Proper hazardous waste disposal is more important than ever, with stricter waste laws on the horizon and growing concern over the impact of waste on the environment.
As a business owner or hazardous waste manager at a company, one of your top questions may involve how to dispose of hazardous waste properly to ensure you are meeting all state and federal regulations. So we put together some of the top questions you may be asking yourself about disposing of hazardous waste.
The Top 5 how to dispose of hazardous waste questions are:
Can I transport hazardous waste myself?
Can I use drop-off sites for business waste?
Should I use a hazardous waste broker?
Does my business need an HMBP?
What should I look for in a disposal company?
1. Can I Transport Hazardous Waste Myself?
Not likely. In many states, including California, it is against the law for any person to transport hazardous waste. The only individuals who may do so are those with valid registration, and the Department of Toxic Substances Control (DTSC) must issue this registration. (One of the key exceptions to this is electronic waste and some types of medical waste, which we’ll address in the next question.)
While it can be tempting to save a few bucks and dispose of hazardous waste items yourself, you and your business could face legal trouble for doing so, no matter if you fall within the requirements to be labeled as small-quantity generators or large-quantity generators.
In fact, in California, it doesn’t matter if your business only generates a small amount of hazardous waste. State law says that Large Vs. Small Hazardous Waste Generator requirements don’t dictate that one requires a registered transporter and the other doesn’t. The quantity of hazardous waste that you generate can impact other requirements like storage, but not when it comes to transporting that trash.
Keep in mind, even if it was legal for you to hop in your company vehicle and haul your hazardous waste to a treatment, storage and disposal facility (TSDF), it’s often not realistic since each facility accepts different types of waste. You could end up spending far more time trying to figure out where to take a type of waste than having a registered transporter haul it away for you.
For example, a specific disposal facility we may only specialize in medical waste disposal, another may focus its efforts on industrial waste like oils, solvents and toxic chemicals. In addition to restricting the type of waste a facility accepts, it likely also limits how much of that waste.
Hazardous waste disposal companies not only legally transport your waste, they will transport it to the appropriate facilities that accept it, even if that means traveling out of state.
2. Can I Use Drop-Off Sites For Business Waste?
If your facility generates certain types of waste in small quantities, you may not always need pick up services. For example, California offers drop-off facilities for medical waste that are designed to make the disposal of hazardous materials easy. These medical waste disposal drop off sites typically accept specific items, however, such as sharps needles and pharmaceutical medications.
These can be a great option if you generate small amounts of regulated medical waste that fall within the parameters of what these locations accept. However, it’s important to double-check that a collection site can accept waste generated from a business, since some may only accept waste from households.
If you’ve just replaced a computer in your business or have a few outdated pieces of electronics you want to get rid of, you may be wondering where to drop off electronic waste. CalRecycle offers a directory on its website that features several companies and organizations that participate in the Covered Electronic Waste Recovery and Recycling Program.
Not every drop-off site accepts the same e-waste items nor the same amounts. Some may only accept products from a household as well rather than businesses, so it’s important to check for quantity requirements and other drop-off requirements that may apply to your company.
Keep in mind that if you are upgrading your facility’s entire computer network system and have several pieces of e-waste to dispose of, you’ll be more likely to require the services of a hazardous waste disposal company that can safely transport the waste.
Whether you drop-off the e-waste or have it hauled away, make sure you clear the devices of any sensitive information that could put your business or its customers at risk.
3. Should I Use A Hazardous Waste Broker?
No! While you may think you are complying with the law and doing the right thing for both your business and the environment, hiring a hazardous waste broker may end up backfiring.
First, a hazardous waste broker is NOT the same as a hazardous waste transporter. Both are two very different things despite their implied intentions.
Brokers typically do not own a hazardous waste transportation business. They act as a middleman between the buyer (you) and the transportation company that takes your waste to a disposal site.
If you’re in the process of looking for a transporter, it’s not unusual to hop online and look for quotes. Once you find a company that seems to fit your needs, you may even take the next step and request that quote. What you will likely not know is that the company you just made the request from is not a hazardous waste transportation company, but a broker.
One of the easiest ways to tell whether a transportation company is legitimate is if it has a physical location on its website. Many brokers only provide a phone number because they are not legitimate transportation companies. You can further read about the differences in our article, Hazardous Waste Transporters Vs. Brokers.
So why is a hazardous waste broker a bad idea? The broker receives your request and then starts calling hazardous waste transportation companies to get a price from them for your disposal. The broker takes the quoted price then marks it up with whatever percentage it wants and submits the quote to you for approval.
