How small businesses can manage hazardous waste: A guide
Friday, August 28, 2020
Many small businesses are not even aware that they generate hazardous waste.
Hazardous waste is any solid, liquid or gas that is either chemically or biologically treated, burned, incinerated, or recycled. In the absence of waste management regulations, some companies dispose this waste directly into barren landmasses, rivers, and streams.
Hazardous wastes are mostly liquids that are measured in gallons. According to the EPA, small businesses that generate between 100 and 1,000 kg (220 and 2,200 lbs.) of hazardous waste per month are called Small Quantity Generators (SQGs).
Is Your Small Business A Hazardous Waste Generator?
Small businesses in the following categories typically generate hazardous wastes:
- Dry cleaning
- Furniture manufacturing and refinishing
- Construction, demolition and reconstruction
- Vehicle maintenance
- Equipment repair
- Pesticide users/ application services
- Educational and vocational shops
- Photo processing
- Leather manufacturing
Why is Hazardous Waste Management Important?
Disposing hazardous waste directly can cause serious environmental and health implications. It can pollute surface soil, making it unfit for farming. The waste can also percolate through the aquifers to mix with freshwater bodies that supply drinking water to animals and human communities.
Without hazardous waste management, your business can also land in serious legal trouble. The Resource Conservation and Recovery Act (RCRA) of the U.S. Environmental Protection Agency defines a framework for disposal of hazardous solid waste and helps businesses comply.
Identifying the Types of Hazardous Waste Your Business Generates
The hazardous waste your business generates can be classified into three broad categories.
1. Listed Waste: The waste your business generates can fall into any of the four categories defined in the list published in Code of Federal Regulations - Title 40 CFR Part 261 Subpart D. The list is defined by four main codes — F, K, P and U — with over 500 subcategories. For example, spent solvents are defined with codes between F001 and F005 whereas sludge from treatment of electroplating is defined by F006.
Some waste materials are considered so hazardous that they are harmful to humans even after treatment, such as beryllium powder and certain pesticides.
The F & K lists: These wastes defined in 40 CFR section 261.31 are not specific to an industry, and can be divided into groups:
- Electroplating and other metal finishing wastes.
- Dioxin-bearing wastes.
- Chlorinated aliphatic hydrocarbons.
- Wastes from wood preserving.
- Petroleum refinery wastewater treatment sludge.
- Multisource leachate.
- Spent solvent wastes.
- The K-List defines 13 categories of hazardous waste that are industry-specific. They are defined in detail in 40 CFR section 261.32 –Wood preservation.
- Petroleum refining.
- Veterinary pharmaceutical manufacturing.
- Inorganic pigment manufacturing.
- Inorganic/Organic chemicals manufacturing.
- Explosives manufacturing.
- Iron and steel production.
- Primary aluminum production.
- Secondary lead processing.
- Pesticides manufacturing.
- Primary aluminum production.
- Ink formulation.
To indicate the reason for listing each waste category, EPA has assigned a code against them.
The P & U lists: The P and U lists of CFR define hazardous wastes from discarded commercial chemical products. It must meet either of the three criteria:
- The waste must contain at least one chemical listed under the P and U list. The complete list can be seen under 40 CFR section 261.33.
- The chemical to be disposed with the waste must be unused.
- The chemical must be of commercial use grade.
2. Characteristic Waste: Hazardous wastes are further divided into four categories by EPA depending upon their characteristics.
Ignitability: Liquids that have flash points below 60 C, non-liquids that ignite under specific environmental conditions, ignitable compressed gases, and oxidizers.
Corrosivity: Aqueous waste with pH level less than or equal to 2, and greater than 12.5 based on the liquids ability to corrode steel.
Reactivity: These wastes tend to react with environmental factors such as water and heat. They can explode and are considered unstable.
Toxicity: Wastes that are harmful if ingested or absorbed are considered toxic, and have the ability to pollute groundwater. Toxic waste can be tested via Toxicity Characteristic Leaching Procedure (TCLP).
3. Mixed Radiological and Hazardous Waste: This comprises waste that is a mix of hazardous and radioactive material. Mixed wastes are regulated under RCRA and Atomic Energy Act. Hazardous components are managed by EPA and RCRA. Radioactive components are managed by the Department of Energy (DoE) and the Nuclear Regulatory Commission (NRC).
