Hazardous Waste Terms

A Solid Waste is a Discarded Material (that is not exuded by regulation). A Discarded Material is Abandoned, Recycled, inherently waste-like, or a Military munition.

A solid waste is Abandoned if it is:

• Disposed of,
• Burned or Incinerated,
• Accumulated, stored, or treated (not recycled) before or in lieu of being abandoned by being disposed or, burned, or incinerated.
• Also see Discarded Material

A generator may accumulate hazardous waste for a short period of time before managing it on-site or shipping it off-site. The waste must be accumulated in either tanks, containers or drip-pads; it may not be accumulated in surface impoundments.

There are two kinds of Accumulation:

• see Satellite Accumulation Area
• see Hazardous Waste Storage Area (Central Accumulation Area

Waste accumulation time depends on your generator status (see below). Generators may receive a 30-day extension for the accumulation of hazardous waste if uncontrollable and/or unforeseen circumstances cause them to accumulate waste on site for longer than the permissible time. Such an extension cay be granted by a Regional Administrator or authorized state.

• Small Quantity Generators (SQG) may accumulate/store waste for no more than 180 days, unless the waste must be transported 200 miles or more to a TSDF: then the limit is 270 days.
• Large Quantity Generators (LQG) may accumulate/store waste for no more than 90 days.

Are Hazardous Wastes that have been determined to pose a severe risk to human health and the environment even when properly managed.

Acute Hazardous Waste are toxic to humans in low doses and/or short exposure times.

Small quantities of Acute Hazardous Waste can subject facilities to the more stringent regulatory requirements. A generator who accumulates >2.2 lbs. of acutely hazardous waste would become a large quantity generator (LQG).

Acute Hazardous Wastes include all P-Listed hazardous wastes as well as those F-Listed wastes (F020-F023 and F026-F027) from non-specific sources that are dioxin-related

Are regulated by the U.S. Environmental Protection Agency (EPA) under the Resource Conservation & Recovery Act (RCRA)

Oregon – All small and large quantity hazardous waste generators are required to submit an annual report to DEQ. The report is due March 1st of every year and provides information on activities of the previous calendar year.

Washington – The dangerous waste annual report is a combination of required forms and other documents that summarize your dangerous waste activities in Washington state. If you have an active EPA/State Identification (ID) Number, then you must submit a dangerous waste annual report. Reports are due March 1 each year.

Idaho – Hazardous Waste Generator Annual Reports are submitted by all large quantity hazardous waste generators (LQGs) and small quantity hazardous waste generators (SQGs), as and commercial hazardous waste disposal facilities. Reports are due March 1 each year.

Utilization or reuse of a material that would otherwise have become a Solid Waste. Such as reusing a spent material as an ingredient in an industrial process to make a product or as an effective substitute for a commercial product, without reclamation.

• Examples include: landfill cover, aggregate substitute, fuel substitute or the feedstock in a manufacturing process.

EPA – Beneficial reuse is reusing a waste material, that would otherwise be discarded, in a manner that makes it a valuable commodity.

Oregon – Beneficial use of solid waste is a sustainability practice that involves using a waste in a manufacturing process to make another product or using it as a substitute for construction materials.

• • Oregon DEQ has standing beneficial use determinations and makes other beneficial use decisions on a case-by-case basis.
  • Beneficial use is defined as “the productive use of solid waste in a manner that will not create an adverse impact to public health, safety, welfare, or the environment.”

The treatment technology that best lessens or reduces the toxicity and/or mobility of the hazardous constituents for a particular waste.

A report submitted by Small (SQG) and Large Quantity Generators (LQG) who ship hazardous waste off-site to a treatment, storage, disposal (TSD) facility must prepare and submit a Biennial Report that summarizes their hazardous waste generation in terms of the nature, type, quantity, disposal method, and composition of their waste.

It provides the EPA and states the quantities of hazardous waste generated and the movements of those hazardous wastes.

The Biennial Report form (EPA form 8700-13A/B) must be submitted to the authorized state agency or EPA regional office by March 1 of every even-numbered year.

The report includes the following information:

• The EPA identification number, name, and address of the generator.
• The calendar year covered by the report
• Your EPA identification number, name, and address for each off-site treatment, storage, or disposal facility to which waste was shipped
• The name and EPA identification number of each transporter used
• A description, EPA hazardous waste number (from 40 CFR part 261, subpart C or D), DOT hazard class, and quantity of each hazardous waste shipped off-site
• A description of the efforts undertaken during the year to reduce the volume and toxicity of waste generated.
• A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years
• The certification signed by the generator or authorized representative.

Also see Annual Report

Building Management Companies, Commercial Real-estate Companies, Retail and Big Box Stores, Hotels and Restaurants all generate and have waste to dispose of from time to time.

Knowing what wastes you have and whether or not they are hazardous is a responsibility of the business. Improper management of waste is an economic and environmental liability. Results can be fines, bad press, closures, harm to people and animals, and damage to the surrounding environment. The cost for proper disposal and management of waste far exceeds the cost and liability of a clean-up or injured worker.

Knowing how to store, track, label and dispose of your waste prevents misuse, spills and accidental exposures to harmful chemicals. Doing so can also prevent violations from state regulatory agencies, such as your states Safety Dept. Environmental Dept. or local Fire Marshal.

These wastes tend to be forgotten and/or stored out of the way. Unfortunately, they are usually seen by someone everyday right up until an inspector asks, “What’s all that?”

Many wastes have some sort of hazard associated to them, so they should not or cannot be thrown in the garbage, such as;

Fluorescent light tubes, batteries, e-waste, vehicle maintenance waste, aerosols, printing chemicals, pool cleaning chemicals, fertilizers, poisons, etc.

The good news is much of your waste can be recycled.

Types of waste these business may have can vary:

Building Management Companies, Commercial Real-estate Companies and Hotels generally have janitorial and maintenance waste or waste left by tenants, such as;

• • Fuel and oil from generators, paints, aerosols, cleaners, old smoke alarms, herbicides, pesticides, etc.

Retail and Big Box Stores can have janitorial and maintenance, but may also have off-specification, damaged or returned products, such as:

Drain cleaners, aerosols, paints, etc.

Depending on the volumes, these business are usually Exempt Generators.

Meaning you cannot store more than 1,000 kg (2,200 lbs.) of hazardous waste or 1 kg (2.2 lbs.) of acute hazardous waste on site at any time.

Your hazardous waste must be sent to an off-site treatment or disposal facility (TSD) which is:

• • A state or federally permitted hazardous waste treatment, storage, or disposal facility (TSDF).
  • 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 treats the waste prior to use, reuse, or recycling).
  • A universal waste handler or destination facility subject to the universal waste requirements of 40 CFR Part 273.
    • Universal wastes are hazardous wastes such as batteries, recalled and collected pesticides, mercury-containing thermostats and other equipment, mercury-containing lamps, or aerosol cans.

In Oregon you are a VSQG / Conditionally Exempt Small Quantity Generator if in every calendar month, you:

• Generate 2.2 pounds or less of acute hazardous wastes, or
• Generate 220 pounds or less of hazardous wastes, or
• Generate 220 pounds or less of spill cleanup debris containing hazardous wastes, or
• Never had on-site more than 2,200 pounds of hazardous wastes.

In Washington you are a SQG / Conditionally Exempt Small Quantity Generator if in every calendar month, you:

• Generate 2.2 pounds or less of acute hazardous wastes, or
• Generate 220 pounds or less of hazardous wastes, or
• Generate 220 pounds or less of spill cleanup debris containing hazardous wastes, or
• Never had on-site more than 2,200 pounds of hazardous wastes.

Being an Exempt Generator is the governments way of encouraging you to manage your hazardous waste correctly by making it easy for you to so and not overwhelming you with confusing regulations. However, the responsibility is yours, ignorance is not a valid excuse and will not stop a fine from a violation, especially if it has caused harm or a release.

In Idaho, all forms of cannabis/marijuana, including processed products made from cannabis/ marijuana are illegal to possess.

To dispose of it you can contact local law enforcement or a licensed hazardous waste disposal company.

