Lead’s value to society is considerable and diverse, and its existence in our environment will only increase in the years to come, especially for its application to high-tech batteries as a replacement for politically unpopular fossil fuel technologies.

Yet, lead is dangerous—mortally so. Few things in the world are as useful as lead and yet so commensurately hazardous. Consider:
Lead is a neurotoxin. Inadvertent lead consumption can compromise one’s heart, kidney, and neural functioning. Lead exposure in children is known to cause impaired cognition, behavioral disorders, hearing problems, and delayed puberty. Lead correlates with reduced fetal growth in pregnant women. And although there are medications that can reduce the levels of lead in one’s blood, there are no treatments for the many dire health consequences of lead poisoning.

Clearly, expert hazardous waste management is crucial when any quantity of lead comes to an end of its useful life.

For more information and resources concerning lead disposal, contact us at (800) 936-2311.

2. Are automobile airbags considered a hazardous waste?

Most airbag modules include inflators that depend on sodium azide for generating the gas that “instantly” fills the bag in the event of a crash. When an airbag is deployed, sodium azide is converted into harmless nitrogen gas by other chemicals in the inflator. In fact, a fully deployed airbag can simply be handled as solid waste and disposed of in the garbage.

But sodium azide in isolation is toxic, dangerous to inhale, and can burn exposed skin. Mixed with water, it forms hydrazoic acid, which is also extremely toxic and can enter groundwater when hazardous waste removal precautions are inadequate or nonexistent.

Incidental exposure to sodium azide can occur when untrained workers dismantle vehicles in such a way as to cause the airbag suddenly to deploy. Undeployed airbag modules can also explode when exposed to the heat in an auto shredder.

For more information and resources concerning air bag disposal, contact us at (800) 936-2311.

3. Where can I recycle nylon?

Due to the technical challenges that are common to nylon recycling, there are relatively few recycling facilities that accept it. But there are recyclers who have the specialized equipment and expertise to create post-consumer and/or post-industrial plastics from used nylon, and they compete against one another to obtain it.

Nylon is essentially a simple plastic made from coal, water, and air; and it’s the main constituent in a myriad of household, consumer, industrial, agricultural, and military products. So there’s a lot of old nylon out there, and while not an in-your-face candidate for hazardous material disposal, as a polymer, it doesn’t break down easily. So it’s there to stay when it finds its way into our landfills and waterways.

Compounding the problem, nylon recycling is difficult. Metal, glass, and other “recyclables” must be melted at high temperatures to be rendered into a reusable form. This provides the collateral benefit of incidentally purging any contaminants they might contain, such as microbes, bacteria, and non-recyclable materials.

Conversely, nylon cannot tolerate high heat, and it melts at a much lower temperature. This allows contaminants—organic or otherwise—to remain alive or otherwise unscathed. For this reason, nylon needs to be thoroughly cleaned before it can have a second life as a raw material.

Until recently, this has made the cost of nylon recycling prohibitive relative to simply sourcing it new. But this is rapidly changing.

For more information and resources concerning nylon recycling, contact us at (800) 936-2311.

4. Does the EPA Alcohol Exemption apply to my business?

Solid or otherwise, not all waste that incidentally contains alcohol necessarily requires hazardous material removal.

EPA hazardous waste regulations stipulate that any aqueous solution with a flashpoint below 1400F is ignitable and therefore requires hazardous waste management. However, this rule does not apply to aqueous solutions containing less than 24 percent alcohol.

Per the EPA, “alcohol” is defined as any chemical containing the hydroxyl [-OH] functional group; and a solution is only considered aqueous when it’s at least 50 percent water by weight.

Thus, if the waste is contaminated with a solution that is less than 50 percent water and/or more than 24 percent alcohol by volume, it requires hazardous waste removal. In sum, it is deemed flammable—and dangerously prone to spontaneous combustion when compacted into a trash bin or garbage pail.

If said waste is contaminated with a solution that is at least 50 percent water and less than 24 percent alcohol by volume, it can be disposed of in accordance with the applicable rules for solid waste. It isn’t considered potent enough to self-ignite; or if it should ignite, there’s too much water present for it to sustain combustion. No hazardous waste management is required.

Thus, bars and restaurants don’t have to worry about discarding cocktail napkins, worn bar rags, or frayed table napery that might be booze-soaked, so long as the booze in question is less than 48 proof and more than 50 percent water (48 proof = 24 percent alcohol).

For more information and resources concerning the EPA Alcohol Exemption, contact us at (800) 936-2311.

5. What paperwork is most crucial for EPA compliance?

There is required paperwork that is fairly common across the different kinds of businesses and industries that must deal with hazardous waste or chemical disposal. However, different types of enterprises are required to have updated documents that are specific to their hazardous waste management needs. The eight items below provide a place to begin.

