessary and required precautions are taken.
Hazardous Waste Management - Waste Minimization
The best approach to hazardous waste management is to not to generate hazardous waste, or to generate less hazardous waste. The amount of hazardous waste that is generated can be reduced by developing good waste practices. These include:
- Do not mix nonhazardous waste with hazardous waste. Once anything is mixed with a hazardous waste, the entire batch becomes hazardous increasing the amount of hazardous waste. Mixing wastes can also make recycling difficult, if not impossible.
- Change materials, the processes, or both to eliminate the production of hazardous waste. Replacing a material or a process with another that produces less waste not only reduces hazardous waste, it typically will save money. An example is using plastic blast media for paint stripping of metal parts rather than conventional solvent stripping.
- Recycle and reuse materials. Put useful components back into productive use rather than disposing of them. Materials such as oil, solvents, acids, and metals are commonly recycled and used again.
- Safely store containers to prevent spills and leaks, and thus prevent the creation of additional hazardous waste. Store hazardous product and waste containers in secure areas, and inspect them frequently for leaks. When leaks or spills occur, materials used to clean them also become hazardous waste.
- Make a good faith effort to reduce the amount of hazardous waste. SQGs do not have to document their waste minimization activities nor create a waste minimization plan. However, when the waste is shipped off-site, SOGs must certify on the manifests that a good faith effort to minimize waste generation has been made.
Hazardous Waste Management - Shipping Waste Off-Site
SQGs must follow specified shipping procedures that are designed to ensure safe transport and management of hazardous waste.
SQGs may only send their hazardous waste to regulated Treatment, Storage, and Disposal Facilities (TSDF) or to a regulated recycler. Most regulated TSDFs and recyclers will have a permit from the EPA or the state in which they are located. However, some operate under other regulations that do not require a permit. Check with state authorities to be sure the facility you select has all of the necessary permits. All TSDFs and recyclers must have EPA identification numbers.
SQGs are responsible for properly packaging, labeling, and marking all hazardous waste shipments. In addition, they are responsible for compliance with DOT regulations for placarding the vehicles in which the wastes are shipped. Most small businesses use a commercial transporter to ship hazardous waste. These transporters can provide advise on the requirements for placarding, labeling, marking, and packaging. However, the generator of the waste remains responsible for compliance.
Federal regulations allow SQGs to transport their own hazardous waste to a designated TSDF, provided they comply with DOT regulations. However, some states do not allow this practice. Contact the DOT and your state hazardous waste management agency to learn about the hazardous waste transportation regulations that apply in your state.