In Oregon and Washington, you can possess certain amounts of medical and/or recreational cannabis/marijuana. Companies that typically generate marijuana/cannabis waste are:

Analytical labs, growers, distributors and stores that sell cannabinoid-based products containing THC.

Disposal in OR and WA is achieved by destroying the cannabis/marijuana at an offsite solid waste processing facility, such as a municipal or regional landfill, incinerator, waste to energy facility, or composting site.

Prior to disposal Generators of cannabis/marijuana waste must do a waste determination to see if the material is a hazardous or dangerous waste, or not. In particular, facilities that extract THC from cannabis/marijuana should do this determination.

If the waste is a RCRA hazardous or WA state dangerous waste, it must be sent to a permitted TSD facility.

Cannabis/Marijuana waste could be hazardous or dangerous wastes due to the addition of pesticides and/or solvents during analysis and in WA if the THC level is 10% or greater.

If the waste is not a hazardous or dangerous waste, it must be rendered unusable prior to it being send off-site for disposal.

Unusable renders the cannabis/marijuana undesirable, unrecognizable, incapable of growth or germination and “unusable” by humans or animals.

Unusable includes, but is not limited to, ingestion, inhalation, topical application, processing or remediation.

This can be achieved by grinding (for solids) or absorbing (for liquids) the cannabis waste together with other (compostable or noncompostable) waste materials, such that the resulting mixture is at least fifty percent (50%) non-marijuana waste.

Solid cannabis/marijuana waste it can destroyed by mixing it with dirt, bark/wood chips, food scraps, vegetable oils, potting soil and other inert/non-hazardous materials.

It should be at least a 50:50 blend

Liquids containing cannabis/marijuana can be destroyed by mixing with kitty litter, shredded paper, oil sorb, lime, vermiculite, or other similar materials.

It should be at least a 50:50 blend

Once the non-hazardous or non-dangerous cannabis/marijuana waste has been rendered unusable it can be placed in your municipal garbage container.

Your garbage container must be secured and locked such that it cannot be opened or moved (rolled away etc.).

You can also hold this waste inside of your building, so long as it is secure from theft until such time it can be placed in the garbage container for disposal (i.e., just prior to the garbage or compost trucks arrival).

Conditionally exempt small quantity generator. As of 2017 a CESQG is now called a Very Small Quantity Generator (VSQG).

A facility or organization that generates no more than 100 kilograms of hazardous waste in a month. Must have less than 1,000 kilograms of hazardous waste on site at any time. CESQGs have minimal regulatory requirements. In particular, assuming they meet the quantity thresholds, there is no time limit for shipping the hazardous waste off-site.

Comprehensive Environmental Response, Compensation and Liability Act of 1980, 42 U.S. C Section 9601 et seq., referred to colloquially as “Superfund”, providing for cleanup and remediation of uncontrolled or abandoned hazardous waste sites and response to accidents, spills and other emergency releases of hazardous substances. CERCLA provides EPA with enforcement authority to ensure that responsible parties pay the cleanup costs. (“PRPs” are Potentially Responsible Parties.)

Any substance, or mixture of substances.

The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name that will clearly identify the chemical for the purpose of conducting a hazard classification.

Chemical wastes, as reported to EPA’s Toxics Release Inventory (TRI), may or may not also be considered RCRA hazardous waste, but they are toxic chemicals. TRI reporting is based on how chemicals are used and not on the characteristics of the wastes generated. While the quantity of TRI chemicals released to the air, water, or land does not indicate their health risks, the information can be used as a starting point to evaluate the potential for human exposure to TRI chemicals and whether their releases may pose risks to human health and the environment.

TRI (Toxics Release Inventory) in a mandatory program that tracks the management of certain toxic chemicals that can pose a threat to human health and the environment. It is a resource for learning about toxic chemical releases and pollution prevention activities as reported by industrial and federal facilities. 

Facilities that have or use one or more of the approximately 775 TRI-listed chemicals or 33 chemical catergoried must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery, treatment or disposal. 

A “release” of a chemical means that it is emitted to the air or water, or placed in some type of land disposal. 

The information submitted by these facilities is compiled into the Toxics Release Inventory (TRI).

This data is used by communities, government agencies, companies, and others to inform people of what chemicals are in their communities and their associated risks, such as causing cancer or other chronic human health effects. Significant adverse acute human health effects and/or significant adverse environmental effects. 

The Emergency Planning and Community Right-to-Know Act (EPCRA) created TRI to promote emergency planning and to provide the public with information about releases of toxic chemicals in their communities. 

A RCRA characteristic hazardous waste is a solid waste that meets the definition of one or more of the four waste characteristics: Ignitability (D001), Corrosivity (D002), Reactivity (D003), and Toxicity (D004 – D043).

Ignitable wastes include liquids with flash points below 60 °C, non-liquids that cause fire through specific conditions, such as spontaneous combustion, have a flash point less than 60 °C (140 °F), are ignitable compressed gases, are oxidizers.

Corrosive wastes are acids or bases (pH less than or equal to 2, or greater than or equal to 12.5) or are capable of corroding steel, such as storage tanks or drums.

Reactive wastes may be unstable under normal conditions, may react with water, may give off toxic gases and may be capable of detonation or explosion under normal conditions or when heated. They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water.

Toxic wastes that are hazardous due to the toxicity characteristic and are harmful when ingested or absorbed into the body. Toxic wastes present a concern as they may be able to leach from the waste into the environment, such as groundwater.

Toxicity is defined through a laboratory procedure called the Toxicity Characteristic Leaching Procedure (TCLP). 

A container is closed when all openings or lids are properly and securely affixed to the container, except when wastes are actively being added to or removed from the container.

The codification of the general and permanent rules and regulations published in the Federal Register by the executive departments and agencies of the federal government of the United States.

40 CFR: Protection of the Environment. EPA regulation to protect human health and the environment. Includes hazardous waste regulation.

49 CFR: Transportation. Department of Transportation regulations that include hazardous materials transportation (including hazardous waste) regulations and federal motor carrier regulations.

You are a conditionally exempt generator, if in every calendar month, you:

• Generate 2.2 pounds or less of acute hazardous wastes, or
• Generate 220 pounds or less of hazardous wastes, or
• Generate 220 pounds or less of spill cleanup debris containing hazardous wastes, or
• Never had on-site more than 2,200 pounds of hazardous wastes.

A confined space has limited or restricted means of entry, is not designed for continuous human occupancy, and is large enough and configured so that a person can enter the space and maneuver well enough to perform tasks.

Examples; pits, tanks, vats, silos and vaults.

Hazards associated with confined spaces include oxygen deficiency, toxic vapor’s, explosive or combustible gases, solvents or dusts, temperature extremes, as well as, physical and mechanical hazards such as rotating machinery, electrical equipment or walls and materials that can engulf or trap an entrant.

There are three types of Confined Spaces:

Non-Permit

Is for a confined spaces that pose no risk or hazards to the entrants. Normal safety protocols and notifications should be observed.

Alternate-Permit

An alternate permit is required for a confined space that with proper ventilation it poses no other hazards to the entrant.

Permit-Required.

Permit-Required confined spaces are the most hazardous and require you or some qualified person to completed a safety checklist, simply called a “permit”, before you enter into the space.

If entry cannot be avoided and it is a Permit-Required space the entrants must follow a specific set of safety protocols. These may include:

• Air monitoring
• Lock out / Tag out
• Respirator use
• Specialized PPE
• Rescue equipment
• Specific training for supervisors, entrants and rescuers
• Use of certain equipment, such as non-sparking tools
• Having a rescue team on stand-by

C&D (construction and demolition) waste and debris, which typically consists of roadwork material, excavated material, demolition waste, construction/renovation waste, and site clearance waste.

Much of this debris is be sent to landfill or recycling.

Concrete and wood can be grinded for reuse.

Clean soil can be used as fill or ground cover.

Repository used to accumulate waste from residential, commercial and industrial sites.

Containers can vary in size and type according to the needs of the business or restrictions of the community.

Something that holds waste. These vary widely in size and type, but the most common are 55-gallon drums, roll-off dumpsters and portable tote tanks.

Requires facilities (past and present) that treat, store or dispose of hazardous wastes to investigate and clean up contaminated soil, groundwater, and surface water.