1. Contingency plan for hazardous waste management. This paperwork is required of all hazardous waste treatment, storage, and disposal facilities (TSDF). It’s also required of any entity deemed a large quantity generator (LQG) of hazardous waste. Plans need to be clearly articulated, individual personnel must know their respective duties in case of an emergency, and their contact information must be up to date.

2. Hazardous waste training records for personnel. Individual personnel at LGQ entities must complete annual training, and training records for each must be extant for minimally three years subsequent to his or her attrition.

3. Records of waste determination. You must document how you identified something as hazardous waste and what danger it poses. But just as importantly, you should document how you identified something as not being hazardous waste in the event you’re challenged about it. Such records must be extant for three years subsequent to the last treatment, storage, or disposal of a material.

4. Generator’s biennial report. This must be extant for three years after the due date: generally March 4 of even-numbered years.

5. Hazardous waste manifests. These are integral to most hazardous waste inspections. As a hazardous waste generator, you must keep a copy of the manifest signed by the transporter; a confirmation copy of the manifest with the TSDF’s signature must also be kept on file after the waste is accepted by the transporter. Both must be extant for three years.

6. Land disposal restriction documentation. Certain determination and notification records must be kept onsite for three years subsequent to your shipping hazardous waste offsite to be treated before disposal.

7. Tank and storage area inspection records. If hazardous waste is managed in tanks, such tanks must undergo daily inspections, records of which must be extant until the facility closes, along with an engineering assessment of the tank system’s integrity.

8. Incident reports. In the event of an incident that involves your contingency plan, you must keep records of the time, date, and details until your facility closes.

Keeping these documents at-the-ready so that you can quickly present them on demand will facilitate the inspection process and reduce the inevitable angst that comes with an EPA visit. It will also make for a calmer, happier EPA inspector—which has obvious benefits.

For more information and resources concerning EPA paperwork requirements, contact us at (800) 936-2311.

6. What are the requirements for mixing hazardous waste streams?

Consolidating the waste streams entering your accumulation areas is one obvious way to reduce your hazardous waste disposal costs. Consider:

Combining compatible waste materials into larger shipping containers reduces the number of units you need to ship, lowering your handling and transportation outlays.
The fewer containers you handle and transport, the fewer units there are to be inspected, which lowers your compliance liability (should one or more of them fail to meet regulatory guidelines).

Bear in mind, however, that waste stream consolidation is yet another area of hazardous waste management that demands expert consultation. This is because mixing one kind of waste haphazardly with another can generate dangerous chemical reactions—along with any number of applicable government fines and sanctions that will dwarf any potential savings you were hoping to achieve.

Some chemical constituents of hazardous waste shouldn’t be nearby each other—let alone in the same container—and not knowing which is incompatible with what can make for an unhappy surprise.

For more information and resources about mixing waste streams, contact us at (800) 936-2311.

7. What is the “Hazardous Waste Generator Improvements Rule?”

The Hazardous Waste Generator Improvements Rule is an attempt by the EPA to simplify some regulations for hazardous waste generators, making such rules easier to understand, while providing greater flexibility for hazardous waste management.

Nonetheless, expert advice is advisable. Consider:

By the EPA’s own account, the simplified rules feature more than 60 revisions and new provisions that will impact between 424,000 and 677,000 hazardous waste generator locations, affecting virtually all U.S. industries as well as many other commercial and government enterprises.

Basically, the new Hazardous Waste Generator Improvements Rule includes three main changes:

1. It will allow very small quantity generators (VSQGs) producing 100 kilograms or less of hazardous waste per month to ship their waste to a large quantity generator (LQG) under the control of the same company. According to the EPA, this can reduce a company’s operating costs and environmental liability, encourage greater recycling efforts, and reduce the amount of VSQG hazardous waste being sent to municipal solid waste landfills.

2. Instead of triggering more stringent generator regulations, it will allow a small quantity generator (SQG) or a very small quantity generator (VSQG) to keep its present generator status in the case of a non-routine event. According to the EPA, this can provide relief if, for example, a company generates an atypical amount of hazardous waste in a single month, as in the case of a product recall.

3. It mandates that additional information be provided about the dangers posed by a hazardous waste when it’s being accumulated onsite; as well as amending regulations about communicating such risks to workers, waste handlers, and emergency responders.

For more information and resources concerning the “Hazardous Waste Generator Improvements Rule,” contact us at (800) 936-2311.

8. What is “landspreading?”

“Landspreading” is the practice of returning to the soil a portion of the organic matter and fertilizing elements that might have been removed by harvested crops.

