Have you ever wondered; what is a hazardous waste profile? One of the requirements of hazardous waste disposal is an onerous piece of paperwork with the rather opaque name “Hazardous Waste Profile.”
(If you have paleo interests in the EPA and its peculiar nomenclature, then you’ll be tickled to know that the Hazardous Waste Profile used to be called a Waste Characterization Profile: a factoid sure to stir admiring interest at your next Zoom meeting.)
The EPA Hazardous Waste Profile requires you to list the chemical properties of waste so as to determine its classification for EPA and DOT shipping requirements.
Bear in mind, a Hazardous Waste Profile is a completely different animal from a Hazardous Waste Manifest. The former documents the chemical constituents of waste; the latter is used to track it from “cradle to grave.”
The info needed to complete a Hazardous Waste Profile should be alive & well in your Waste Analysis Plan, which you were required to file as part of your EPA permit application to become a hazardous waste management enterprise way back when.
You can refamiliarize yourself with the ins & outs of a Waste Analysis Plan here. But for now, just remember that your Hazardous Waste Profile has to do with a specific waste you need to manage, while your Waste Analysis Plan talks about all the hazardous materials you handle.
EPA logic behind the Hazardous Waste Profile requirement
The EPA compels you to create a Hazardous Waste Profile for any episode of hazardous waste removal, and it must be presented to a treatment & disposal facility (TSD) prior to its arrival, otherwise, it’s illegal for the TSD to accept it in the first place. Among the reasons for this:
- Listing every chemical lurking in a hazardous waste allows the TSD to determine in advance of delivery whether they’re legally qualified to accept said waste and—if so—how they’ll manage it (e.g. landfill, incineration, or further processing).
- It also addresses the practical concern about whether the TSD has room for the waste at the time you want to dispose of it.
Remember that any Hazardous Waste Profile you develop has to be presented over your signature (or that of one of your listed managers) to guarantee its truthfulness. Thus, accuracy is vital for avoiding EPA fines, sanctions, or maybe even a protracted residency in a gated community (without access to the keys).
As we’re fond of counseling when it comes to EPA mandates: get expert advice.
And here’s an interesting corollary: an analogous profile is required of any non-hazardous waste you want to ship offsite to a TSD. In other words, hazardous or not, you must analyze a waste, document what you find, and present the info to the TSD before you transport it, and they can accept it. Again: get expert advice.
Required content for a Hazardous Waste Profile
A typical hazardous waste profile form will ask for such esoterica as:
- The chemical composition of the hazardous waste
- How it was created (End-of-life chemical? Industrial byproduct? Accidental spill?)
- Its form (Liquid? Solid? Sludge?)
- Whether it’s odorous
- Whether it’s volatile and (if so) its flashpoint
- Whether you intend to transport it in boxes, drums, or whatever
- Its EPA hazardous waste code
- Its DOT description
Hazardous Waste Profiles must be kept current
If you routinely ship a specific type and quantity of hazardous waste to a TSD, it makes sense that you would send it accompanied by the exact same Hazardous Waste Profile. However, you need to be careful that the scientific or industrial process that generates that waste has not itself evolved over time.
In such a case, the chemical composition of the waste might have changed significantly from the first time you developed its Hazardous Waste Profile. Thus, it’s a good idea to review each Hazardous Waste Profile to ensure it remains true to the hazardous waste you’re delivering to the TSD.
One way to ensure the accuracy of your Hazardous Waste Profiles is by conducting annual profile reviews with your TSD vendor to vet each one you have on record.
Get Expert Help
The requirements for completing and maintaining a Hazardous Waste Profile are many and can change with the political winds: one more reason why it’s crucial to partner with a reputable hazardous waste management company that has demonstrable knowledge, experience, and resources to help you complete one accurately.
Although a hazardous waste disposal company cannot legally complete a Hazardous Waste Profile for you, they can provide expert guidance.
For more information, contact us today. And thank you for reading our blog