We all know that managing hazardous waste is nothing to be taken lightly. We know that it poses a danger to health and/or the environment and needs to be discarded of properly. However, when it comes down to the specifics, it can be confusing. What qualifies as hazardous waste? What is proper disposal? Are there any wastes that are exempt? In order to help you easily navigate all the information, we put together a list of answers to common questions regarding waste and proper disposal.
What is waste?
Waste is any material that no longer has a use. It is a material that has already served its intended purpose and is discarded or in need of being discarded.
How do I know which wastes are hazardous?
You must assume that any waste you generate that could reasonably be a hazardous waste is hazardous unless you document that the waste is exempt or non-hazardous. The process of researching and documenting that a waste is non-hazardous is called evaluation. To evaluate a waste as non-hazardous, you must document that it is both not Listed and not Characteristic. As a waste generator you are responsible for proper evaluation.
What wastes are exempt?
There are a plethora of wastes that are exempt from hazardous waste regulations under certain conditions. Some exempt wastes include asbestos, food handling waste, scrap metal, treated wood and wastewater. For a complete list of exempt wastes click here.
What are Listed wastes?
When wastes are listed, it means that the chemical ingredients in that waste meet the definition of hazardous by one of the four federally-mandated hazardous waste lists.
What are Characteristic wastes?
When a waste chemically reacts in the environment or contains toxic contaminants, the waste is considered characteristic. The five federally-mandated hazardous waste characteristics are as follows: ignitability, oxidizers, corrosivity, reactivity and toxicity. In Minnesota, lethality is also considered a hazardous waste characteristic.
How do I evaluate waste?
Wastes are evaluated both by generator knowledge and laboratory analysis.
Evaluate by knowledge: According to the Minnesota Pollution Control Agency, when you evaluate by knowledge you apply “documented information and scientific or industry-accepted reasoning to determine that waste is not hazardous”
Evaluate by laboratory analysis: When you evaluate by laboratory analysis, you collect samples of waste, run lab tests and compare your results to existing hazardous waste thresholds.
What records must I keep?
When you determine your waste is non-hazardous, you must keep record of this for a minimum of three years. These records must be kept accessible at the sight where the waste was generated for at least three years after you stop generating the waste.
Who else regulates hazardous waste?
There are numerous federal agencies that regulate hazardous waste:
- The U.S. Department of Transportation regulates hazardous materials under the Hazardous Materials Regulations or HMR.
- OSHA regulates hazardous chemicals under the Hazard Communication Standard or HCS.
- The EPA and the MPCA regulate hazardous substances under the Clean Water Act and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or SuperFund.)
Fortunately, you don’t have to know all the ins and outs of hazardous waste management for yourself. You can rely on ISG/IWS. We are your strategic partner in compliance! Contact us to schedule a free phone consultation to see how we can help meet your compliance needs.