A RCRA program that oversees the investigation and cleanup of nearly 4,000 hazardous waste sites across the country.

It is run by the EPA and 43 authorized states and territories, alongside responsible facilities.

RCRA permits issued to TSDFs must include provisions for Corrective Action as well as financial assurance to cover the costs of implementing those cleanup measures.

Having the quality of corroding or eating away; being erosive.

The characteristic which identifies hazardous wastes that are acidic or alkaline and can readily corrode or dissolve flesh, metal, or other materials.

EPA, under RCRA, a hazardous waste is corrosive if it is:

• Aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5; or
• A liquid and corrodes steel at rate greater than 6.35 mm (approx. 1/4 inch) per year at a test temperature of 55 degrees Celsius (40 CFR 261.22).

DOT, under the HMR, a Class 8 (Corrosive) material is defined as a liquid or solid that:

• Causes irreversible full thickness destruction of human skin at the site of contact within a specified period of time (4 hrs.).
• Is a liquid, or a solid that may become a liquid during transportation, which has a severe corrosion rate on steel or aluminum, at least 6.25 mm (0.25 in.) a year, at a test temperature of 55°C (130°F).

Dental Amalgam contains mercury and possibly other metals such as silver, tin and copper. The Environmental Protection Agency (EPA) estimates that 50 percent of mercury entering Publicly Owned Treatment Works (POTW) comes from the amalgam used in dental offices.

The amount of Mercury can vary, but most amalgams exceed the regulatory limits for mercury and possible silver.

Depending on your Generator Status and the level of mercury (as well as other metals, such as copper, silver, tin, and zinc) present in your waste Dental Amalgam it could have RCRA waste codes applied (e.g., D009 for mercury and D011 for silver).

The vast majority of dental offices have an exempt Generator Status (VSQG in OR and ID, SQG in WA). If this is the case, the RCRA codes would not be applicable. However, it must still be managed compliantly as a waste. It is also the responsibility of each dental office to determine their Generator status.

Dental offices that use mercury containing Dental Amalgams are required to minimize the amount of mercury that reaches their sewer system. Most office do this by using Traps and Separators, which can remove up to 99% of the mercury.

Traps screen out larger particles of mercury amalgams.

Separators capture amalgam particles that are too small to be screened out by the traps.

Practices that help mitigate mercury from getting into sewers system and the environment include:

Not rinsing the Traps or other mercury contaminated items in sinks.

Properly cleaning and maintaining traps and separators.

Not putting any mercury containing items (amalgam, amalgam traps, teeth or capsules in with your red bag / biohazardous waste.

Send mercury containing liquid and solid waste to a permitted recycler or disposal facility.

The hazardous waste treatment, storage, disposal (TSD) or recycling facility that has been designated on a manifest by the generator. The facility must meet one of the following:

• Has received a permit or interim status in accordance with 40 CFR 270 & 124.
• Has received a permit or interim status from an authorized state in accordance with 40 CFR 271.
• Is regulated under 40 CFR 261.6(c)(2); or
• Is regulated under Subpart F of 40 CFR 270.

A facility designated on a manifest or any other shipping document by a hazardous waste generator that recycles hazardous waste received from off-site in units that are exempt from the requirements to obtain a Resource Conservation and Recovery Act permit for the management of hazardous waste.

A Discarded Material is defined by regulation as any material which is:

• Abandoned
• Recycled
• Inherently waste-like
• A military munition
• An unused Commercial Chemical Product (CCP) meets the definition of a solid waste when the generator makes the decision to discard it. Under RCRA, unused products do not become ‘waste’ until they become ‘discarded material.’

EPA believes that an unused product becomes ‘discarded’ when an intent to discard the material is demonstrated.

asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

The discharge, deposit, injection, dumping, spilling, leaking, or placing of any hazardous waste or hazardous substance into or on any land or water so that the hazardous waste, or hazardous substance or any constituent thereof, may enter the environment or be emitted into the air or discharged into any waters of the state as defined in ORS 468.700.

The discharge, deposit, injection, dumping, spilling, leaking, or placing of a hazardous waste into or on land or water so that the waste or its constituents may enter the environment or be emitted into the air or discharged into any waters, including groundwater.

Is a permitted Treatment Storage and Disposal facility (TSD or TSDF) where hazardous waste is intentionally burned, treated prior to being placed into or on any land or discharged into any waters. (e.g., Part B permitted Incinerators and Subtitle C landfills)

A facility or part of a facility at which hazardous waste is intentionally placed into or on any land or water, and at which waste will remain after closure (i.e., an End Facility).

U.S. Department of Transportation requires and enforces stringent safety procedures for the transportation of hazardous materials, including Hazardous Waste in conjunction with the EPA.

DOT empty containers are not defined by volume or weight. They are defined by the existing hazardous properties. If the hazard still exists, then it is regulated as a full package by DOT no matter how much material is still left in the package. For example, if your package has residual flammable liquid that is still creating a flammable atmosphere within the drum, then this empty drum, which contains only the residue of a DOT hazardous material shall be offered for transportation and transported in the same manner as when it was full.

DOT has the authority to regulate the transportation of hazardous materials under the Hazardous Materials Transportation Act (HMTA), which is overseen by the Pipeline and Hazardous Materials Safety Administration (PHMSA) division of DOT.

A DOT hazardous material is defined as “a substance (gas, liquid, or solid) capable of creating harm to people, environment, and property.”

By definition, hazardous materials are capable of posing an unreasonable risk to health, safety, and property in commerce. This includes substances, wastes, marine pollutants, elevated temperature materials, and items included in DOTs Hazardous Materials Table (HMT – 49 CFR 172.101) (e.g., laboratory chemicals, solvents, alcohol, acids, compressed gases, cleaners, pesticides, paints, infectious substances, radioactive materials).

Note that anything excluded from the EPA’s Hazardous Waste Manifest requirements is not considered a hazardous waste by DOT when shipped. However, it may still be considered a hazardous material.

Hazardous materials are legally defined by class, characteristic, and name:

• Class 1: Explosives
• Class 2: Gases
• Class 3: Flammable Liquid
• Class 4: Flammable Solids
• Class 5: Oxidizing Substances, Organic Peroxides
• Class 6: Poisonous (Toxic) and Infectious Substances
• Class 7: Radioactive Materials
• Class 8: Corrosives
• Class 9: Miscellaneous Dangerous Goods
• DOT code requires that any employee involved in the transportation (shipping or receiving) of hazardous materials must be trained and tested in general awareness, site-specific job functions, and transportation security.

For the purpose of applying the U.S. Department of Transportation’s (DOT) Hazardous Materials Regulations (HMR) and identifying hazardous materials, the DOT limits the meaning of hazardous waste to only those RCRA hazardous wastes that are required to be documented on a uniform hazardous waste manifest when transported. This definition excludes shipments of wastes that are not required to be documented on a manifest, such as government-transported shipments and those from Very Small Quantity Generators (VSQGs).

The DOT diamond hazard labels are based on the Hazard Class or Classes for the primary, and any subsidiary hazard classes of the hazardous material listed in the PSN.

The label must be printed on or affixed to a surface of the package or containment. The label must be located on the same surface of the package and near the shipping name marking. If primary and subsidiary hazard labels are required, they must be displayed with 6 inches of each other.

Hazard class labels must be durable and weather resistant. These labels must withstand without deterioration or change in color, a 30-day exposure to reasonable transport conditions.

The labels must not be obscured by markings or attachments.

The label colors must contrast the background they have been printed or affixed to.

