Industrial Hazardous Waste Recycling
Written by Steve Hudgik February 2013
The EPA provides regulatory relief for many types of waste recycling. As a result, when waste materials are recycled, regulatory and compliance costs for industry are reduced. In addition, safe recycling of industrial hazardous waste helps:
- reduce costs
- meet corporate environmental stewardship goals
- protect the environment
- improve your community and brand image
To recycle industrial hazardous waste, follow these steps:
Industrial Hazardous Waste Recycling
1. Determine How The Waste Is Regulated
Not all waste is classified as a solid waste. And not all solid wastes are hazardous wastes. In addition, some hazardous wastes are exempt from regulation or are regulated under alternative regulations. For information on determining whether a material is a solid waste, and whether it can be recycled under RCRA Subtitle C.
Industrial Hazardous Waste Recycling
2. Choose A Responsible Recycler
Always use a waste recycler who is responsible and capable of handling the hazardous materials your facility generates. Also be sure to use a recycler who is legitimately recycling those materials.
Hazardous waste generators use various methods for evaluating a potential recycler. For example, they may audit recyclers to ensure there have the capability to safely handle and process certain hazardous secondary materials. Some common questions generators may ask are:
- What is the recycling facility's site and ownership history?
- Has there been any previous recycling activity or contamination at the recycler's location?
- Does the recycler have a history of environmental compliance?
- Has the recycler been subject to any enforcement actions?
- Is the recycler's facility currently in compliance with all required permits?
- What is the general housekeeping like at the facility?
- Does the recycler use responsible waste processing practices, such as waste screening?
- Do they have acceptance procedures, residuals management, drop-off and tracking protocol, and certificates of recycling?
- Is the recycling company financially sound?
- Does the recycler have adequate pollution liability insurance and provisions for necessary facility closure and cleanup costs if necessary?
Industrial Hazardous Waste Recycling
3. Confirm That Your Waste Will Be Legitimately Recycled
Some recyclers may claim that they are recycling a material only so they can avoid being subject to RCRA regulation, when they actually are not doing recycling. The EPA calls this practice "sham recycling." The EPA determines whether an activity is legitimate recycling based on a number of factors. One of the key factors the EPA looks at is whether the secondary material can actually be used for the claimed use. For example, if the amount of secondary material produced by recycling is in excess of what can actually be used, recycling is not taking place.
The determination of whether legitimate recycling is taking place is based on the facility's records of their recycling transactions. However, making an accurate determination can be difficult. It involves assessing the intent of the recycler by evaluating circumstantial evidence. Key considerations regarding this determination include:
- Is the secondary material similar to an analogous raw material or product?
- What degree of processing is required to produce a finished product?
- What is the value of the secondary material?
- Is there a guaranteed market for the end product?
- Is the secondary material handled in a manner consistent with the raw material or product it replaces?
The EPA has provided some examples of "sham" recycling. These include:
- The recycled material is ineffective or it is only marginally effective for the claimed use. For example, when certain heavy metal sludges are used in concrete, those sludges do not contribute any significant element to the concrete's properties.
- If the recycled material is used in excess of the amount necessary. For example, using recycled materials containing chlorine as an ingredient in a process requiring chlorine, but in using them in excess of the required chlorine levels.
- If the recycled material is handled in a manner that is not consistent with its use as a raw material or commercial product substitute. For example, the recycled materials are stored in a leaking surface impoundment, when normal raw materials are stored in a tank in good condition.
Industrial Hazardous Waste Recycling
4. Participating in an EPA Program
The EPA has two programs that may be helpful
WasteWise
Wastewise helps organizations reduce waste and implement sustainable materials management practices. It focuses on eliminating waste (prevention) and the recycling of municipal solid waste and select industrial materials.
Organizations can join Wastewise as a partner, endorser, or as both. Partners demonstrate how they reduce waste, practice environmental stewardship, and incorporate sustainable materials management into their waste-handling processes. Endorsers promote enrollment in WasteWise as part of helping their stakeholders realize the economic benefits of reducing waste.
WasteWise is a free, voluntary EPA program.
Coal Combustion Products Partnership (C2P2)
The Coal Combustion Products Partnership (C2P2) is a cooperative effort between the EPA, the American Coal Ash Association, the Utility Solid Waste Activities Group, the DOE, the Department of Agriculture-Agricultural Research Service, the Federal Highway Administration, and the Electric Power Research Institute. The objective is to promote the beneficial use of coal combustion products (ash resulting from burning coal) and the environmental benefits that result from their use. For example, some coal ash has properties similar to concrete, and it can be used as a component in concrete used for highways.
Industrial Hazardous Waste Recycling
5. Keep Track of Your Recycling Success
Measuring, keeping records and reporting on your recycling efforts delivers two important benefits.
Reducing waste is not just about protecting the environment, it is a cost effective approach to becoming more competitive and improving profits. For example, the underlying principle that forms the foundation of lean manufacturing practices is that of reducing and eliminating waste. Accurate record keeping and reporting allows you to identify those waste reduction practices that are working well, and those that need further improvement. In addition, you'll be able to see the ROI resulting from waste reduction, providing the justification for further improvements in this area.
Tracking and reporting of waste reduction and recycling performance also shows investors, and other stakeholders, that the company is not in violation of environmental regulations, and, thus are not at risk for fines and penalties related to safety, health, or environmental concerns. In addition, through public relations, organizations can promote environmental successes, build an environmentally friendly reputation, and establish themselves as an environmental leader.
