Cradle to Grave - The Life and Times of Hazardous Waste (Part 2 of 2)

Proper Handling, Transportation and Disposal

By Sean M. Alvarez, CSP

In last month's Osh Basics, we indicated that there are three fundamental components to the proper management of hazardous waste:

We reviewed the need for accurate waste determination and some important items for you to consider.  Now that you have accurately determined the type of waste you have, you will need to manage that waste properly and arrange for transportation and disposal.

PROPER HANDLING

Since you have determined that your waste is hazardous, you may be considered a hazardous waste "generator".  The first step in proper waste handling is to determine what type of hazardous waste generator you are. 

What type of generator are you?

There are numerous waste management standards that generators of hazardous waste must follow before their waste can be disposed of or recycled.   Use the following table  to determine what type of generator you are:

Type of Generator	Generates
Large Quantity Generator (LQG)	>1,000 kg of hazardous waste per calendar month -or- >1 kg of acutely hazardous waste
Small Quantity Generator (SQG)	Between 100 kg and 1,000 kg of hazardous waste per calendar month -and- Accumulates < 6,000 kg of hazardous waste at any time
Conditionally Exempt Small Quantity Generator (CESQG)	<100 kg of hazardous waste per calendar month -or- < 1 kg of acutely hazardous waste per calendar month -and- Accumulates < 1000 kg of hazardous waste, 1 kg of acutely hazardous waste or 100 kg of any residue from the cleanup of a spill of acutely hazardous waste at any time.

Be aware that many states do not have the CESQG category of generator.  It is important that you review your state's generator definitions so that you can understand which generator standards apply to you.

Obtain an EPA ID number

One way that EPA monitors and tracks generator activity is by assigning EPA ID numbers.  If you generate hazardous waste, you must have an ID number.  Furthermore, it is important that you only do business with transporters and disposal facilities that also have EPA issued ID numbers.  As a generator, you can obtain an EPA ID number from your state hazardous waste agency.

Place the waste in appropriate containers

Proper handling of hazardous waste first begins by placing the waste into an appropriate container.   Fixed tanks and portable containers may be used for hazardous waste accumulation or storage.  Keep in mind that there are regulations pertaining to labeling, air emissions and secondary containment from both tanks and containers.

Generally speaking, tanks and containers must be in good condition, compatible, closed at all times, properly labeled and ultimately managed safely. 

Labels help to identify the material inside the tank or container as a hazardous waste.   Most tanks or containers need to be labeled with the date that the first drop was placed into container. 

Properly store / accumulate the waste

Once the hazardous waste has been placed into an appropriate container and labeled, the waste should be moved to an area designated for storage and/or accumulation of hazardous waste.  Most LQG's refer to this area as a "90 day storage area".  The reason for this is that most waste cannot be accumulated onsite for longer that 90 days without obtaining a storage permit.  SQG's typically have 180 days or more for hazardous waste accumulation and have different handling standards.  Be sure to check the regulations for specifics.

The Uniform Fire Code also has requirements for proper waste storage.  These requirements include such items as aisle spacing and compatibility.  You can consult with your local fire department to determine these requirements.

Satellite accumulation areas are often used at the point of waste generation.  EPA allows the placement of one 55-gallon drum at or near the point of waste generation for the purpose of addressing waste such as lab solvents that is more slowly generated. Keep in mind that accumulation quantities may differ for acutely hazardous and extremely hazardous waste.

You will need to label the satellite drum as a hazardous waste drum, noting the date that the first drop went in.  For the most part, you will have one year to fill the drum, three days to move the drum to the 90-day area once filled and 90 days after filling to dispose of the waste. Satellite accumulation areas can be a good tool but do not let them get out of hand.  Proper inspection and inventory of satellite areas is an essential part of most waste management programs.

