Hazardous waste sampling is a process required by the EPA for any company which creates byproducts that might be dangerous to the environment or people. Companies whose production creates a potentially hazardous byproduct are responsible for determining the short and long-term effects of their waste on both people and the environment.
On top of that, federal regulations require "cradle-to-grave" monitoring of any hazardous waste. This means that your business is responsible and liable for that waste until it is properly disposed of.
Knowing how to properly sample hazardous waste streams is not only required by the EPA, but if done correctly, can save your business a lot of money in disposal costs. The question many business tend to grapple with is...Can they adequately perform their own sampling process or do they need outside help?
Everything starts with identifying whether the waste that a generator produces is hazardous or not.
The definition of hazardous waste is quite complicated and is found in 40 CFR, Part 261, "Identification and Listing of Hazardous Waste." Broadly, RCRA considers all discarded hazardous waste as "solid" waste. It is more specifically defined in the Resource Conservation and Recovery Act of 1976 under title 40, section 261. Solid wastes include any solid, semisolid, liquid, or even containerized (compressed) gas waste listed under section 261 of the RCRA. This definition breaks down further into two categories:
If your business produces any waste which conforms to the above definitions you need to move on to the next step in the process.
Unless the waste which your business produces is on the exempted list under the RCRA, you have to test for whether or not your waste is hazardous. This can be accomplished in two ways under the RCRA:
If your business treats, stores, or disposes of its own waste you have to take extra steps to be RCRA-compliant, and therefore, be considered a TSD facility. This is necessary if your facility stores hazardous waste for more than 90 days before moving it off-site for disposal or treatment. In addition to this, to remain RCRA-compliant your business must create and follow a Waste Analysis Plan (WAP) and submit that WAP to the EPA when seeking RCRA permission. Your WAP must include all of these steps:
The RCRA includes step-by-step instructions for the required test methods under CFR 261, appendices II and III, as well as instructions for the appropriate methods of analysis. More importantly, the EPA requires timely analysis for the samples to be considered valid.
Most labs which analyze hazardous wastes will provide containers and instructions on the minimum sample sizes. The EPA provides a field book, the SW-846 Test Methods Manual, detailing the required sample types, sizes, and frequency of testing. As an example, the SW-846 requirement for solid waste is 500 grams, whereas for liquids it can vary from one liter to eight liters, while volatile chemicals need to completely fill any container they are in to minimize the chance of contamination.
A number of additional criteria also inform how often you collect samples, where you collect them from, and how many samples are required. For example, if your facility produces streams of hazardous waste which only contain one kind of waste per stream, a single annual test will usually be satisfactory. If, however, your hazardous waste streams are mixed in some way, or you vary your methods of production, multiple and repeated tests may become necessary.
For some mid-sized companies, and especially smaller companies which produce hazardous waste, the need to work with an independent hazardous waste company is an extremely attractive for a number of reasons.
Knowing how to properly sample your hazardous waste is very important. If you are unsure about how to perform a correct sampling, or have no idea where to send the sample, contact your local hazardous waste transportation company for help.