• Each person who offers or transports hazardous materials must comply with the placarding requirements. It is the responsibility of the shipper or the carrier to make sure the correct placards are offered or affixed.
• Use the HMR and refer to both placarding Tables (1 and 2) and any exceptions.
  • All applicable placards must be placed on each side of the vehicle.
  • UN ID numbers must be used on:
    • Non-Bulk Packages: If 4,000 kg (8,882 Lbs.) of a Single Commodity is loaded at one facility and contains no other materials.
      • Except: o Class 1, 7, or any other material not requiring ID #s.
      • Small quantities, LTD QTY’s, Combustibles, etc.
    • All Bulk Packages: 4 Sides if > 1,000 Gallons; 2 Sides if < 1,000 Gallons.
  • Placarding Exception for less than 454 kg (1,001 pounds). Except for bulk packaging’sand hazardous materials subject to  172.505, when hazardous materials covered by table 2 of this section are transported by highway or rail, placards are not required on:
    • A transport vehicleor freight container which contains less than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by table 2 of paragraph (e) of this section; or
    • A rail carloaded with transport vehicles or freight containers, none of which is required to be placarded.
      • This exceptiondoes not prohibit the display of placards in the manner described, if not otherwise prohibited (see § 172.502), on transport vehicles or freight containers which are not required to be placarded.
    • Placarding Requirements have two Tables (1 and 2). General requirement of which are:
      • Table 1 – Any bulk packaging, freight container, unit load device, transport vehicle or rail car containing any quantity of material listed in Table 1 must be placarded.
      • Table 2 – When the aggregate gross weight of all hazardous materials in non-bulk packages covered in Table 2 is greater than 454 kg (1,001 lbs.), placards are required on the transport vehicle or freight container when transported by highway or rail.
• You cannot over placard. Placards may not be displayed on a transport vehicle, portable tank, or freight container unless: Transported material is a hazardous material; Placarding represents a hazard of the material; Placarding conforms to the regulations.
• Placarding requirements do not apply to small quantities of certain hazard classes; Limited quantities; Infectious substances; Other regulated material (ORM-Ds); Combustible liquids in non-bulk packaging’s; Materials prepared in accordance with §173.13

E-Waste (computers, printers, monitors, laptops, cell phones, etc.) can come from businesses, government offices, schools and individuals. Much of it can be reused, refurbished, or recycled.

Many states, such as Oregon, prohibit the disposal of discarded electronic equipment including computers, monitors, printers, TVs, stereo systems, VCRs, phones and other personal electronic devices.

Other states, Washington and Idaho, require e-waste be recycled or reused. If it is not, a waste determination must be done and if the e-waste is determined to be a hazardous or dangerous waste it must then be disposed of at a permitted disposal facility.

E-waste contains toxic metals, some of which are hazardous (such as lead and cadmium) and must be managed correctly through a permitted disposal facility or recycler.

It is best to gather and send all your e-waste to a company who will have it recycled.

Modern e-waste recyclers are capable of separating out all the various types of plastics, metals and glass that come from discarded computers, monitors, keyboards, tablets, cell phones, televisions, DVD players, stereos, copiers, laptops, or any piece of equipment containing a circuit board.

Washington State Department of Ecology’s (DOE)

e-Manifest is an electronic version of the hazardous waste manifest that is obtained from the EPA‘s national e-Manifest system and transmitted electronically to the system. It is the legal equivalent of EPA Forms 8700-22 (Manifest) and 8700-22A (Continuation Sheet).

Electronic Manifest System (or e-Manifest System) is the EPA‘s national information technology system through which the electronic manifest may be obtained, completed, transmitted, and distributed to users of the electronic manifest and to regulatory agencies.

According to EPA, a hazardous waste is “a contaminated chemical or byproduct of a production process that no longer serves its purpose and needs to be disposed of in accordance with the EPA.”

Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries, and may come in many forms (e.g., liquids, solids, gases, and sludges). To determine whether a waste is considered “hazardous,” EPA has developed a flowchart identification process (pictured below).

EPA’s Resource Conservation and Recovery Act (RCRA) establishes the regulatory framework for managing hazardous waste. The degree of regulation that applies to each hazardous waste generator depends on the amount of hazardous waste produced.

Unless it is managed at the facility, hazardous waste generated must eventually be transported off site for disposal, treatment, or recycling. At this point, DOT regulations kick in for the transportation of freight, including the transport of RCRA hazardous waste.

EPA code (40 CFR 266 and 273) requires that any employee taking part in chemical waste management (hazardous or universal) must be trained in proper waste disposal practices.

The number EPA assigns to each hazardous waste in 40 CFR 261, Subpart D, and to each characteristic waste in 40 CFR 261, Subpart C.

A hazardous waste EPA ID number is issued by either the U.S. Environmental Protection Agency (federal EPA ID numbers) or by the State (State EPA ID numbers).

The EPA ID number identifies each handler of hazardous waste on a hazardous waste manifest and other paperwork.

One is assigned to each generator, transporter, and TSDF that generates, transports and/or disposes of hazardous waste.

LQG’ and SQGs must obtain an EPA ID Number.

VSQGs do not need to obtain EPA ID numbers because they are exempt from the notification requirements in the Resource Conservation and Recovery Act (RCRA).

VSQGs should check if they need to obtain an EPA ID number under their state regulations, as some state have more stringent requirements.

An activity (planned or unplanned) that does not normally occur during a generator’s operations and that causes that generator to exceed the threshold for its normal generator category for that month.

Very small quantity generators and small quantity generators can experience episodic events.

Generator has 60 days from the start of the event to complete it and ship all the hazardous waste off site to a RCRA-designated facility for treatment, storage, or disposal.

If the hazardous waste is not off site within 60 days, then it must be counted toward the generator’s monthly generation levels.

The generator may only use this provision once every calendar year unless there is a second event for which the generator receives approval from the U.S. Environmental Protection Agency (EPA) to manage as an additional episodic event.

If the first event is planned, then any second event would have to be unplanned. If the first event is unplanned, any second event would have to be planned.

Planned episodic events include tank or lab cleanouts, short-term demolition projects, short term construction projects, short-term site remediation, equipment maintenance during plant shutdowns, and removal of excess chemical inventories.

Unplanned episodic events include production process upsets, product recalls, accidental spills, or “acts of nature,” such as a tornado, hurricane, or flood.

A category of waste that is excluded from certain hazardous waste requirements. One example is recycled scrap metals. Some scrap metals may have chromium (hazardous), but, with the excluded waste category, recycling is encouraged.

Regulated nationally by the U.S. Environmental Protection Agency (EPA) under the Emergency Planning and Community Right to Know Act (EPCRA) regulations.

Could cause serious human health effects from short-term exposures such as accidental air releases. Extremely hazardous substances must be reported to state and local emergency planners.

All contiguous land and structures, other appurtenances, and improvements on the land, used for treating, storing, or disposing of hazardous waste. A facility may consist of several treatment, storage, or disposal operational units (e.g., one or more landfills, surface impoundments) or combinations of them.

For reporting purposes, facility refers to hazardous waste generators; RCRA treatment, storage, and disposal facilities; and designated recycling facilities

The term includes all contiguous land, structures, other appurtenances and improvements on the land, owned or operated by the same person or by any person who controls, is controlled by, or under common control of any person.

A state that EPA has given primary responsibility for implementing the Resource Conservation and Recovery Act (RCRA) hazardous waste program. Federally authorized states have adopted and apply RCRA hazardous waste rules that are at least as stringent as the EPA rules.

• Fuel Blending is an environmentally safe and economical solution that is also an EPA approved disposal method, by which RCRA hazardous and non-hazardous wastes can be blended together in order to create a usable fuel alternative which is burned by cement kilns instead of or along with the burning of traditional fossil fuels, such as natural gas or coal. These cement kilns are RCRA Part B permitted TSDFs that are regulated federally by the EPA as well as the State in which they operate. These facilities are also subject to the same strict air emission standards as hazardous waste incinerators.
• The use of this waste as a fuel in cement kilns has many benefits, as it prevents thousands of tons of waste from going into our landfills or waste incinerators and lowers the amount of non-renewable resources used, such as coal. Cement Kilns are more efficient at burning hazardous waste than conventional waste incinerators and release less CO2 as well. They also burn the waste at higher temperatures, for longer durations, allowing for a more complete burning of the waste. Even the ash from the fuel used in the process is used, as it drops into and reacts with the hot minerals to become an integral part of the end-product; the clinker that is ground into Portland cement.
• The production of Portland cement is a very heat/fuel intensive process, which requires the raw material be heated to a temperature of 2,500-2,700 F. Part B permitted kilns can use this burnable waste for up to 100% of their total fuel needs, however, on average it currently accounts for only 20 to 30% of their total fuel consumption, which equates to the energy needed to power 5,000 to 8,000 homes per year.
• Fuel Blending waste does need to meet certain requirements to be used as an alternate fuel in a cement kiln, usually imposed by the facility’s Part B permit or by federal/state regulation. For example, most kiln facilities require the waste be >2,500 btu/lb., < 50 ppm PCBs, <2 ppm mercury, etc. Acceptable wastes are your typical flammable organic solvents (such as toluene, acetone, thinner), oil-based paint, used oils, coatings and resins. Additionally, dispersible solids and sludges of these wastes or dry debris (PPE, rags, absorbent pads, etc.) contaminated with these wastes is acceptable for use fuel.
• Certain wastes that are not acceptable for Fuel Blending are corrosive (pH < 2 or >5) and reactive wastes (such as chemicals that can cause hazardous polymerization or generate dangerous levels of heat when mixed with other materials), as well as wastes that have a low energy value (e.g., alcohols that have a low BTU value and/or a high percentage of water). Other non-acceptable wastes are dioxins, furans, cyanides and explosives.
• The advantage to everyday generators of small amounts of flammable wastes, is that it can still be used. We can package small jars and bottles that will eventually be poured off into drums or totes. We can also pickup your drums, totes and tankers of waste alcohols, solvents and flammables. All of which will be pumped into railcars and transported to a cement kiln for use as an alternative fuel.

