Preventing hazardous waste violations from infiltrating your company requires a lot of hard work and an understanding of evolving rules and regulations.
To help California companies understand their obligations under the complex Resource and Recovery Act of 1976 (RCRA), we’ve put together this list of hazardous waste disposal best practices.
Here are the top 10 hazardous waste disposal best practices to ensure your facility stays compliant:
- Properly label your hazardous waste.
- Perform hazardous waste determinations.
- Know your responsibilities.
- Fill out waste manifests.
- Manage expired hazardous waste.
- Develop a hazardous waste contingency plan.
- Prioritize hazardous waste training.
- Ensure containers are closed.
- Manage mercury containing waste properly.
- Perform routine inspections of storage areas.
Properly Label Your Hazardous Waste
If you are a hazardous waste generator, you are required to properly label hazardous waste containers. There are
free hazardous waste labels available, but you must ensure the labels include information like the following:
- A clearly visible label that says hazardous waste
- The date accumulation begins
- Composition and physical state of the waste
- Statement or statements that call attention to the particular hazardous properties of the waste (e.g. flammable, reactive, corrosive)
- Name and address of the generator
Proper labeling helps ensure the safe handling, storage and disposal of hazardous materials, protecting both human health and the environment. It also aids in emergency response situations, where clear identification of the waste can prevent accidents and ensure appropriate measures are taken.
Perform Hazardous Waste Determinations
Hazardous waste generators have the sole responsibility to select the appropriate classification for waste they generate. They must know what regulations apply based upon their hazardous waste generator status.
Here are the three steps to making a hazardous waste determination:
Step 1: Determine if the material is solid waste. This involves identifying whether the material is discarded, inherently waste-like or a by-product of industrial processes.
Step 2: Determine if the solid waste is exempted or excluded from hazardous waste regulation. Some wastes, such as certain recycled materials or waste from households, may not be subject to hazardous waste regulations.
Step 3: Determine if the waste is a “listed” hazardous waste. Check if the waste appears on any of the four hazardous waste lists (F-list, K-list, P-list, and U-list) specified by the Environmental Protection Agency (EPA).
Proper hazardous waste determination is critical to ensure compliance with environmental laws and to protect human health and the environment. Failure to accurately classify waste can result in improper handling and disposal, leading to serious legal and financial consequences.
Know Your Responsibilities
It is a major no-no to either mistakenly or purposefully dispose of hazardous waste into municipal dumpsters or
into sewer systems by dumping waste down the drain. Such actions not only pose significant environmental and public health risks but also result in severe legal penalties.
Companies must first understand their hazardous waste generator requirements that dictate the procedures they must follow in terms of hazardous waste disposal and reporting. This includes maintaining proper documentation and records of all hazardous waste activities, conducting regular training for employees handling hazardous materials, and ensuring that all waste is properly labeled and stored.
It is also important that generators understand that the law dictates a “cradle to grave” requirement. All hazardous waste generators are responsible for the proper disposal of their hazardous waste streams, from the moment they are generated to final disposal.
This responsibility includes selecting and using certified hazardous waste transporters and disposal facilities, tracking the waste through its entire lifecycle, and promptly addressing any incidents or spills.
Neglecting these responsibilities can lead to significant fines, damage to the company's reputation, and harm to the environment and public health. Adhering to these regulations not only ensures compliance but also demonstrates a commitment to environmental stewardship and corporate responsibility.
Fill Out Waste Manifests
To properly track hazardous waste streams, a uniform hazardous waste manifest must accompany most hazardous waste that is shipped off-site. This manifest ensures that the waste is documented and traceable throughout its entire lifecycle.
The Uniform Hazardous Waste Manifest is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage and disposal facility (TSDF). It contains detailed information about the type and quantity of waste, the identity of the generator, and the transportation and disposal methods used.
Each party in the chain of shipping, including the generator, transporter and TSDF, signs and keeps one of the manifest copies, creating a cradle-to-grave tracking of the hazardous waste. This tracking system ensures accountability at every stage, helps prevent illegal dumping and facilitates prompt response in case of accidents or spills.
Accurate completion and management of the manifest are also crucial for regulatory compliance and can be subject to inspection by environmental authorities. Using electronic manifests (e-Manifests) is becoming increasingly common, providing an efficient and more secure way to handle and track hazardous waste documentation.
Manage Expired Hazardous Waste
Companies, laboratories, and colleges and universities must take precautions to track and properly dispose of expired
chemicals. Chemicals at the end of their usable lives can be very volatile. If they are mistakenly mixed with other potentially reactive agents, or simply have decomposed due to age and become less stable, they can become a tremendous hazard.
