Does my business generate hazardous waste - and what should we do with it?

How much consideration do you give to the waste your business generates? If any of your waste is considered hazardous under Federal and State regulations, then mishandling or improper disposal can result in massive fines and penalties that can quickly wipe out profits.

Hazardous Waste Regulations

If you’re a business owner, your top priority is to make a profit. You do that by making quality products and then finding and retaining customers. You focus on getting the best price for quality materials as well as production efficiencies to control your costs. That’s all as it should be, but how much consideration do you give to the waste you generate? If any of your waste is considered hazardous under Federal and State regulations, then mishandling or improper disposal can result in massive fines and penalties that can quickly wipe out profits.

If you generate solid waste, you’re required to determine if it is hazardous. A solid waste is defined as a solid, liquid or gaseous material that is discarded by disposal, burning or recycling. Your waste is considered hazardous if it contains items on any of four lists (F, K, P and U) published by the Environmental Protection Agency (EPA) in 40 CFR Part 261. Waste materials that make these lists are known to be harmful to human health and the environment when improperly managed.

Waste materials that are most hazardous make the P-List (acutely hazardous) or the U-List (toxic). There are six hazard codes for wastes that make these lists:

Hazard CodeHazard
IIgnitability Characteristic
CCorrosivity Characteristic
RReactivity Characteristic
EToxicity Characteristic
HAcutely Hazardous

Once you’ve determined that you are generating hazardous waste, you need to calculate your Generator Category by measuring the amount of hazardous waste you generate in each calendar month:

  • 220 pounds—Very Small Quantity Generator (VSQG)
  • 220 to 2,200 pounds—Small Quantity Generator (SQG)
  • 2,200 pounds—Large Quantity Generator (LQG)

If your business is an SQG or LQG, you must obtain and use an EPA Identification Number. The annual registration fee you’ll pay is based on the maximum amount generated in any month of the previous year, not a monthly average.

Accumulating hazardous waste at your production facility can be a danger to human health and the environment so it should be kept on-site only for a short time—unless you obtain a permit. SQGs can accumulate no more than 13,228 pounds of hazardous waste on site for up to 180 days without a permit. LQGs can store greater amounts but must meet strict storage requirements and follow stringent requirements for emergency equipment testing and maintenance, with access to communications or alarms. Employees must be thoroughly trained on proper waste handling and emergency procedures.

Most hazardous waste cannot be disposed on land unless it meets treatment standards to reduce the hazardous components to levels set by the EPA. When hazardous waste is removed from the production site, it must be properly contained to ensure safe transport, correctly labeled and accompanied by a hazardous waste manifest. The hazardous waste manifest tracks hazardous waste from its generation to its ultimate disposal and must be maintained on file to document compliance.

In August 2016, the EPA increased the maximum penalties for certain violations of EPA regulations and environmental law. These higher penalties can be retroactively applied to violations that occurred as far back as November 2015. For many offences, fines doubled or even tripled. Disposing of hazardous waste in the wrong way and hoping you won’t get caught is not a viable business plan. The fines from even a single violation could easily bankrupt your company.

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Mike Watts

by: Mike Watts

Pinnacle Environmental Services

From its inception, Pinnacle Environmental Services, Inc. (Pinnacle) has maintained its focus on providing superior customer service to our customers. We strive to exceed expectations through our comprehensive environmentally-friendly and innovative solutions to current waste management challenges. We are confident in our ability to implement cleaner, greener innovations into your operations, making better use of resources and minimizing waste, all of which serve to reduce the collective impact on our planet. Consider our Total Waste Management Program. We create custom programs for each of our clients and it all begins by listening—a rare commodity in this industry. Rather than make an attempt to sell you a standard package of services, our highly-trained analysts perform an on-site Waste Analysis Study. We talk with management and production staff to carefully examine the waste streams and determine their source and content. This helps us understand the entire trajectory of your operations. With that understanding as the foundation on which to build, we apply our expertise to develop your Total Waste Management Program. And we do more than just develop the program, we work with you to ensure a smooth transition. We deliver on-site training for your management and production staff to ensure everyone understands the new system of waste management. We establish and adhere to a pick-up schedule, using the appropriate vehicles with drivers who are DOT-trained and certified in OSHA hazardous material handling. Our drivers are also certified drug-free! Sustainability is a word that is often used in discussing environmental issues. At Pinnacle, we value sustainability not just in the environmental sense, but also in the lasting relationships we have with our clients. That is why we go to so much effort with the Total Waste Management Program! We want more than just a call for service. We are dedicated to establishing exemplary service and a long-term commitment to your company. Pinnacle has the expertise and training that assures you that we will meet Federal, State and Local Regulations. Compliance is the bedrock philosophy of our management. You will enjoy peace of mind knowing we are handling this critical aspect of your business and confident it will be handled well. You will also enjoy the knowledge that by choosing Pinnacle, you are making our world a little bit greener! So—check us out. We promise outstanding results every day. Give us the opportunity and we will show you how we earn the right to handle your business with our cost effective environmental solutions based on compliance and customer service!

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