On the simplest level, this is what you do when you set your lawnmower to “mulch,” leaving the grass clippings on your lawn, allowing them to decompose into fertilizer rather than bagging and disposing of them in a landfill. It’s also what farmers do when they “plow under” the remains of a crop and let it compost over the winter.

However, in both these examples, the composted elements were already there.

A more illustrative example is what farmers do when they liquefy the manure from livestock and spread it across their fields. The manure wasn’t in the field in the first place (as were your grass clippings); and by landspreading the manure instead of disposing of it, they avoid the need for hazardous waste management.

What’s intriguing, however, is the fact that an organic waste that’s assessed to have ecological benefits neither needs to be onsite nor solely agricultural to be a candidate for landspreading, as many of the wastes secondary to nonagricultural activities are recoverable for farming benefits or ecological improvements.

For more information and resources about landspreading, contact us today at (800) 936-2311.

9. What are recommended guidelines for hazmat-incident contingency plans?

No matter how large or small your enterprise, you need to consider the environmental damage that might be caused by escaped hazardous materials that are supposed to be under your control—and for which you will ultimately be held legally and financially responsible, regardless of whether such a disaster is man-made (e.g. human error) or an Act of God (e.g. a tornado).

The onset of a disaster is not the time to begin a discussion about whether you’re actually experiencing one—whether major or minor. And the definition of that contingency shouldn’t be left to employees’ ad hoc interpretations of what’s occurring as things begin to unravel.

This is important because recognizing an unfolding disaster should instigate a well-defined and rehearsed contingency plan, with all employees knowing what triggers its implementation.

Our advice: no matter how benign the potential effect, the possible release of any amount of hazardous material into the environment should thrust your contingency plan into motion. This is especially true if circumstances are going to attract attention from mainstream news media, which are prone to sensationalize anything having to do with hazardous waste removal.

For more information and resources regarding contingency plan development, contact us today (800) 936-2311.

10. Do e-cigarettes require hazardous waste management?

Yes. Broadly speaking, e-cigarettes have three main components: a cartridge that holds the flavored nicotine “vaping” solution, a heating element, and a lithium ion battery. Two of these components—the cartridge and the lithium ion battery—require hazardous waste removal:

Without proper hazardous waste disposal, cartridges with residual solution pose a threat to domestic pets and wildlife, should the residual nicotine find its way into the environment, and even to children, should they find the expended cartridges and play with them.

As to the batteries, although the EPA doesn’t regulate the disposal of batteries in small quantities, local jurisdictions might have specific rules for electronic waste disposal. This is because it’s dangerous to toss lithium ion batteries into a trash or recycling bin.

Once in the back of a refuse or recycling truck, surrounded by dry paper and cardboard, pressure and heat can cause lithium ion batteries to spark, causing a rolling inferno. In fact, lithium ion batteries are one of the leading causes of recycling-truck fires.

For more information and resources regarding vape cigarette disposal, contact us at (800) 936-2311.

11. What are the hazardous waste requirements for medical marijuana cultivation and processing?

Commercial marijuana cultivation is wrought with regulatory hazards, and arguably more so than any other category of agribusiness requiring hazardous waste disposal. Thereby, the need for extra caution and expert advice is crucial.

Waste generated from cannabis cultivation differs radically from other kinds of commercial or industrial byproducts requiring hazardous waste disposal. This is because such waste might contain regulated substances under federal law. Treated as regular garbage, cannabis waste can be subject to search and seizure—without a warrant—instigating a costly legal nightmare.

Aside from these federally imposed impediments, spent chemicals used to extract plant oils might themselves require hazardous waste removal. And residual tetrahydrocannabinol (THC)—the chemical responsible for most of marijuana’s euphoric and medicinal effects—can poison animals and have adverse effects on the local ecology if improperly disposed.

Because of the localized nature of hazardous waste enforcement, byproducts from marijuana production and processing must be evaluated against state and regional regulations as well as federal ones. Typically, jurisdictions within and across states consider marijuana flowers, trim, roots, stalks, leaves, and residue to require hazardous waste removing.

For more information and resources regarding hazardous waste requirements for medical marijuana cultivation and processing, contact us at (800) 936-2311.

12. What are the end-of-life disposal requirements for electrical transformers?

The huge inductive coils contained within utility electrical transformers are bathed in oil to absorb heat and prevent them from melting.

At first, polychlorinated biphenyls (PCBs) were employed, since they’re nonflammable and highly nonconductive. Sadly, they’re also extremely toxic; they’re not biodegradable; and they’re absorbed faster than they can be metabolized (or excreted) by animals and humans. Incinerating PCBs generates such poisons as chlorinated dioxins and dibenzofurans, which are even more toxic to humans, animals, and the environment than the PCBs themselves.