Proper procurement, inventory management and end-of-life disposal practices are the key to reducing or eliminating the risk posed by expired chemicals. Regular audits and inventory checks help ensure that expired chemicals are identified and handled promptly. Implementing a first-in, first-out (FIFO) inventory system can also minimize the accumulation of expired chemicals.
Training employees on the proper handling and disposal of hazardous waste, including recognizing signs of chemical instability, is essential for maintaining a safe working environment. Establishing clear procedures for the disposal of expired chemicals, including the use of appropriate containment and labeling, further reduces the risk of accidents.
Working with certified hazardous waste disposal companies ensures that expired chemicals are disposed of in compliance with all regulatory requirements, minimizing environmental impact and legal liability. Proactive management of expired chemicals not only enhances safety but also demonstrates a commitment to responsible and sustainable operations.
Develop A Hazardous Waste Contingency Plan
A written Hazardous Waste Contingency Plan is a program designed to minimize hazards to human health and the environment from fires, explosions or an unplanned sudden release of a hazardous waste.
The plan lays out an organized, planned and coordinated response to an emergency. The type of contingency plan required for a facility depends on your hazardous waste generator status.
Failure to develop and notify the proper authorities is a violation of hazardous waste laws.
What should be in your hazardous waste contingency plan?
- Emergency Coordinator Contact Information: Names, addresses and phone numbers of all persons qualified to act as emergency coordinators. At least one coordinator must be on call at all times.
- Emergency Procedures: Detailed steps to follow in the event of a fire, explosion or hazardous waste spill, including evacuation procedures, emergency equipment usage, and spill containment measures.
- Emergency Equipment List: A description and location of emergency equipment, including fire extinguishers, spill control materials, protective clothing and decontamination supplies.
- Notification Procedures: Protocols for informing local emergency response teams, police, fire departments and relevant regulatory agencies in case of an incident.
- Facility Layout: Diagrams of the facility showing the location of hazardous waste, emergency equipment and primary and alternative evacuation routes.
- Training Program: Documentation of the training provided to employees on emergency response procedures, use of emergency equipment and communication during an emergency.
- Review and Update Procedures: Regular review and update of the contingency plan to ensure it remains current and effective, incorporating lessons learned from drills and actual incidents.
Regular drills and reviews of the contingency plan are essential to ensure that all personnel are prepared to respond effectively in an emergency, thereby safeguarding both human health and the environment.
Prioritize Hazardous Waste Training
It is important to establish a proper training routine for your employees in order to increase the safety standards of your workplace.
Many contractors are required to use 40 Hour HAZWOPER (Hazardous Waste Operations and Emergency Response) trained personnel as contract specifications indicate and for submittals for bidding.
The HAZWOPER law was meant to be broad and to encompass personnel involved with hazardous materials and hazardous waste management.
Other training should include spill response procedures, personal protective equipment (PPE) use, and emergency evacuation protocols. Regular updates and refresher courses are essential to maintain high safety standards and ensure compliance with regulations.
Ensure That Containers Are Closed
Open containers containing hazardous waste are a common hazardous waste violation.
The laws dealing with hazardous waste containers are very clear. Containers with hazardous waste must be closed and latched at all times except when adding or removing waste.
Additionally, ensure that containers are compatible with the waste they hold and are made of materials that prevent leaks or spills. Regular inspections should be conducted to verify that all containers are properly closed and that there are no signs of damage or deterioration.
Implementing a systematic procedure for closing and sealing containers can further enhance safety and regulatory compliance.
Manage Mercury Containing Waste Properly
The EPA has been cracking down on improper storage and disposal of mercury related products including assessing heavy fines for improper disposal.
Mercury waste includes mercury-containing industrial wastes and also discarded mercury-containing products. Mercury and most of its compounds are extremely toxic and must be handled with care.
Many companies make a critical mistake by attempting to reduce the weight and volume of their waste streams by extracting small amounts of mercury from commercial products and discarding the heavier plastic and metal components. This practice inadvertently changes the waste's classification from a commercially produced universal waste to elemental mercury, which has more stringent handling and disposal requirements.
This can lead to a lifetime of cost for elemental mercury storage. This is a costly mistake.
Perform Routine Inspections Of Storage Areas
Hazardous waste generators are required to perform a weekly inspection of the hazardous waste container storage areas. This free hazardous waste storage checklist can help you make sure you’re crossing your T’s and dotting your I’s.
Make sure you inspect:
- Container integrity for signs of leakage, corrosion or physical damage
- Labeling and signage to ensure all containers are properly labeled
- Storage conditions to verify proper temperature and ventilation
- Spill control measures to ensure they are available
- Access and security to make sure your area is restricted to authorized personnel only
Keep your company in compliance. By following these strategies, a waste generator can reduce the risks of incurring financial penalties and damage to its reputation.
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