Select a disposal method and facility

You must now choose how and where you would like your waste to be disposed of or recycled.  Listed below are several terms that you should be familiar with as you begin evaluation of disposal options:

With increasing technology there are new ways constantly being developed to treat, recycle, reuse or otherwise dispose of hazardous waste. Depending upon the composition of your waste, you could be eligible for substantial discounts for useful materials that can be reclaimed from your waste.  Many states even support online waste trading.  Remember -- your waste could be somebody else's pot of gold!

Regardless of which disposal method or facility you choose, be sure to inspect and research the facility that your waste is being sent to.  Remember that you, the generator, will be responsible for this waste long after it has left your facility and has been disposed of.

Coordinate with Disposal / Recycling Facility

Most Treatment, Storage and Disposal Facilities (TSDF's) will want a sample of your waste so that they may "profile" it.  Simply put, they want to know exactly what is being shipped to them so that they can properly and safely manage it.

After profiling your sample, the TSDF will advise you of what treatment options, if any, may be available at their facility. 

Which is better, disposal or recycle?

This is an answer that only you and your business can determine.  Many argue that landfill costs are less and therefore landfilling is better.  Others argue that recycling, while sometimes more expensive, is the right thing to do every time.  Still others believe that you should consider "lower total cost" over "lower price per pound" each time.

Regardless, you must determine which environmental positions and risks your facility or company is willing to take and how much they are willing to spend.  The responsibility for the waste stays with the generator from cradle to grave.

TRANSPORTATION

Now that you have selected a destination facility, you will need to select a method to get the waste there.

Select a transporter

There are numerous hazardous waste transporters from which to choose.  A transportation broker may be able to help you find the lowest rates.  Keep in mind that the EPA and Department of Transportation (DOT) heavily regulate transportation of hazardous waste.  Therefore, make sure that you have researched the qualifications and certifications of the trucking or rail company you choose. 

Prepare for waste containers for Transportation

EPA has adopted DOT's pre-transport regulations for packaging, labeling, marking and placarding.  In summary, these regulations say that hazardous waste must be properly packaged to prevent leaking during normal transport.  Additionally, the waste containers must be labeled, marked and placarded so that the characteristics and dangers associated with transport are readily identifiable.  Once again, many states enforce stricter transportation requirements than that of the EPA.  Be sure that you are familiar with your state's requirements for pre-transport of hazardous waste.

Prepare the paperwork

The Uniform Hazardous Waste Manifest is the document used for transportation of hazardous waste.  This manifest creates a paper trail for tracking hazardous waste. 

The form is intended to be uniform in structure but some states have their own format. 

Since the generator is legally responsible for completion of this document, make sure that you have been properly trained to complete and sign the hazardous waste manifest.

Many states have requirements for returning a copy of the manifest to the state within a certain amount of days after the waste has arrived at the receiving TSDF.  Make sure that you are familiar with your state requirements regarding manifest reporting.  

Keep detailed records

Finally, recordkeeping is an essential part of any waste management program.  For most documents involved in the hazardous waste process, there is a three year record retention requirement. 

Additionally, there are reporting requirements such as biennial reporting and exception reporting.  Good recordkeeping will aid you in fulfilling your reporting requirements.

Be sure to check with your state regarding required reports and record retention.

What next?

Whether you are a LQG or a SQG, you will want to begin implementing waste minimization programs immediately.  Waste minimization or source reduction programs are now required in many states.  Simply put, such a program will help you to reduce the quantity of waste at the source.  When all else fails and waste must be generated, you should make every effort to recycle or reuse the material in accordance with applicable laws and regulations.

Less waste generated means a reduction in lab fees, handling expense, transportation and disposal costs.  Less waste generated means fewer compliance exposures to your company.  Less waste generated signifies that you have an environmentally friendly company. 

Ultimately, less waste generated means less risk for everyone and for the environment - from cradle to grave.

There are many other regulations pertaining to the storage, accumulation, transportation and disposal of hazardous waste.  These include such items as, employee training, emergency response plans, source reduction, used oil recycling and land disposal restrictions to name a few.   You can obtain information on these items and more at the Environmental Protection Agency waste website .

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