Given that rouges’ gallery of drawbacks, production of PCBs was banned in the United States in 1979.Thereby, PCBs haven’t been used in electrical transformers for 40 years, more-or-less. This is good in the obvious sense, but it also means that there’s a lot of legacy equipment in existence that’s nearing end-of-life (or languishing in junk piles) that needs to be disposed, and so doing will require careful hazardous waste removing.

PCBs haven’t been specified inside electrical transformers for nearly 40 years. This is good in the long run. But it also means that there is a great deal of legacy equipment that’s nearing end-of-life that will require hazardous waste management, as PCB contamination is particularly onerous, and the regulations surrounding its disposal are commensurately strict.

It’s also worth noting that mineral oil—the most common replacement for PCBs—might be contaminated with PCBs and thus require a more rigorous level of hazardous waste management than is common for less-toxic waste oils.

For more information and resources regarding hazardous waste disposal for electrical transformers, contact us today at (800) 936-2311.

13. What is biohazard remediation?

Biohazard remediation involves completely cleaning, sanitizing, and deodorizing a site where a fatal accident has occurred. It’s a category of hazardous waste management that requires the handling of human blood, body fluids, and feces; and so workers are potentially exposed to staph, hepatitis, HIV, and other communicable diseases.

Complicating matters is the fact that the need for biohazard remediation has no respect for anyone’s familiarity or experience with hazardous waste removal. Consider:

Owners and operators of entities that routinely require hazardous waste management are familiar with how to stage dangerous waste onsite and secure expert services for its proper disposal.

Conversely, unexpected death can happen at any business or factory; and if your management team has neither the internal experience nor external resources for dealing with hazardous waste removing, then the need for immediate and expert advice is even more compelling.

As with all situations involving hazardous material disposal, biohazard remediation requires special training. No less than three federal agencies contribute to the laws surrounding biohazard remediation. These include OSHA, the EPA, and the Centers for Disease Control and Prevention (CDC).

For more information and resources regarding biohazard remediation, contact us today at (800) 936-2311.

14. What is an EPA Provisional Identification Number?

Perhaps your business or enterprise doesn’t normally produce hazardous waste. But that doesn’t mean the intricate requirements of hazardous waste management couldn’t suddenly be thrust upon you.

If deemed an environmental hazard, a spill or other kind of emergency can set into motion the regulatory prerogatives of the EPA; and what’s totally benign in moderation can be classified as needing hazardous material disposal when in overabundance: spilled milk comes to mind.

Removing what the EPA deems to be hazardous waste from your site—and transported to a state or federally regulated hazardous waste management, treatment, or storage facility—will require you to obtain an EPA identification number. There are two types:

You likely don’t have the first kind: A permanent number, for locations where hazardous waste is managed from ongoing operations. The second kind is what you will need: A provisional number, for locations that need to dispose of hazardous waste right away due to an emergency.

The EPA will assign a Provisional Identification Number that will allow you to dispose of hazardous waste for 30 days. However, other reporting requirements might apply, for which many states maintain a telephone hotline that should probably be in your Rolodex®—or its modern-day equivalence.

For more information and resources regarding an EPA Provisional ID Number, contact us at (800) 936-2311.

15. How and when does the EPA consider a hazmat container to be “RCRA Empty?”

When it comes to hazardous waste containers, what appears empty to you might not be considered so by the EPA. So the containers themselves might be subject to hazardous waste regulation, and inadvertently mishandling them can run you afoul of the law, even after having complied carefully with all hazardous waste management mandates for the material itself.

Regulations defining whether containers are truly “empty” in the eyes of the EPA—and therefore exempt from hazardous waste disposal regulations—are detailed in the federal Resource Conservation and Recovery Act (RCRA). Thereby, in hazmat lingo, the question of import is whether or not a container is “RCRA empty.”

The EPA prescribes three different “emptiness” standards that are necessary and sufficient to avoid hazardous material removal regulations. One is simply for “hazardous waste,” another for “acute hazardous waste,” and a third for “compressed gas hazardous waste.”

You might suppose that hazardous wastes and/or residue remaining in a container (or inner liner) deemed RCRA empty are exempt from EPA hazardous waste disposal rules. This is true for the most part, but you must determine whether removal of the original waste (or its subsequent management) doesn’t in itself produce a hazardous waste. An example might be the residual mixture of waste and cleaning solvent (aka rinsate) left from a triple-wash regimen.

You can avoid the time and expense of handling your empty hazmat containers (or inner liners) as hazardous materials themselves if you can make them RCRA empty, which will also allow you to pursue other recycling or reconditioning options. But as with all EPA regulations, caveats abound, and at the risk of redundancy: Expert advice is crucial!