The lowest temperature at which vapors of a material will ignite, when given an ignition source.

For example, an open-top container of gasoline on a cold day would still produce ignitable vapors because it has a very low flash point.

WXXX (W followed by three numbers) Code describes the general physical and chemical characteristics of a hazardous waste.

Link.

A person who, by virtue of ownership, management, or control, is responsible for causing or allowing to be caused the creation of hazardous waste.

Any person or site whose processes and actions create hazardous waste listed in 40 CFR 261. Generators are divided into three categories based on the quantity of waste they produce in a month, and each category must comply with the applicable set of requirements. The three categories are:

• Large Quantity Generators (LQGs)
• Small Quantity Generators (SQGs)
• Very Small Quantity Generators (VSQGs).

Any business or individual whose act or practice creates or produces hazardous waste. Typically listed as either a Large Quantity Generator (LQG), or Small Quantity Generator (SQG).

Is a term used when a Generator is making a waste determination based on what they know about a particular waste stream.

Acceptable knowledge includes knowing what goes into the waste: chemical compositions and concentrations. The process that generates the waste, what chemicals go in, what gets used in or during manufacturing, what gets lost during any reactions, treatments, rinses and/or emissions and finally what comes out as waste once the process is completed.

The generators can use their experience of the process and other reliable and relevant information, such as SDSs, product specification sheets, tests other than those methods set forth in subpart C of 40 CFR part 261 and so forth.

When available knowledge is inadequate to make an accurate determination, the generator must test the waste according to the applicable methods set forth in subpart C of 40 CFR part 261.

Means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity.

The DOT divides hazardous materials into nine Hazard Classes, based on the physical properties and/or health hazards of the material, e.g., flammable solid, carcinogen, oral acute toxicity.

CLASS 1 EXPLOSIVES

DIVISION 1.1 MASS EXPLOSIVE HAZARD

DIVISION 1.2 PROJECTION HAZARD

DIVISION 1.3 MASS FIRE HAZARD

DIVISION 1.4 MINOR EXPLOSION HAZARD

DIVISION 1.5 VERY INSENSITIVE EXPLOSIVES

DIVISION 1.6 EXTREMELY INSENSITIVE EXPLOSIVES

CLASS 2 GASES

DIVISION 2.1 FLAMMABLE GASES

DIVISION 2.2 NON-FLAMMABLE GASES

DIVISION 2.3 POISONOUS OR TOXIC

CLASS 3 FLAMMABLE LIQUID

Includes materials whose Flash Point (FP) is < 141F

Hazardous Waste with a FP of < 140 F

Combustible Liquids are materials whose FP is > 141 F, but < 200 F. Materials transported domestically only, whose FPs are 100 F up to 141 F may be reclassified as combustible in accordance with 173.120(b).

CLASS 4 FLAMMABLE SOLIDS

DIVISION 4.1 FLAMMABLE SOLID

DIVISION 4.2 SPONTANEOUSLY COMBUSTIBLE MATERIAL

DIVISION 4.3 DANGEROUS WHEN WET

CLASS 5 OXIDIZING SUBSTANCES; ORGANIC PEROXIDES

DIVISION 5.1 OXIDIZER

DIVISION 5.2 ORGANIC PEROXIDE

CLASS 6 POISONOUS (TOXIC) AND INFECTIOUS SUBSTANCES

DIVISION 6.1 POISONOUS (TOXIC) MATERIAL

DIVISION 6.2 INFECTIOUS SUBSTANCE

CLASS 7 RADIOACTIVE MATERIAL

CLASS 8 CORROSIVES

Hazardous Waste Acids – pH < 2

Hazardous Waste Bases – pH > 12.5

Dermal – A liquid or solid that causes full thickness destruction of human skin at the site of contact within a specified period of time (four hours).

Metal – Materials that corrode through steel or aluminum at least 6.25 mm (0.25 in.) a year.

CLASS 9 MISCELLANEOUS DANGEROUS GOODS

Can include Environmentally Hazardous Substances, Hazardous Wastes, and Marine Pollutants.

The Hazard Communication Standard (HCS) is an OSHA requirement that’s purpose is to ensure chemical safety to employees who may come into contact with hazardous chemicals at their workplace by providing them with information and training on the potential hazards.

The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees.

requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.

Those who manufacture and/or import chemicals must assess their hazards, as well as create labels and safety data sheets (SDS) that inform their customers of the potential dangers.

Classifying the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of safety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures.

Workplaces that have or use hazardous chemicals must have clearly displayed labels and supply SDSs to employees who may come in contact with them.

Employees must also be trained on the proper handling of hazardous chemicals as well as on how to read their related labels and SDSs.

Is done to learn whether workers are exposed to hazardous materials or harmful conditions.

The hazard evaluation process will recognize and evaluate chemical, physical and biological hazards within the workplace to determine if proper controls are present and control unacceptable exposures.

Is the primary component of a Health Hazard Evaluation done to identify and assess hazards that can effect employers and their workers:

• Collect and review information about the hazards present or likely to be present in the workplace.
• Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.
• Investigate injuries, illnesses, incidents, and close calls/near misses to determine the underlying hazards, their causes, and safety and health program shortcomings.
• Group similar incidents and identify trends in injuries, illnesses, and hazards reported.
• Consider hazards associated with emergency or nonroutine situations.
• Determine the severity and likelihood of incidents that could result for each hazard identified and use this information to prioritize corrective actions.
• Some hazards, such as housekeeping and tripping hazards, can and should be fixed as they are found.

Is the principal mechanism that the EPA uses to place uncontrolled waste sites on the National Priorities List (NPL).

It is a numerically based scoring system that uses information from initial, limited investigations,  the preliminary assessment (PA), the site inspection (SI), and the expanded site inspection (ESI) if necessary, to assess the relative potential of sites to pose a threat to human health or the environment.

Means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

Regulated nationally by the U.S. Occupational Health & Safety Administration (OSHA)under the Hazard Communication Standard (HCS) regulations, pose a physical or health hazard to workers.

Regulated nationally by the U.S. Environmental Protection Agency (EPA), must be reported to state and local emergency planners under the Emergency Planning and Community Right to Know Act (EPCRA) regulations. These hazardous chemicals include both Superfund hazardous substances and extremely hazardous substances.

Hazardous chemicals, as defined nationally by the International Code Council in the International Fire Code (IFC), pose an unreasonable risk to the health and safety of operating personnel, emergency personnel, the public, and the environment if not properly controlled during handling, storage, manufacture, processing, packaging, use, disposal or transportation.

Hazardous constituents carry the chemical or physical risk that caused a waste they are contained in to be considered a hazardous waste by the U.S. Environmental Protection Agency (EPA) or MPCA. They are different than groundwater protection hazardous constituents or underlying hazardous constituents.

Hazardous constituents are identified nationally by the EPA under the Resource Conservation and Recovery Act (RCRA) regulations, which have been adopted in Minnesota by the MPCA.

