Sadly, managing commercial waste isn’t that simple (or scary). It’s a complicated, costly, and risky business. That’s doubly true when it comes to hazardous waste management.
As a small business owner, it’s your duty to manage hazardous waste responsibly. That means understanding what it is, how it’s regulated, and what you should do to dispose of it correctly.
Fortunately, we’ve got you covered. Here’s everything you need to know about hazardous waste management.
Hazardous waste handled with care? Check.
How Do I Identify Hazardous Waste?
Hazardous waste is any waste with characteristics that make it dangerous to humans or the environment.
If you’re not sure if a certain type of waste is hazardous, the guidelines laid out by the Environmental Protection Agency (EPA) are a great place to start. These list hundreds of types of hazardous waste, and give great advice about how to identify non-hazardous waste.
If the type of waste your business generates isn’t listed, your next point of reference should be the Resource Conservation and Recovery Act (RCRA). This intimidatingly long piece of legislation specifies four general characteristics of hazardous waste: ignitability, corrosivity, reactivity and toxicity.
Still unsure? Ask yourself these quick questions:
- Does it ignite at low temperatures (sub-60 degrees)?
- Can it corrode, dissolve or otherwise damage steel?
- Is there a risk of it exploding, or emitting dangerous gases under normal conditions?
- Is it poisonous to ingest? Is skin contact harmful?
If the answer to any of these is ‘Yes’, you’re probably dealing with hazardous waste. That said, things get even more confusing when you consider the countless exemptions for certain types of seemingly hazardous waste.
We wish we could offer you a simple answer; but a 1,000 word article just won’t cut it. Check out Subtitle C of the RCRA for more information, or complete this short form to request professional advice.
How is Hazardous Waste Management Regulated?
According to the law, you’re responsible not just for removing hazardous waste from your premises, but also for transporting it safely to a secure landfill. In other words, you’re accountable for your hazardous waste “from cradle to grave”.
Hazardous Waste Storage
As a small business owner, the scope of your responsibilities depends on how much hazardous waste you generate. The RCRA rules distinguish between very small, small and large generators:
|Size of Generator||Max monthly generation||Requirements|
|Very Small Quantity Generators (VSQGs)||100kg||Must identify all the hazardous waste generated|
Max 1,000kg waste stored on site at any time
Must deliver waste to authorized person/facility
|Small Quantity Generators||1,000kg||Mustn’t store waste for more than 180 days (270 days for long-distance shipping)|
Max 6,000kg waste stored on site at any time
Must store waste in secure containers
Must have an emergency response coordinator
|Large Quantity Generators||More than 1,000kg||Mustn’t store waste for more than 90 days|
Must store waste in secure containers
Must comply with stricter emergency procedures
Must submit biennial waste report
Hazardous Waste Transportation
If you’re planning on doing this yourself, you’ll need to follow the Department of Transportation’s (DoT) hazardous materials regulations. These rules apply any time you use public roads, railways or waterways to transport hazardous waste. Carriers are required to make special provision for:
- Placarding and marking vehicles
- Loading and unloading
- Blocking and bracing
- Incident reporting
- Security planning
- Employee training
Fines for breaching these regulations apply on top of fines for breaching the RCRA rules.
Hazardous Waste Treatment
Some types of hazardous waste must be incinerated or oxidized before being disposed of. Hundreds of EPA-recognised treatment facilities across the country can provide this treatment. However, be aware that each facility’s capacity varies, which has a direct impact on the cost of hazardous waste treatment.
Hazardous Waste Disposal
Unless you’re an exempt small quantity generator, you can’t use a regular landfill. Instead, you’ll need to find an EPA-approved secure landfill designed to protect groundwater and surface water resources.
Fines for Hazardous Waste Management Violations
Carelessness is costly in the business of hazardous waste management. Since 2016, fines for hazardous waste management violations have nearly doubled, rising from $37,500 per day to $72,718 per day.
To make matters worse, the EPA can retroactively apply these rates to violations that occurred before 2016. Clearly, it pays to get things right the first time.
Whenever potentially hazardous waste is involved, it’s best to seek professional advice. The RCRA is part of federal law, and the EPA enforces it strictly. Ignorance of the law isn’t an excuse for breaking it, so it’s vital to know what kind you’re dealing with before you start disposing of it – especially when mistakes result in such weighty fines.
To arrange a free phone consultation with a top waste management firm, simply complete this short form. One of our trusted advisors will be in touch to assess your needs and help you find the best waste management solution for your business.