For more information and resources regarding “RCRA Empty” requirements, contact us at (800) 936-2311.

16. What are recycling and fuel-blending?

One way to lessen the capital cost of hazardous waste management is to recycle the valuable constituents of such wastes for reuse, or blend them into fuel. Beyond the obvious economic benefit, recycling mitigates damage to the ecology by reducing the amount of materials requiring hazardous waste disposal; and fuel-blending has the added benefit of reducing fossil fuel consumption.

For example, a post-manufacture cleansing process that uses acetone will yield a hazardous waste that contains the spent acetone along with the solute it removed (e.g. electroplating residues such as chrome or cadmium). Recovering the acetone by distillation and using it again for the same process (or something akin) is a simple case of recycling for energy recovery.

Contrast this with “fuel-blending,” a process the EPA says is “an important option for reducing petroleum consumption.” Although the thermal energy of the acetone cannot be adequately salvaged in isolation, it burns more efficiently when mixed with other fuels (e.g. gasoline); and the combination can then be used to power one or another industrial process.

You are likely familiar with the idea of fuel-blending from experience at your local gasoline pump. For example, you find so-called E-10 almost everywhere, which is ten percent ethanol. E-85 is 85 percent ethanol. B-2 is five percent biodiesel. There are others—and they are known as “on-spec” for meeting the purity and proportional requirements specified by the EPA.

If there are “on-spec” fuels per the EPA, then you might guess there are fuels that are commensurately “off-spec,” and you would be correct. You must ensure that any fuel blend you receive from a distillery is on-spec for purity and being in the correct proportion.

For more information and resources regarding recycling and fuel-blending requirements, contact us at (800) 936-2311.

17. Can you treat hazardous waste without a treatment permit?

Maybe. In general, any enterprise intending to engage in hazardous waste “treatment” is required to obtain a treatment permit from the EPA.

Bear in mind the agency deems almost any facet of hazardous waste management as an instance of “treatment,” including any effort to make a hazardous waste non-hazardous or less hazardous. It also deems any effort on your part to reduce the volume of a hazardous waste (to facilitate its storage or transport) as an instance of treatment.

Nonetheless there are certain exceptions wherein a treatment permit is not necessary.

Per the EPA, hazardous waste can be treated in tanks, containers, or containment buildings without obtaining a treatment permit (or interim status) so long as you comply with a number of “unit-specific requirements” cited in EPA regulation §262.34, with particular references to Part 265 (51 FR 10146, 10168; March 24, 1986).

That said, there are four specific activities that might not require your securing an EPA treatment permit. These are:

Adding absorbents
Treatments while accumulating
Incidental processing
Disassembling equipment

For more information and resources regarding EPA permit exemptions, contact us at (800) 936-2311.

18. Do state-by-state environmental regulations generally concur with those of the EPA?

Individual states have the power to adopt hazardous waste management regulations that are more stringent than those of the federal government—and a number of them have done so.
In fact, in matters of hazardous waste disposal, the face of the EPA is likely that of your state—not the federal government.

Perhaps most significantly, individual states can differ from federal guidelines about what constitutes a hazardous waste per se, as well as how it should be handled.

Examples might be an industry-specific waste in a state where that industry is common; or a unique military waste in a state with a large military facility; or where the federal government allows certain waste to be placed in landfills, some states do not.

Also, different states might have different regulations about “lethality” or “severe toxicity” characteristics when determining if something is a hazardous waste; or they might add to the characteristics already in place per the EPA.

For more information and resources regarding state vs. federal EPA regulations, contact us at (800) 936-2311.

19. What are the educational requirements for an onsite hazardous waste manager?

While the academic requirements to become a hazardous waste manager vary across employers, in virtually all cases the minimum educational prerequisite is—or should be—an undergraduate degree.

Usually, that degree must be in chemistry or biochemistry, environmental science or engineering, waste management, or toxicology. And given the high legal, financial, and ethical stakes involved in hazardous material disposal, it is not atypical for private and public entities to require a graduate degree of those who aspire to hazardous waste management leadership.

Regardless of degree, the person you have in charge of disposing hazardous waste must have job-specific training about how to handle and remove chemical, biohazard, and radioactive wastes safely.

For more information and resources regarding the educational requirements for an onsite hazardous waste manager, contact us at (800) 936-2311.

20. What are some worthwhile national conferences for hazardous waste management professionals?

Cleantech Forum San Francisco

The Cleantech Forum San Francisco is promoted as “a comprehensive 3?day program (providing) exclusive opportunities to network, learn, and get deals done.”

It brings together corporate executives, startup and growth company CEOs, investors, government agencies, and other luminaries from across diverse environmental disciplines who touch upon hazardous material removal.

