Purchasing Resources for RoHS Regulations

Avoiding Hazardous Waste Trouble

Run a clean business to avoid the EPA, bad press, and a spoiled Earth
By W. Eric Martin, Keyboard pounder & synonym selecter TwoWriters.net By their very nature, some businesses -- such as drycleaners, printers, furniture manufacturers, and construction firms -- create hazardous waste or work with hazardous materials on a regular basis. (In general, a waste is considered hazardous if it's ignitable, corrosive, reactive, or toxic.) You might be tempted to conceal that waste in your regular trash or dump it in some out-of-the-way place, but that strategy can backfire in the long run and place your business in big trouble. By knowing and following the governmental waste-handling laws, you can:

1. Protect the health of your employees.
2. Stay in the good graces of the state and federal EPA.
3. Present your business as an environmentally-responsible firm.

 

Meet the federal regs

The term "hazardous waste" has a specific definition under government regulations, and you need to know whether your manufacturing by-products fall into this category.
Try: The Environmental Protection Agency (EPA) gives short descriptions of the different types of hazardous wastes. For an extensive list of hazardous wastes, look at the Code of Federal Regulations, which includes the EPA waste number for each type of waste. The EPA also has an easy-to-read single page chart of hazardous waste in PDF format.

Meet the state regs

Most states have their own department of solid and hazardous waste with regulations that might differ from the feds. Learn the laws for your state in case you need to register or report waste generation.
Try: The Environmental Compliance Assistance Program (ENVCAP) has links to every state hazardous waste department (and a state environmental agency when no waste department exists). Employees of local waste departments can visit your company and advise you on the proper steps to take.

Get registered

Unless you're keeping all your hazardous materials on site, you need to hire someone to cart it away, which means you need to register with the Office of Hazardous Materials Safety, part of the U.S. Department of Transportation.
Try: Check the requirements for hazardous waste generators. If you fit this category, register online, clicking the "Initial" category if this is your first time.

Check your volume

Your responsibilities differ depending on your volume of waste. If you produce less than 220 pounds of hazardous waste per month, you are a conditionally exempt small quantity generator (CESQG) and federal laws don't require you to keep waste records, although they're still recommended. Produce between 220 and 2,200 pounds monthly, and you're a small quantity generator (SQG). Any more than that, and you're a large quantity generator (LQG).
Try: Florida's Department of Environmental Regulation has a checklist of requirements for SQGs that's generally applicable for SQGs in all states. The Minnesota Pollution Control Agency has an employee training form that covers the handling of hazardous waste that's required for SQGs. The regulations for LQGs are more extensive and include a biennial hazardous waste report that you must file. The short version of the LQC regulations (PDF) runs only four pages, while the user-friendly version (PDF) spans 335 pages. The EPA has helpfully posted a list of common violations by LQGs.

Keep on truckin'

Transporting the waste yourself to a treatment plant is an expensive job that requires a ton of paperwork. You're better off hiring a transporter that specializes in the waste your company produces.
Try: The Missouri Department of Natural Resources has a list of almost 200 hazardous waste transporters from a variety of states. If you can't find a company near you on that list, contact your state hazardous waste department and request a list of transporters.

Give waste a new home

You need to ship the waste to an authorized treatment, storage and disposal facility (TSDF). Each TSDF will handle different materials, so you need to find one that's right for you.
Try: CHWMEG, Inc., a non-profit trade association that conducts independent reviews of treatment facilities has a TSDF search engine on its Web site.

Find a buyer

Believe it or not, another business might be eager to buy your hazardous waste -- or at least take it off your hands for free, which is the next best thing.
Try: Industrial Materials Exchange services are available in Illinois, Kentucky, New Hampshire, Texas, and Washington/Oregon/Idaho among other states. Search Google for "materials exchange" and your state to find a nearby IME. The EPA maintains a list of state-specific exchanges, but not all of these handle hazardous waste.

• Train employees to handle waste with care, post the appropriate warning signs, and have safety equipment available at all times.
• Monitor your waste volumes to make sure you don't cross from a CESQG to a SQG -- and if you do, take the appropriate action.
• Watch for production improvements that can lower your waste volume. If you don't produce it in the first place, you don't have to transport and treat it.