In the end, you pay more for a service you could receive directly from a waste transportation company. However, your risk extends far beyond costs. You lose control over who is handling your waste when you work with a broker. There is no way to know who the broker is using to transport your hazardous waste.
That means you run the risk of the broker using an unlicensed transportation company. If something goes wrong during transport, your business is at risk due to cradle to grave requirements.
Hazardous waste brokers also do not need any qualifications to sell you disposal services. These brokerage type businesses could even be call centers handling inquiries and processing orders.
4. Does My Business Need An HMBP?
It may. A Hazardous Materials Business Plan (HMBP) is an important document that contains additional information about hazardous materials used on-site at a facility.
This plan is important to have for all aspects of your operation, including disposal, if you have hazardous materials on site because it provides important information to first responders when there is a threat to public health and the environment. It also satisfies federal and state Community Right-to-Know Act laws that require industries to report on the storage and use of hazardous materials.
The state of California requires a facility to complete a hazardous material business plan if the company handles a certain amount of hazardous materials over the course of a year. These amounts are:
55 gallons in liquid form
500 pounds in solid form
200 cubic feet of compressed gas
Your facility must also create a HMBP if the materials being used are considered to be “extremely hazardous substances,” per Section 355.61 of Title 40 of the Code of Federal Regulations.
Additional state and federal requirements are outlined in this Governor’s Office of Emergency Services document. There are a lot of stipulations, so it is best to check the link or consult a hazardous waste disposal company to help you.
In general, HMBPs include four elements:
Business activities and owner identification
Hazardous material inventory
A site map
An emergency response plan and employee training
Because local authorities may have additional requirements that minimize potential harm to the community, it is important to check with your local or county government agency to determine any additional components that must be included in a plan.
5. What Should I Look For In A Disposal Company?
Many companies are aware that they need a licensed disposal company to help them dispose of their hazardous waste. However, when it comes to choosing the best company for the job, things can get a little more complicated.
That’s because there are an endless number of disposal companies in the market that say they’ll dispose of your waste properly, but not all are reputable. And if they do get the job done, their services may be limited. In fact, an experienced disposal company can assist your business with much more than simply hauling away your waste.
When searching for a hazardous waste disposal pick up company, here are eight qualities to look for in a partner:
Background checks are passed and up to date. The first thing you should check is that it has passed all background checks and holds the appropriate state and federal licenses (such as Motor Carrier Permit, DOT Hazardous Material License, DTSC Transporter Registration, etc.). The California Department of Toxic Substances Control maintains a registered hazardous waste transporter database where you can verify whether a business is a registered waste transporter. This database also provides when the transporter’s registration expires, the transporter’s registration number and the transporter’s location and contact information.
A disposal company should have knowledge of YOUR type of waste. The transporter you work with should also be hazardous waste disposal experts and knowledgeable about the specific type of hazardous waste that your business generates. Each type of hazardous waste has its own specific regulations that must be followed during transport and disposal. Even states have their own different hazardous waste laws, which is important for a transport company to know if it must take your waste to another state for proper disposal.
You receive help developing your waste management plan. There’s always room for improvement in your operations, and the experience of a reputable waste disposal company can help you develop a waste management plan that is thorough and safe.
Waste streams can be identified. While you may already know what hazardous materials you have on-site, occasionally projects may uncover new potential hazards. The best disposal companies can identify uncertain waste streams through profiling and testing to ensure the right facilities receive the correct hazardous materials.
The best disposal companies will look for ways to save you money. Top disposal companies consider themselves your partner and will look for ways to ensure you’re not paying more than you have to for waste disposal services. One way they can do this is by evaluating your waste streams to determine if they can be classified as non-hazardous waste, possibly saving you money on your disposal fees.
You don’t have to worry about burdensome paperwork. Disposal companies should help you prepare manifests and other required paperwork needed for transport.
Proof is provided. Transportation services should always be able to offer evidence that your waste has been properly disposed of at the treatment and disposal facility.
A hazardous waste walk-through program is available. A walk-through program evaluates your waste procedures and catches potential issues before they become costly mistakes. This type of program is consultative in nature and can be a significant help to improving your waste management procedures.
Navigating hazardous waste regulations can be challenging, especially as laws evolve and new requirements are put into place. A high-quality, licensed hazardous waste transporter can help ensure your business is properly disposing of its waste and remains favorable in the eyes of the law.