Hazardous drugs are defined differently by two federal agencies: however, both address health care employee safety. Both definitions are advisory on the federal level, not regulatory.

As defined by the American Society of Hospital Pharmacists (ASHP), adopted by U.S. Occupational Safety and Health Administration (OSHA), hazardous drugs cause cancer, damage genes, increase risk of birth defects, or damage organs.

As defined by the National Institute for Occupational Safety and Health (NIOSH), an agency of the U.S. Department of Health & Human Services, hazardous drugs are those used for cancer chemotherapy, antiviral therapy, hormones, bioengineered drugs, and drugs harmful for pregnant or nursing mothers.

DOT – Any chemical or item that is a risk to public safety or the environment when being transported or moved in commerce by air, rail, ground, or sea.

OHSA – Any substance or chemical which is hazardous to people’s health or is physically hazardous.

EPA – Any item or chemical which can cause harm to people, plants, or animals when exposed by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

NRC – Is any material considered hazardous by its production of ionizing radiation. This includes special nuclear material, by-product material, and radioactive substances.

Hazardous materials, regulated nationally under the Hazardous Materials Regulations (HMR) by the Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency of the U.S. Department of Transportation (DOT), pose an unreasonable risk to public health and safety or property when transported in commerce.

Hazardous materials include most hazardous wastes, some hazardous substances, and environmentally hazardous substances in addition to other PHMSA-designated materials.

A substance or product that is dangerous or potentially harmful to human health or the environment. Hazardous materials are regulated by DOT while in transportation.

An agency of the U.S. Department of Transportation (DOT), under the Hazardous Materials Regulations (HMR). Extremely hazardous substance See citations in Table 1 on page 8.

The term “hazardous substance” means:

• Any substance designated pursuant to the Clean Water Act (CWA) section 311 (“CWA Hazardous Substances”),
• Any toxic pollutant listed under section 307(a) of the Federal Water Pollution Control Act [ 33 U.S.C. 1317(a)]. (“CWA Toxic Pollutants”),
• Any hazardous air pollutant listed under section 112 of the Clean Air Act (“CAA Hazardous Air Pollutants (HAPs)”),
• Any hazardous waste having the characteristics identified under or listed pursuant to Resource Conservation and Recovery Act (RCRA) section 3001 (“RCRA Hazardous Wastes”).
• Any imminently hazardous chemical substance or mixture with respect to which the Administrator has acted pursuant to section 7 of the Toxic Substances Control Act.
  • There are currently no substances are designated under this authority).

Gets an RQ (Reportable Quantity) value.

There are currently about 800 CERCLA hazardous substances. In addition, there are approximately 1,500 known radionuclides, approximately 760 of which are listed individually.

The CERCLA list of hazardous substances can be found at 40 CFR part 302.4EXITEXIT EPA WEBSITE in Table 302.4 “List of Hazardous Substances and Reportable Quantities”.

Regulated by the U.S. Environmental Protection Agency (EPA) under the Clean Water Act (CWA), present an imminent and substantial danger to the public health or welfare, including fish, shellfish, wildlife, shorelines, and beaches, when discharged into navigable waters of the United States. These hazardous substances are also known as Clean Water Act hazardous substances or CWA hazardous substances.

Hazardous substances, regulated by the EPA under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, often referred to as Superfund) may present substantial danger to the public health or welfare or the environment when released into the environment. This definition establishes liability on the federal level for environmental damages caused by hazardous substances under Superfund. These hazardous substances are also known as Superfund hazardous substances or CERCLA hazardous substances. Superfund hazardous substances do not include petroleum or natural gas liquids.

All Clean Water Act hazardous substances (discussed in the previous paragraph) are Superfund hazardous substances, but not the reverse; the Superfund hazardous substances umbrella is larger and includes more hazardous substances.

Have a Reportable Quantity (RQ) value if spilled.

• A regulated subset of waste that can pose a substantial or potential hazard to human health or the environment when improperly managed. Possesses at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity), or appears on special EPA lists.
• According to the EPA, hazardous waste is defined as waste with properties that make it dangerous and potentially harmful to human health and environment. The Resource Conservation Recovery Act (RCRA) has a more precise definition which requires hazardous waste to exhibit particular characteristics and fall into a particular description. For more specifics on hazardous waste click here for the definition of hazardous waste in the Federal Code of Regulations
• Describes a solid waste that exhibits a distinct hazardous characteristic or is otherwise listed as a hazardous waste in federal or state regulations.
• Solid wastes with properties that make them dangerous or capable of having a harmful effect on human health and the environment. Under RCRA, Hazardous Wastes are specifically defined as wastes that exhibit a specific characteristic (toxicity, flammability, ignitability or infectious) or are specifically listed as a hazardous waste in the Subtitle C. States and provinces may promulgate their own definitions.
• Hazardous wastes are determined by being on one of EPA’s four lists (F, K, P, or U) or meeting one of four characteristics (ignitability, corrosivity, reactivity, or toxicity).
• Hazardous wastes are regulated nationally by the U.S. Environmental Protection Agency (EPA) under the Resource Conservation & Recovery Act (RCRA).
• Wastes must be assumed to be hazardous unless they are exempt from the RCRA regulations or are evaluated as not being included on any of four EPA lists and not meeting any of four physical and chemical characteristics.
• Federally regulated hazardous wastes are also known as RCRA hazardous wastes or EPA wastes.
• Hazardous waste is a solid waste (solid waste includes solids, liquids and compressed gases) that possesses at least one of four characteristics (ignitibility, corrosivity, reactivity, or toxicity), or that appears on federal or state official lists of hazardous wastes.
• A solid waste is a hazardous waste if it is:

Defined by Title 40 of the Code of Federal Regulations (CFR), Part 261 as a hazardous waste.

A document required for LQGs and SQGs that establishes an organized, planned, and coordinated course of action to follow in case of a fire, explosion, or release of hazardous waste or hazardous waste constituents that could threaten human health or the environment.

Waste Characterization testing on solid and liquid samples to determine if material is considered hazardous based on the RCRA definition in 40 CFR Subpart 261.

The accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous waste into or on any land or water.

Discharges can occur during the transportation, storage or management of hazardous waste.

Also known as Subtitle C Landfills. Hazardous waste landfills are dedicated to the treatment, storage and disposal of hazardous wastes. When hazardous waste is removed from a contaminated site, those sites become safe places for plants, animals and human health. The materials contaminated with hazardous waste are treated and contained in the landfill, so it is no longer a threat to human health and the environment. To learn more about Subtitle C Landfills

The U.S. Environmental Protection Agency Uniform Hazardous Waste Manifest (EPA Forms 8700-22 and 8700-22A) is used by hazardous waste generators, hazardous waste transporters and hazardous waste treatment, storage and disposal facilities.

EPA launched the hazardous waste e-Manifest system nationwide on June 30, 2018. Generators, transporters, and receiving facilities have the option to create and submit manifests electronically. These manifest users may continue to use paper manifests after June 30, 2018; however, use of e-Manifest is highly encouraged by EPA.

Is meant to track hazardous waste from the generator/generation (through any transporters and on) to final disposal at a TSD facility.

When completed, the form contains information on the type and quantity of the waste being transported, instructions for handling the waste, and signature lines for all parties involved in the disposal process.

Each party that handles the waste signs the manifest and retains a copy for themselves

The receiving TSD facility returns a signed copy of the manifest to the generator within 35 days.

Hazardous waste manifests must accompany all hazardous waste that is shipped off site.

Each transporter signs the completed manifest when the shipment is accepted for transport.

The facility operator at the designated/final TSD also signs the form when the shipment is received and sends a copy of it back to you:

SQGs and LQGs must keep copies of the manifests that are signed by the TSDF for 3 years from the date the waste was accepted by the initial transporter.

If they do not receive a copy back from the TSDF in 35 days, they must investigate why and if they do not receive the copy back in 45 days, they must notify EPA.

Generators are not required to keep copies of manifests on site; however, they must be made available upon request.

For example, they may keep copies at a corporate headquarters.

(HAZWOPER) requires any employees who are in positions that may respond to chemical spills or emergencies onsite to be trained in chemical risk recognition, spill control basics, emergency response, and additional requirements depending on the level of response expected.