Compost

Compost is the annual conference of the US Composting Council, purported to be “the largest gathering of organics recycling professionals anywhere.” Exhibitors and attendees include “municipal and solid waste and recycling program managers, equipment suppliers, consultants, and educators.”

C&D World

The annual C&D World conference is hosted by the Construction & Demolition Recycling Association, which promotes the eco-friendly recycling of construction and demolition materials. Products such as recycling equipment, crushers, and recycling systems are showcased. Educational sessions cover systemic solutions to environmental challenges across recycling and waste management industries.

Global Waste Management Symposium

The Global Waste Management Symposium is a biennial event billed as “North America’s #1 technical conference for the presentation of applied and fundamental research and case studies on waste management.”

Plastics Recycling

The Plastics Recycling conference is for plastic reclaimers, equipment manufacturers, brand owners, brokers, government officials, and other worldwide authorities on sustainability

WWETT Show

The initials stand for Water & Wastewater Equipment, Treatment, and Transport, the wastewater industry’s largest annual event, and it promises “a robust Marketplace Expo, best-in-the-industry education, a festival of live demos, (along with) great parties and events.” Expect over 100 sessions, each with titles like “Active Flow Rehabilitation of a 96” to 108” Sanitary Sewer Interceptor” and “From A-to-Effluent: The Essentials of Septic Tank Design.”

SWANApalooza

SWANApalooza, a convocation sponsored by the Solid Waste Association of North America (SWANA), is actually four events held in one location: the Annual Landfill Gas and Biogas Symposium, the Annual Landfill Symposium, the Road to Zero Waste Conference, and the Spring Training & Exam Center. Topics include safety, technology advances, and such esoterica as food scrap disposal. Networking opportunities include a “fun run,” vendor receptions, and more.

International Conference on Solid Waste Technology and Management

This conference invites researchers, educators, government officials, consultants, managers, community leaders, and other stakeholders to submit papers for oral presentations or poster sessions. Papers related to landfill topics are read (e.g. energy recovery & thermal treatment, household hazardous wastes, solid waste dust, waste collection), as well as those related to recycling (e.g. waste reduction, composting & biological treatment, regulations, medical wastes).

BioCycle West Coast

Although billing itself as “the original and longest-running national conference on organics recycling (emphasis added), BioCycle West Coast has a definite California buzz.

ISRI Las Vegas

Held by the International Scrap Recycling Institute and purportedly the “largest scrap recycling event in the world,” Topics include international trade, human resources, compliance, business valuation, and commodity-specific issues as they have to do with such recyclable wastes as plastic, ferrous and non-ferrous materials, tires, rubber, paper, and electronics.

WasteExpo

WasteExpo is a presentation of Waste 360, an “information, event, commerce, and education provider” to the recycling community. Features over 600 exhibitors among 12,000 attendees. Topics include but are not limited to recycling/landfill, fleet management/collection, organics, safety, and food recovery.

21. What are some worthwhile national associations for hazardous waste management professionals?

Here are four nationally prominent associations that we think should be on your professional radar.

1. The Solid Waste Association of North America (SWANA)
Although not specifically dedicated to hazardous waste removal, this is arguably the premier professional association concerning solid waste management. The association promotes itself as “an organization of professionals committed to advancing from solid waste management to resource management through (our) shared emphasis on education, advocacy, and research.”

2. North America Hazardous Materials Management Association (NAHMMA)
Specific to hazardous wastes emanating from households and small businesses, this association concerns itself with pollution prevention, product stewardship, safety, and cost-effective hazardous waste management. As disposing hazardous waste from households and small businesses goes largely unregulated by local, regional, and national agencies across the United States, NAHMMA is dedicated to providing guidance about best practices for doing so. Product manufacturers, government regulators, and hazardous waste professionals make up the target audience.

3. National Waste & Recycling Association (NWRA)
This organization exists for collection and post-collection waste & recycling “service” professionals (e.g. waste/recycling collection, landfill management, and composting operations) as well as “suppliers” (i.e. businesses that manufacture equipment or design technology for waste/recycling collection and processing). It promotes itself as working “to make trash collection, processing, and disposal operations safer through training, promoting best practices, advancing safety legislation, and setting industry equipment standards.”

4. National Association of Environmental Professionals (NAEP)
The National Environmental Policy Act of 1969 led to the formation of the EPA, and in so doing created a need for “environmental professionals.” Thereby, the National Association of Environmental Professionals (NAEP) was formed to define, organize, and set standards for persons aspiring to the “environmental professional” distinction across a variety of related trades and expertise.

22. What is a waste analysis plan?

Your enterprise requires an RCRA permit if it generates, treats, or stores hazardous materials or is involved with hazardous waste removal. Applying for this permit requires you to create a Waste Analysis Plan (WAP), which is step-by-step protocol for treating, storing, and disposing hazardous wastes such as corrosives, flammables, explosives, gasses, poisons, etc.

