Facilities must know the quantity of hazardous waste that is generated each month at the plant. The quantity drives the hazardous waste program the generator must follow – small quantity (SQG), large quantity LQG), or very small quantity (VSQG). It is advantageous to be in the smallest generator status legally possible. The federal 8700-12 form or a similar form must be filed when a change in generator status occurs. States that have approved the Hazardous Waste Generator Improvements Rule will allow episodic generation – a one-time allowance for exceeding the generator status hazardous waste quantity amounts. Many states require SQG and LQG to file a form 8700-12 as an annual or biennial generator report. Hazardous wastes must be identified at the point of generation, e. g. at the machine or cleaning process where a solid or liquid waste is generated. SDS’s prove useful in this process of hazardous waste determination. Sometimes testing will have to be performed to determine if a waste is hazardous. NOTE: Written documentation is required for all wastes generated on site to show how you determined whether a waste is hazardous or non-hazardous. D-E-C can help with this process by matter of review or evaluating new waste streams.
The hazardous waste management regulations are specified in the Resource Conservation and Recovery Act. These regulations are and found at 40 CFR 260-299. States federally approved for their hazardous waste programs may have additional requirements. Specific requirements include waste labeling and storage, shipping manifests, emergency procedures, management of incompatible wastes, waste accumulation, written procedures for prevention of fires and explosions, spill procedures, recordkeeping, inspections, and the making of arrangements with the local police and fire departments and hospitals – to name a few. These regulations are some of the most complex issues enforced by the federal and state governments. Because they are detailed and proscriptive, it is easy to not have everything in place that is required. D-E-C can review your hazardous waste management program or assist in development of a program so that none of the requirements are missed.
Facilities may manage fluorescent and mercury bulbs, batteries, aerosol cans (in some states), pesticide containers, and mercury containing equipment as universal wastes. This is a subset of hazardous waste that has easier compliance controls. Some states include additional universal wastes like oil filters and antifreeze. These rules require training, have specific labeling and storage requirements. Shipments are also regulated. Surprisingly, these are some of the most cited violations during hazardous waste inspections. D-E-C can supply needed attention to detail to prevent violations. Written procedures are recommended, and aerosol cans require a spill response and cleanup procedure.
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