Hazardous waste disposal plays a critical role in protecting people and the environment from harmful substances. From industrial facilities to small businesses, hazardous waste can be found in many forms, including liquids, solids, gases, and sludges, that require proper handling and management. Without strict safety practices and compliance with regulations like the Resource Conservation and Recovery Act (RCRA), the risks to public health, ecosystems, and communities can be severe.
Every year, industries dispose of or release about 3.36 billion pounds of toxic waste into the environment.
EPA’s Waste Management Program
Under the Resource Conservation and Recovery Act (RCRA), the EPA controls hazardous waste from its creation to its final disposal. This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. The management of hazardous waste falls under Subtitle C of the RCRA. Title 40 CFR Parts 260–273 outlines the regulations for identifying, classifying, generating, managing, and disposing of hazardous waste.
The EPA outlines steps in complying with regulations for hazardous waste disposal, including:
- Identify
- Count
- Notify
- Manage
- Transport
- And, Recycle-Treat-Dispose
Identify
Identify hazardous waste generated. The RCRA has four characteristics of hazardous waste, including:
- Ignitable (EPA D001) – 40 CFR 261.21
- Corrosive (EAP D002) – 40 CFR 261.22
- Reactive (EPA D003) – 40 CFR 261.23
- And, Toxic (EPA D004) – 40 CFR 261.24
The EPA identifies hazardous waste through a specific process. To qualify, the material must first be considered a solid waste. It must either appear on the EPA’s hazardous waste lists or exhibit hazardous characteristics such as toxicity, reactivity, ignitability, or corrosivity. In addition, regulators exclude certain wastes from oversight, and they also remove some from regulation through formal delisting.
Count
Add up the total weight of all hazardous waste (see 40 CFR §262.13(c) and (d)) and determine whether you fall into one of the three generator categories:
- Large Quantity Generators (LQGs) – Generate 1,000 kilograms or more per month of hazardous waste, more than 1 kilogram per month of acutely hazardous waste, or more than 100 kilograms per month of acute spill residue or soil
- Small Quantity Generators (SQGs) – Generate more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month
- Or, Very Small Quantity Generators (VSQGs) – Generate 100 kilograms or less per month of hazardous waste, 1 kilogram or less per month of acute hazardous waste, or less than 100 kilograms per month of acute spill residue or soil
Notify
LQGs and SQGs must notify the EPA, or their state agency if the state runs its own hazardous waste program, about hazardous waste activities using Form 8700-12. Some states also require VSQGs to notify. For help with Hazardous Waste Management Notification and Reporting, contact your state or EPA regional office.
Manage
Manage the hazardous waste according to the specific regulations associated with each generator category. Learn the regulations with which LQGs, SQGs, and VSQGs must comply. Certain waste types and business sectors have unique requirements, such as:
- Universal Waste – Universal waste rules streamline the hazardous waste management standards for batteries, pesticides, mercury-containing equipment, and bulbs
- Pharmaceutical Hazardous Waste – Healthcare facilities, such as pharmacies and hospitals, and retail stores with pharmacies that dispose of pharmaceuticals, may be regulated hazardous waste generators
- And, Hazardous Waste Generated at Academic Laboratories – Standards for managing hazardous waste in laboratories in colleges and universities, teaching hospitals, and nonprofit research institutes that are either owned by or formally affiliated with a college or university
Transport
Any LQG or SQG that transports or offers hazardous waste for off-site transport must use a Manifest. The Hazardous Waste Manifest System website provides forms, reports, and procedures to track hazardous waste from the generator facility to the off-site facility that will store, treat, or dispose of it.
Recycle-Treat-Dispose
Small and large quantity generators may recycle their hazardous waste on-site without a permit IF they comply with the waste accumulation time limits and other waste accumulation regulations specified in 40 CFR sections 262.15-17.
A generator may treat their hazardous waste on-site in a generator accumulation unit without a hazardous waste permit to render it either non-hazardous or less hazardous, provided they comply with all the applicable hazardous waste generator requirements in 40 CFR sections 262.15-17, and provided that the treatment is not thermal treatment.
Otherwise, treatment and disposal of the hazardous waste is subject to the hazardous waste Treatment, Storage, and Disposal Facility (TSDF) regulations of 40 CFR parts 264 and 265 and the permitting regulations of 40 CFR part 270.
Conclusion
Many industries produce hazardous waste, and regulators classify generators based on the amount of waste produced each month, not the size of the business or facility. Under the Resource Conservation and Recovery Act (RCRA), the EPA ensures generators manage hazardous waste safely to protect human health and the environment.