The HAZWOPER training requirements are often confused with hazardous waste generator employee training required by the EPA under the RCRA regulations

This OSHA program requires that all employees must be trained on emergency response, spill management, and risk minimization. This training covers:

Code requirements​

• Hazard classes, risk identification, hazardous communication
• Site safety programs​
• Proper selection use of appropriate PPE and respiratory protection​
• Advanced spill management and emergency response procedures​
• Risk minimization, emergency management, and engineering controls​

Refers to many types of hazardous waste operations and emergency services conducted around the world, especially those conducted under the auspices of the federal government of the United States. HAZWOPER training is covered under OSHA.

Is meant to protect employees who may be exposed to hazardous substances at hazardous waste facilities or when they respond to emergencies (such as spill cleanups).

Requires employers to follow specific work policies, practices, and procedures to protect their employees while conducting hazardous waste operations to include; handling, cleanup, disposal, and/or emergency response.

HAZWOPER applies to employers:

Cleanup operations.

Involve employees who remove, contain, incinerate, neutralize, stabilize, process, or handle hazardous substances at a hazardous waste site to make it safe for people or the environment.

There are three kinds of cleanup operations: cleanup operations required by a government agency at an uncontrolled hazardous waste site, corrective actions that involve cleanup at sites covered by RCRA, and voluntary clean-up operations.

Operations involving hazardous wastes at treatment, storage, and disposal (TSD) facilities.

Treatment, storage, and disposal (TSD) facilities treat, store, or dispose of hazardous waste and are required to have an RCRA permit or interim status from EPA, must comply with HAZWOPER.

Operations that generate hazardous waste but are not TSD facilities.

Businesses that generate hazardous waste as a byproduct of their production operations, store it for a short time, and then send it to a TSD facility, must comply with HAZWOPER.

VSQGs (Conditionally exempt small quantity generators) are exempt from HAZWOPER. However, they must comply with the emergency response requirements in HAZWOPER:

If you require your employees to respond to emergencies in areas that store hazardous waste and/or substances, you must comply with the applicable ER requirements in HAZWOPER.

You do not have to comply with the applicable ER requirements in HAZWOPER if you require your employees to evacuate the facility during an emergency and they do not assist in the response. You still need a compliant emergency action plan.

Operations that respond to emergencies involving releases of hazardous substances.

Emergency response operations caused by uncontrolled releases of hazardous substances where your employees respond, no matter where they occur, you must comply with HAZWOPER.

There are two types of storage areas: the satellite accumulation area and the main hazardous waste storage area.

Satellite Accumulation Areas

The satellite accumulation area is an area at or near the point of hazardous waste generation and under the control of the operator of the process generating the waste.

At or near the point of generation and under the control of the process operator means the satellite accumulation area cannot be in the next room, through a doorway or too far away from the process. The main hazardous waste storage area can be anywhere at the facility and is where the facility stores their waste before being sent off-site for treatment, disposal, or recycling. There can also be more than one main storage area. The requirements for each storage area are listed below.

Can accumulate up to 55 gallons of non-acute hazardous waste or one quart of acute hazardous waste.

Required to date the containers when the above quantity limits are reached so that the generator can remove the hazardous waste to the main hazardous waste storage area or ship the wastes off-site within 3 days of reaching the above limits

Need to keep the containers closed except when adding or removing wastes; and

Must mark the containers with either the words “Hazardous Waste” or with other words that identify the contents of the container.

Central or Main Hazardous Waste Storage Area

The main hazardous waste storage area can be anywhere at the facility and is where the facility stores their waste before being sent off-site for treatment, disposal, or recycling. There can also be more than one main storage area. The requirements for each storage area are listed below.

Required to comply with the hazardous waste time and quantity limits appropriate to your generator status.

Must keep the containers sealed except when adding or removing wastes, in good condition, and secured from failure (i.e., the container’s material needs to be compatible with the waste)

Must conduct weekly inspections with logbook entries; and

Need to label each container with the words “Hazardous Waste”, a specific description of its contents, and the date on which the container first entered the main storage area.

If you have multiple main hazardous waste storage areas at your facility, you cannot start the clock over again by moving your wastes from one area to another.

Must be identified with signage and other markings to designate the area.

Must maintain aisle space to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes.

Inspectors should be able to walk and squat down between rows of containers and be able to inspect and read each containers label without obstruction.

Containers holding ignitable or reactive waste must be located at least 15 meters (50 feet) from the facility’s property line.

The large quantity generator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction including but not limited to the following: Open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat-producing chemical reactions), and radiant heat.

Incompatible wastes, or incompatible wastes and materials, must not be placed in the same container.

A generator must use a container made of or lined with materials that will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.

A container holding hazardous waste must always be closed during accumulation, except when it is necessary to add or remove waste.

A container holding hazardous waste must not be opened, handled, or stored in a manner that may rupture the container or cause it to leak.

Required labels must be visible.

A person engaged in the off-site transportation of hazardous waste by air, rail, highway, or water.

Because hazardous waste transporters move regulated wastes on public roads, highways, rails, and waterways, they are subject to EPA (RCRA) and DOT regulation.

A transporter of hazardous waste must obtain/have an EPA ID number.

Must transport hazardous waste using an EPA Hazardous Waste Manifest.

Must obey all DOT Hazardous Materials regulations.

Drivers and Transporters must be licensed, permitted and insured to haul Hazmat.

Hazard Analysis is the first step in risk management. A Hazard is a condition, event, or circumstance that could lead to or contribute to an unplanned or undesirable event. During an Analysis you look for potential hazards and what the chances are of an incident occurring that could cause damage or injury. They typically consist of the following elements:

Process: A series of actions that are performed by multiple pieces of equipment or locations in a single system.

Risk: An event that might occur that threatens safety, either human or environmental.

Scenario: The risk assessment and the negative outcome associated with an event (e.g., human injury). A single process can have many scenarios.

What Happened: What changed the expected behavior of the process and lead to a risk.

What If: A condition that could potentially change the expected outcome of the process and lead to a risk.

Cause: The event that results from a change and leads to an undesirable safety or environmental outcome.

Consequence: The undesirable safety or environmental outcome that results from the cause. Together, the cause and the consequence define the risk.

Risk Assessment: Identifies the probability that the risk will have a negative safety or environmental impact and the severity of that negative safety or environmental impact.

Safeguard: A system or device that prevents the risk from occurring or lowers the probability or severity identified by the risk assessment.

Hazard and Operability Study (HAZOP) systematically identifies all of the ways in which operating conditions can deviate from the intended design, with the result being a safety hazard or an operating problem.

Job Hazard Analysis (JHA) systematically identifies all the risk hazards associated to a particular job or project.

HAZOPs and JHAs identify items such as:

• Conditions/hazards in work area.
• Appropriate tools provided and used.
• Correct PPE provided and used.
• All major components, pipes, and valves clearly labeled.
• Are operators trained and able to diagnose alarms
• Safety Data Sheets made available.
• Are work permits in place (hot work, confined space entry, etc.).
• Are hazardous materials (e.g., flammable materials) properly stored.
• Equipment and control system design understood.
• Description of the process technology understood.
• Identification of known hazards associated with the materials and processes being used.
• Past accident and incident experience.
• Overall industry experience with the process.
• Results of previous hazard reviews.

EPA has established a system of labeling hazardous materials to help identify the type of material and threat posed.

Hazard identification is part of the process used to evaluate if any particular situation, item, thing, etc. may have the potential to cause harm. To find and record possible hazards that may be present in your workplace The complete process is a Risk Assessment:

1. Identify hazards and risk factors that have the potential to cause harm (hazard identification).
2. Analyze and evaluate the risk associated with that hazard (risk analysis, and risk evaluation).
3. Determine appropriate ways to eliminate the hazard or control the risk when the hazard cannot be eliminated (risk control).

Hazard identification can be done; during design or a new process beginning, before or during certain tasks, during inspections or after incidents and near misses.

See Hazardous Materials

Household hazardous waste (HHW) is exempt from the U.S. Environmental Protection Agency’s Resource Conservation & Recovery Act (RCRA) regulations.