When you have identified the category and the type of waste your business generates, you are required to dispose of the waste based on the guidelines laid down for each category.
Managing and Disposing Hazardous Waste On-Site
Businesses that are SQGs can accumulate the waste on-site for up to 180 days without a permit. They can accumulate the waste for up to 270 days if it needs to be shipped for a distance more than 200 miles.
All SQGs must have safety and emergency response guidelines including:
- A detailed and written contingency plan.
- An efficient alarm system for all personnel.
- Connectivity with local police and fire departments for emergencies.
- Availability of portable fire-control devices, and spill control and decontamination equipment.
- Adequate water supply and pressure, form-producing equipment, and automatic sprinklers.
This list will give you a snapshot of the type and quantity of tanks commonly used for storing and managing hazardous waste, in municipal, environmental remediation, refineries and other applications.
How Can you Get an EPA Identification Number?
If you are an SQG, it is mandatory to obtain an EPA Identification Number. It is a 12-character number that helps the EPA track and monitor hazardous waste and disposal when you send it offsite to be managed.
You can obtain an EPA Identification Number by following these steps: Contact the hazardous waste management agency in your state to obtain the EPA form 8700-12, “RCA Subtitle C Site Identification Form” (Site ID form). You can also download the form online from EPA website, and send it to your respective state agency. The EPA website also gives all the instructions that will help you fill the form.
You must list the hazardous wastes your business generates along with their EPA Hazardous Waste Code available from 40 CFR Part 261. You need to submit a separate form for each site where hazardous wastes are generated. Each site will receive a unique EPA Identification Number by your state agency.
When you submit the form, the EPA will assign your facility a unique identification number. If you shift your facility, you need to inform the EPA which will either assign you a new ID or allocate you the number which was previously associated with your new facility. Starting from 2021, all SQGs will need to re-notify the EPA every four years using the same form. If your business moves into VSQG or LQG category, you need to contact EPA and resubmit the form.
How Does EPA Help Small Businesses Avoid Violations?
EPA along with your state’s hazardous waste management agency provides comprehensive guidelines and resources for small businesses. The EPA Frequently Asked Questions (FAQs) cover various topics for managing and disposing hazardous waste. Relevant sections of CFR include:
- 40 CFR Part 761 (handling PCBs and polychlorinated biphenyls).
- 40 CFR Part 372 (reporting of toxic release).
- 40 CFR Part 403 (reporting of domestic sewage).
- 49 CFR Parts 171-180 (transportation of hazardous materials via shipping vessel, rail, aircraft, or public highway).
EPA also provides industry-specific RCRA in Focus booklets in multiple languages, which helps industries gain knowledge of hazardous waste management. Each industry-specific booklet has a unique code. For example, the booklet for Leather manufacturing is coded EPA 530-K-00-002.
EPA also has an eDisclosure program which allows businesses to self-report any violations with a penalty reduction program.
Sometimes SQGs cannot assess all the compliances themselves. In order to avoid any penalties due to violations, it is recommended to conduct third-party audits that ensure all aspects of the hazardous waste management regulations are being followed.
EPA Guidelines for Small Quantity Generators (SQGs)
Storage containers such as frac tanks and weir tanks in both open-top and closed-top configurations are used to store hazardous waste on-site. The EPA guidelines state that:
- SQGs must label all containers as "HAZARDOUS WASTE" with the date on which accumulation started.
- The steel container should be lined with appropriate material that is inert to the waste. This prevents any possible ignitions, reactions, and explosions.
- Keep all containers in a defined and confined area unless they are being used to fill or drain the waste. The storage space should be safe enough to avoid leakages or accidents.
- Inspect the containers and the area where they are stored at least once a week. Look for any leaks, corrosion or other kinds of deterioration.
- Change the containers if the one which you are using currently is no longer fit to store the waste.
- Do not mix incompatible wastes.
Waste minimization is always better than waste management. You can minimize all the effort by simply following these practices:
- Increase the efficiency and save money by replacing a material or process with another that produces less waste. For example, you can use sandblasting to remove paint than using stripping solvents.
- Try to recycle and reuse the waste rather than disposing it. Items such as oil, solvents, acids, and metals can be easily recycled and reused.
All the standards and procedures to store and manage hazardous waste can seem daunting for a small business. But if you follow the guidelines set by EPA, you can meet the goals without having to worry about violations and penalties.
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