Developing a WAP forces you to consider three elemental questions, and the process by which you do so must be documented therein. In essence, these questions are:

1. By what method did you determine the material under consideration to be a hazardous waste?
2. How did you assay its specific nature compared to other wastes that require hazardous material disposal?
3. And with careful regard to that nature, by what process did you determine how exactly the hazardous material must be handled?

Whoever designs you WAP must be trained in RCRA regulatory requirements and knowledgeable about waste characterization and its disposal. Also, he or she must know who establishes and enforces EPA hazmat regulations locally. Additional considerations abound.

Obviously, as in all things concerning hazardous material removal, expert guidance is of foremost importance. When in doubt, seek help from your environmental services company or your local EPA office. Although service companies cannot legally complete a WAP for you, they can provide expert guidance to help keep you in business—and out of court.

For more information and resources regarding waste analysis plans, contact us at (800) 936-2311.

23. What is an EPA Hazardous Waste Profile?

A Hazardous Waste Profile, formerly known as a “waste characterization profile,” requires you to list the chemical properties of the particular type of waste you intend to dispose of or otherwise transport.

Much of the information you need to complete your Hazardous Waste Profile is likely extant in the Waste Analysis Plan you filed as part of your EPA permit application to become a hazardous waste management enterprise in the first place.

The difference between the two, of course, is that your Hazardous Waste Profile is concerned with a specific waste you wish to dispose of while your Waste Analysis Plan speaks to the sorts of hazardous materials you dispose of or transport generally.

The EPA requires you to create a Hazardous Waste Profile for any instance of hazardous waste removal; and it must be presented to the treatment & disposal facility (TSD) prior to its arrival, otherwise it’s illegal for the TSD to accept your shipment at all.

Listing every constituent of your hazardous waste allows a TSD to determine in advance of delivery whether they are legally qualified to accept such waste at all and (if so) how they will manage it (e.g. landfill, incineration, or further processing). It also addresses more pedestrian concerns such as whether the TSD has the necessary capacity at the time.

All that said: bear in mind that any Hazardous Waste Profile you develop must be presented over your signature (or that of one of your listed managers) attesting to its veracity. Thus, accuracy is paramount for avoiding EPA fines, sanctions, or worse.

For more information and resources regarding hazardous waste profiles, contact us at (800) 936-2311.

24. Do OSHA workplace rules affect hazardous waste management?

Definitely. Proper hazardous waste management falls under EPA auspices, but it’s also an integral part of industrial hygiene (aka occupational hygiene or workplace health), which is the central concern of OSHA.

Per OSHA, industrial hygiene “is the science of anticipating, recognizing, evaluating, and controlling workplace conditions that may cause workers’ injury or illness.” And your responsibility thereto is assessed by “industrial hygienists,” who use “environmental monitoring and analytical methods to detect the extent of worker exposure” and “employ engineering, work practice controls, and other methods to control potential health hazards.”

OSHA develops and enforces mandatory occupational health & safety requirements across more than six million U.S. workplaces. If you handle hazardous waste, your enterprise is certainly among them. So do you need access to an industrial hygienist in advance of a visit from OSHA?

Our advice is an absolute yes, because when you read OSHA materials related to workplace hygiene (let alone hazardous waste removing), the language and tone therein are emphatically regulatory—definitely not consultative. In sum, you want to discover violations (real or perceived) before OSHA does.

For more information and resources regarding OSHA requirements for hazardous waste removal, contact us at (800) 936-2311.

25 and 26. How do I “delist” a hazardous waste stream and what is a delisting petition?

The EPA provides a procedure for removing a waste stream from its list of hazardous wastes—if such waste is proven to be effectively innocent of corrosivity, ignitability, reactivity, and/or toxicity. Called a delisting petition, this procedure must be initiated by you (as a waste generator), and as in all things involving the EPA, it’s crucial to get expert advice.

The first step for developing your delisting petition is to determine which bureaucracy wields authority to review and approve it. It’s not unusual for such power to lie with your regional EPA office; there are ten of them throughout the US. However, in some areas of the country, one or another state regulatory agency might take precedence.

We advise asking your EPA regional lead contact about which regulatory body is alpha in your area. Whether it’s your regional EPA or a state bureaucracy, bear in mind that delisting requirements differ across EPA regional offices; and that each state imposes its own rules, procedures, and filing requirements. Understanding how these requirements might interact and impact your petition is crucial.

Paperwork notwithstanding, the lion’s share of your task will be to assay the characteristics and chemical composition of your waste stream so as to support your rationale for delisting it. Logically, when doing so, you’ll want to “position” your petition for the agency with primary jurisdiction.