The quality of being burnable, or capable of burning.

The characteristic which identifies hazardous wastes that can readily catch fire and sustain combustion.

Ignitable wastes can create fires under certain conditions, are spontaneously combustible, or have a flash point less than 60 °C (140 °F).

Hazardous Waste: A device using controlled flame combustion to burn hazardous waste for treatment or disposal.

Incinerators are regulated as treatment, storage and disposal facilities, and are subject to RCRA permit requirements.

Incinerators do not include boilers or industrial furnaces.

Industrial waste can be hazardous or non-hazardous. It the result of a manufacturing process and once it is generated it is unwanted or has no other use, so it must be properly treated and disposed of.  

Examples of Industrial Wastes are:

Waters pretreated or directly discharged to a POTW from an industrial/manufacturing process, wood, cardboard/paper, ash, slag, foundry sand, scrap metal, plastic, and construction debris.

In Oregon an “Industrial Waste” means any liquid, gaseous, radioactive, or solid waste substance, or a combination of them, resulting from any process of industry, manufacturing, trade, or business or from developing or recovering any natural resources.

Federally, “Non-hazardous Industrial Waste” is subject to Subtitle D of the Resource Conservation and Recovery Act (RCRA).

40 CFR Part 257, Subparts A and B, provide the federal requirements for non-hazardous industrial waste facilities or practices.

Under RCRA, a waste is defined as nonhazardous if it does not meet the definition of a hazardous waste and is not subject to RCRA Subtitle C regulations.

Industrial wastes are typically produced in large volumes and so they must be managed in a manner that prevents damage to human health and the environment.

An industrial waste landfill is any landfill other than a municipal solid waste landfill or a Resource Conservation and Recovery Act (RCRA) Subtitle C hazardous waste landfill, or a Toxic Substances Control Act hazardous waste landfill.

It is used to dispose of industrial solid waste, such as RCRA Subtitle D wastes (e.g., non-hazardous industrial solid waste defined in 40 CFR, commercial solid wastes, or conditionally exempt small-quantity generator wastes.

They may also take C&D waste, construction and demolition debris, which typically consists of roadwork material, excavated material, demolition waste, construction/renovation waste, and site clearance waste.

A subset of remediation wastes that are generated from field investigation activities, which are approved and overseen by the State or the federal EPA and are specifically designed to determine the nature and extent of contamination.

IDW will normally be generated during the remedial investigation and feasibility study stage of a cleanup project.

Lab Packing is a packing method used to compliantly transport small containers (bottles, jugs, jars, vials, etc.) containing various hazardous chemicals.

These small containers of hazardous materials and/or wastes are segregated into hazard classes and subsequently by their compatibility and treatment method before being placed into the appropriate outer containers for transport.

Generators that typically require lab packing are R&D, School, College, University, Hospital and pharmaceutical laboratories.

Labeling is applying the required regulatory information to the outside of a container or packaging in order for it to be properly stored or transported.

Storage and/or Transport Labels:

Hazardous Waste

• • The words “Hazardous Waste” or in WA, “Dangerous Waste” when applicable.
  • Contents, such as the wastes name or the chemical
  • Accumulation Start Date
  • Hazardous Waste Label
  • The words “Hazardous Waste” or in WA, “Dangerous Waste” when applicable.
  • Phrase “Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the US Environmental Protection Agency”
  • Generator’s name and address
  • Generators EPA ID#, if applicable
    • When shipping Haz Waste:
      • Add the manifest number and Propper Shipping Name (PSN)
      • The accumulation start date, the date the first drop when into the container
      • The composition and physical state of the waste
      • A statement which calls to attention the particular or primary hazardous properties of the waste (flammable, corrosive, toxic or reactive).

Universal Waste

• • Company (Generator, Shipper’s) Name
  • Company Address
  • Contents (e.g., NiCad Batteries, Mercury Vapor Lamps…)
  • Accumulation Start Date

Used Oil Label

• • “Used Oil”
  • If the oil is a hazardous waste “Waste Oil”, ref. Hazardous Waste Label

Non-Regulated Material / Non-Hazardous Waste Label

• • “Non-Regulated Material”, “Non-Hazardous Waste”
  • Company (Generator, Shipper’s) Name
  • Company Address
  • Contents (e.g., propylene glycol filters)

A specific set of regulations designed to reduce the amount and/or toxicity of hazardous substances being placed in or on the land.

The regulations identify certain wastes that are restricted, and the standards to which they must be treated before being placed in a landfill.

LDR regulations also require analysis and recordkeeping (See 40 CFR 268).

Concentration levels or methods of treatment for hazardous constituents that must be met before land disposal.

LDRs ensure wastes are properly treated prior to disposal. Release. Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment.

May accumulate their waste for up to 90 days before shipping it off-site.

You are a large quantity generator, if in any one calendar month, you:

• Generate 2, 200 or more pounds of hazardous waste, or
• Generate 2, 200 or more pounds of spill cleanup debris containing hazardous waste, or
• Generate more than 2.2 pounds of acute hazardous waste, or
• Generate more than 220 pounds of spill cleanup debris containing an acute hazardous waste, or
• Have on-site more than 2.2 pounds of acute hazardous waste.

A universal waste handler who accumulates a total of 5,000 kilograms (11,000 pounds) or more of all universal wastes (batteries, pesticides, hazardous waste lamps, or thermostats, calculated collectively) at any time.

This designation as a large quantity handler of universal waste is retained through the end of the calendar year in which 5,000 kilograms or more of universal wastes are accumulated.

The US EPA Land Disposal Restrictions Program has created treatment standards to for hazardous waste which ensure that is properly treated before the hazardous waste is disposed

Paperwork required to accompany some shipments of hazardous waste subject to Land Disposal Restrictions (see above).

The certification informs the receiving facility that the waste is subject to LDR standards and explains what the appropriate treatment standards are.

Describes liquids that have come into contact with waste.

Lead-based paints were banned for residential use in 1978, so homes built before 1978 could have lead based paint. It can be exposed or underneath other layers of paints. When paint with lead peels and cracks, it creates lead paint chips and dust.

The chips and dust that collect due to wear, especially around windows, doors, and cabinets create a hazard for lead inhalation and ingestion.

Children are especially susceptible lead and its toxic long-term effects.

If you suspect lead paint, you should have it tested prior to disturbing it (such as during a renovation or demolition) and if lead is present, depending on the levels, you may need to dispose of it as a hazardous or dangerous waste.

Very small amounts of lead are toxic, so any sanding, scraping, , stripping or power washing of lead paint can create a significant hazard.

Disposal regulations can vary between states, but generally household do-it-yourselfers can dispose of lead paint debris as a household hazardous waste, which is exempt from RCRA/EPA regulation. However, commercial and government buildings and entities that generate lead paint debris must follow RCRA guidelines and determine if the lead debris is a hazardous waste and manage it appropriately based on the outcome of that determination.

In Oregon, the homeowner and/or their contractor who have generated lead paint waste from activities such as renovation or lead paint removal in their home can manage this as household waste so long as it is disposed of at a DEQ permitted solid waste landfill authorized to receive this type of waste.

In Washington, lead paint waste and debris from renovation and abatement at residences is considered household waste and can be disposed of as regular trash.

Per the EPA, residential lead-based paint waste may be disposed of in a C&D landfill or a municipal solid waste landfill.

Refers to the technique used to assess environmental impacts associated with all the stages of a product’s life from-cradle-to-grave.

Liquid wastes or materials have free liquids within the container,

Liquids that readily separate out from a solid at ambient temperature and pressure.

The paint filter test determines the presence of free liquids.

Solid wastes or materials have no free liquids within the container

Entrained liquids such as damp rags, wet soils, etc. are solids (they pass the paint filter test)

Wastes that are considered hazardous under RCRA because they meet specific listing descriptions.

A hazardous waste considered hazardous because it meets specific listing descriptions and the danger it presents is considered self-evident.

Large quantity generator. A facility or organization that generates more than 1,000 kilograms of hazardous waste or 1 kilogram of acutely hazardous waste in any month. LQGs are typically considered to be heavily regulated. Among other things, they can typically accumulate hazardous waste on site for no more than 90 days.