Hazardous Waste Compliance
The Resource Conservation and Recovery Act (RCRA) created a framework for hazardous waste management and established “Cradle-to-Grave” requirements for the generation, transportation, treatment, storage and disposal of hazardous waste. This meant that businesses would not only be responsible for hazardous waste management at their own facilities but could also be held liable for any mismanagement of their waste once it left the property, even by another company. Most states, including Ohio, have been delegated authority by US EPA to implement the RCRA hazardous waste program in their own states. Since 1995, GT has been dedicated to helping clients achieve and maintain compliance with complex hazardous waste regulations.
Waste Characterization: LQGs, SQGs, and CESQGs
All categories of hazardous waste generators – Large Quantity Generators (LQGs), Small Quantity Generators (SQGs), and Conditionally Exempt Small Quantity Generators (CESQGs)/Very Small Quantity Generators (VSQGs) – are required to evaluate their waste streams to determine if they are hazardous wastes. The first step in determining whether a material is a hazardous waste is to determine if it meets the definition of a waste. A waste is a material that is discarded by disposal, burning, or storing or treating in lieu of discarding. In addition, a waste is any material that will be recycled by being used on the ground, burned for energy, or speculatively accumulated. Some wastes are considered “excluded wastes,” which are specific categories of materials that are not considered wastes or hazardous wastes under US EPA and state hazardous waste regulations.
Once a facility has determined a material is a waste, there are a variety of methods that can be used to determine if the waste is considered hazardous. Laboratory analysis and generator knowledge can be used in conjunction with hazardous waste regulations to assist in making this determination.
Hazardous wastes that are specifically listed in hazardous waste regulations are known as “listed wastes,” and are wastes from common industrial processes (F and K Lists) or are discarded commercial products (P and U lists). “Characteristic wastes” are wastes that exhibit one or more of the following characteristic properties: ignitability (D001), corrosivity (D002), reactivity (D003), or toxicity (D004-D043). Wastes with a hazardous component and radioactive component are called “mixed wastes” and are regulated by both RCRA and the Atomic Energy Act.
GT regularly assists clients with hazardous waste evaluation and characterization to accurately identify and classify hazardous waste and ensure proper waste management.
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Generator Status Determination
The complexity of a facility’s hazardous waste requirements is determined by its generator status, which is based on the amount of hazardous waste generated each month, as well as the amount of hazardous waste accumulated on site. The following table summarizes the three hazardous waste generator categories:
Generator requirements become more stringent as the amount of waste generated and/or accumulate increases. CESQGs and VSQGs have very few requirements and are only required to keep records of waste evaluations and comply with DOT pre-transport requirements. SQGs and LQGs must submit initial notifications to US EPA and obtain an EPA RCRA ID Number. Both types of generators must also comply with container management, satellite accumulation, inspection, emergency response, recordkeeping, pre-transport, and manifesting requirements. Both have accumulation time limits – 180 days for an SQG and 90 days for a LQG. In addition, LQGs must conduct annual personnel training, submit biennial reports, and prepare a written contingency plan.
Through the hazardous waste evaluation process, GT assists clients in determining what to count – and what not to count – toward their generator status and can identify on-site management requirements and disposal options. GT can also identify any exclusions or alternative waste management options that may be available to businesses and provide recommendations for waste reduction strategies that may lessen the regulatory burden on the facility.
Hazardous Waste Management Requirements
GT conducts hazardous waste audits and assists clients in developing comprehensive hazardous waste management programs to ensure compliance with hazardous waste regulations. By reviewing a facility’s current hazardous waste management program, GT can identify gaps in compliance, make recommendations for achieving compliance, and provide best management practices to improve and simplify hazardous waste management. GT can assist with container management, development of waste accumulation/storage areas, weekly inspection logs, as well as other monitoring, recordkeeping, reporting and management practice requirements.
Hazardous Waste Contingency Planning
Large Quantity Generators (LQGs) of hazardous waste are required to prepare and maintain a written hazardous waste contingency plan to minimize the risk to human health and the environment from fires, explosions, or unplanned releases. Contingency plans must be submitted to all local police, fire departments, hospitals, emergency response teams, and US EPA or an authorized state program. GT can assist clients in identifying potential hazards associated with hazardous wastes at their facilities and develop customized contingency plans intended to minimize those risks.
Hazardous Waste Reporting and Notifications
In all states, generators are required to file a biennial report detailing the waste types and quantities generated at their facilities if they reached LQG status during an odd numbered calendar year. In some states, reporting requirements apply to smaller generator categories. Some states have more stringent reporting requirements, such as more frequent reports or required reporting for smaller generator categories. GT assists clients with preparing hazardous waste reports to ensure they satisfy their reporting requirements.
Hazardous Waste Identification Numbers
US EPA and state regulatory bodies require certain hazardous waste generators to submit notifications to obtain identification numbers. Generator ID requirements vary depending on a facility’s generator status (LQG, SQG, or CESQG/VSQG), and whether the facility transports its own waste. Generator ID requirements can also vary from state to state. GT helps clients navigate these requirements to ensure all applicable notifications are complete.
Hazardous Waste Training
LQGs are required to conduct initial and annual training for all employees involved with hazardous waste management, and must maintain detailed documentation related to personnel training. GT can provide site-specific hazardous waste training and provide documentation to ensure companies are in compliance with the hazardous waste training regulations.
Universal Waste Requirements
Universal wastes are specific types of hazardous waste that, if handled properly, can be managed under a less complex set of regulations than hazardous wastes. Examples of universal wastes include waste lamps, pesticides, mercury-containing equipment, and discarded batteries. Some states, such as Ohio, also regulate additional state-specific universal waste categories, such as antifreeze, aerosol containers, paint, and paint-related waste. Universal waste requirements allow for a one-year accumulation time limit, and eliminate the need to perform waste evaluations, maintain manifests, and use a hazardous waste transporter. In addition, because universal wastes are not required to be counted toward a generator’s status, managing wastes as universal waste can reduce a facility’s monthly hazardous waste generation, and potentially reduce its generator status. GT works with Small and Large Quantity Handlers of universal waste to identify which requirements apply to their facilities and helps develop and implement universal waste programs that ensure compliance with universal waste regulations, promote proper recycling, and reduce regulatory burden.
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