For more information and resources regarding OSHA delisting requirements, contact us at (800) 936-2311.

27. How do I keep abreast of enforcement trends that are closest to me?

1. Check out the Envirofacts section of the EPA website. It provides single-point access to several agency databases regarding environmental activities affecting air, water, and land anywhere in the United States. Enter your ZIP code to view enforcement activity that might affect hazardous waste disposal in your area.

For a broader picture, Envirofacts allows you to generate data maps for a larger region. You can also investigate specific enforcement topics, which are categorized across Air, Waste, Facility, Land, Toxic Releases, Compliance, Water, Radiation, and other topics pertinent to hazardous materials disposal.

A multi-search function allows you to access several databases simultaneously. You can look for facility information across such categories as Toxic Chemical Releases, Water Discharge Permit Compliance, Hazardous Waste Handling Processes, Superfund Status, and Air Emission Estimates.

2. Know what your peers are doing—or what’s being done to them. Enforcement and Compliance History Online (ECHO) is a public access database of EPA compliance and enforcement data. It allows you to view permit, inspection, and violation information for individual businesses and enterprises involved in hazardous material removal.

These data exhibit a facility’s record with the EPA primarily in relation to the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and Safe Drinking Water Act. You’ll see the dates, types, and seriousness of their violations as assessed by the EPA.

You can also view enforcement actions (both formal and informal) and the attendant penalties these individual businesses and enterprises suffered for their environmental missteps during the last five years—whether sins of omission or commission.

For more information and resources regarding EPA enforcement insight, contact us at (800) 936-2311.

28. Does the EPA require dental clinics to have amalgam separators?

The EPA has mandated that all existing dental practices have amalgam separators installed on dental engines by July 14, 2020. New practices must install them now. These devices are essentially solids-collectors installed on the vacuum lines of dental engines.

As such, they capture any-and-all solids before they can reach the sewer, dropping them into a canister. But notice: amalgam separators don’t separate the mercury from the solids. Instead, the collected amalgam must be (both) removed from the canister and disposed of by a hazardous waste disposal company.

Liability for mercury amalgam waste rests solely with your dental practice until you receive documentation from a licensed and reputable hazardous waste removal company that certifies it was disposed of properly. And you need to retain such documentation in case you’re audited by the EPA—or one or another state environmental agencies.

For more information and resources regarding EPA requirements for amalgam separators, contact us at (800) 936-2311.

29. What is the EPA toxic release inventory?

The toxic release inventory (TRI) is a database of toxic chemical releases and hazardous waste management activities as reported to the EPA by specified industry groups and certain government facilities. It differs from other EPA efforts to regulate hazardous waste disposal, which typically set standards specifying how toxic materials must be handled.

Instead, the chief goal of the TRI program is to publicize the industrial management of toxic chemicals, regardless of whether your hazardous waste management is exemplary or substandard. The underlying strategy is that making the public aware of toxic substances in their midst will generate a commensurate incentive to make industrial chemical-users and toxic-waste generators follow the letter of the law.

The TRI program requires facilities that manufacture, process, or use significant amounts of toxic chemicals to report annually on their release into the environment, whether as solids, liquids, or vapor—whether planned or unplanned. The inventory publicizes these data, and it also includes information about toxic chemicals sent to hazardous waste disposal companies for further waste management.

For more information and resources regarding the EPA toxic release inventory, contact us at (800) 936-2311.

30. What is the EPA “E-Manifest?”

The EPA has launched a national system for tracking hazardous waste shipments electronically. This will be in lieu of the paper manifest that has heretofore done the job.

Per the EPA, the e-Manifest “will modernize the nation’s cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states.”

However— somewhat ominously—one of the other listed benefits is for increased effectiveness of compliance monitoring of waste shipments by regulators.

The e-Manifest will eventually be required in all states, whether a state is presently authorized to run the RCRA program or not; and currently-authorized states will be required to amend their rules to fit the program.

Affected materials include not only the usual federal RCRA hazardous wastes codes but also any so-called “state-only” hazardous wastes, e.g. “paint production waste” for Massachusetts.

You can still use a paper manifest, but it must be accompanied by a check for $20, while filing with an e-Manifest will only set you back four dollars. But bear in mind that the EPA intends to eliminate paper manifests completely within the next five years.

New technology can help you. The first of its kind—and the only comprehensive application for hazardous waste generators of all types and sizes—the PegEx Platform is a new purpose-engineered PC- and mobile-based tool for organizing your hazardous waste management within & across your marketing, sales, managerial, and reportorial data.

For more information and resources regarding the EPA’s new E-Manifest requirement, contact us at (800) 936-2311.

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