Managing the collection and disposal of hazardous waste is one of your facility’s most important tasks, and the consequences of failing to comply with legal requirements can be stark. With stakes so high, how do you ensure you’re meeting your responsibilities while constrained by budgetary and scheduling pressures?
While a fully certified and knowledgeable waste management provider can help you navigate the fine details of compliance, adopting facility-wide best practices for hazardous waste collection is the most effective way to ensure all employees and facility leaders are on the same page.
Here’s what you need to know about the best practices for managing hazardous waste collection in these key areas:
1. Properly Separating
The integrity of each of your waste streams is dependent on your ability to effectively separate waste categories for proper storage and segregated transport.
The Resource Conservation and Recovery Act (RCRA) specifies that solid waste is any refuse, garbage or sludge resulting from an industrial or manufacturing facility. Whether those facilities are water treatment plants, commercial manufacturers, mining facilities, agricultural operations or even industrially-oriented community activities, RCRA standards apply.
Crucially, “solid waste” is a legal term, not a descriptive one. Accordingly, many legally classified solid wastes may be liquid, semi-solid or even gaseous in actual nature.
A given legally defined material becomes “solid waste” when it is:
In this case, abandoned simply means thrown away or discarded, whether by incineration, recycling or dumping.
Materials dangerous enough to always pose a risk to health or the environment are always defined as solid wastes by regulators. Materials that are “inherently waste-like” include those contaminated with radiation, toxins or other known poisons and dangerous chemicals.
Recycled in Certain Ways
A material that will be recycled becomes legally classified solid waste according to specific definitions and exclusions listed in RCRA. A knowledgeable waste management provider is often the best resource for determining how recycled materials in your facility should be classified.
The RCRA assigns hazardous waste products to one of four legally defined lists: The F List, K List, and P and U Lists. These lists are used to describe specific hazardous qualities of materials and substances, along with the attendant requirements for managing their collection, storage, and disposal.
To legally identify hazardous waste, RCRA focuses on the characteristics of that waste, including toxicity, reactivity, corrosivity, and flammability. In some cases, a material may be classified as hazardous based on a characteristic even when it’s not otherwise included on one of the four lists. Work with your waste management provider to determine when this is the case.
Waste that exhibits radioactive qualities is always classified as a hazardous material.
Over time, the legal framework for managing hazardous waste has carved out a variety of exceptions for some types of waste. These waste products may only be conditionally hazardous, or may still be hazardous but conditionally excluded based on other considerations. Ensuring your facility properly identifies its excluded waste categories is an important step to maintain effective compliance.
2. Properly Storing
The RCRA also lays out a variety of requirements for the proper storage of your hazardous waste materials.
Storage containers cannot be deteriorated or leaking when used for hazardous waste. Any waste stored in such containers must be transferred to compliant containers or otherwise dealt with.
Additionally, hazardous waste cannot be stored in a container that would lead to an “incompatible waste” situation. Waste may be incompatible because it would damage or compromise the container itself, or because the container still contains traces of other substances that might react dangerously with the hazardous waste.
Always consult a fully certified and knowledgeable waste management provider to ensure your containers are safe and compliant for every type of hazardous waste in your facility.
You’re required to properly manage storage containers, ensuring they’re always closed except when in use, and that they are handled and transported in a way that ensures they won’t leak or lose integrity.
Storage containers must be held in a containment area that’s designed to prevent environmental or facility contamination if a leak occurs.
Finally, waste products that have ignitable or flammable characteristics must be stored at least 50 feet from the facility property line to protect neighboring properties.
Storage Quantities and Timelines
The EPA defines limits for both the quantity and length of time that hazardous material is stored in your facility.
For quantity, limits range from 100 kg on-site for conditionally exempt small quantity generators, to 1000 kg or more for larger classifications of waste generators. Additionally, you’re only allowed to keep stored waste on-site for 90, 180, 270, or 365 days, depending on your facility’s generator classification.
Work with your waste management provider to determine your facility’s classification and ensure you comply with those requirements.
Owners or operators of a facility are required to inspect container storage areas at least once per week, unless you’re a Performance Track member facility, in which case you must conduct inspections once per month, as approved by the relevant director.
During these inspections you’re required to inspect containers for leaking, deterioration, corrosion or any other factors that might compromise their integrity.
Though hazardous waste management is a complex process, adhering to the best practices in each of the areas noted above—along with partnering with a fully qualified waste management provider—is the best way to ensure your facility stays compliant.