How Can Small Businesses Manage Hazardous Waste?

Attracting hefty fines from the Environmental Protection Agency (EPA) is the last thing your small business needs.

Businesses across industries must stay up to date when it comes to proper hazardous waste disposal. Take pharmaceuticals, for instance. In February 2019, the EPA prohibited “down-the-drain” hazardous waste disposal by pharmas, along with other changes.

Why is hazardous waste management important?

Hazardous waste can adversely affect communities, pollute sites, and can even hit your bottom-line. Effective hazardous waste management not only prevents health, safety and environmental problems, but also ensures your business is compliant with regulations.

Your business has to not only ensure correct hazardous waste disposal, but you also have to stay updated with the latest criteria in the Resource Conservation and Recovery Act (RCRA).

Which Type of Hazardous Waste Does Your Business Generate?

Knowing if you generate hazardous waste is crucial. There are two broad types of waste:

1. Listed waste. Under the Code of Federal Regulations (Title 40 of the CFR, Part 261), there are many types of wastes listed which are classified as hazardous. These are divided into four different lists of hazardous wastes and are designated with codes – F, K, P and U.

  • The F List – These are solid hazardous wastes from non-specific sources such as –
    • Dioxin-bearing wastes
    • Wastes from wood preserving
    • Multisource leachate
    • Spent solvent wastes
  • The K List – These are solid hazardous wastes from specific industries like –
    • Organic chemicals manufacturing
    • Pesticides manufacturing
    • Primary aluminum production
    • Ink formulation
  • The P and U lists – The chemicals from the P list are classified as acute hazardous waste while the U list chemicals are toxic wastes. Some examples are –
    • Discarded commercial chemical products
    • Manufacturing chemical intermediates
    • Off-specification commercial chemical products

2. Characteristic Waste. If the waste generated by your business does not fall into the above list but has certain characteristics that could potentially harm the environment, it falls into the characteristic waste category. Characteristic waste can potentially lead to fire, cause corrosion in metals, tend to be explosive, can produce toxic fumes, or can be fatal if ingested.

Once you have identified the category and the type of waste they generate, your business is required to dispose of the waste based on the guidelines laid down for each category.

What does disposing of hazardous waste on-site involve?

Hazardous waste disposal for small businesses generally involves accumulating the waste generated and then shipping it off for storage, treatment, or disposal. On-site management of hazardous waste involves taking adequate measures during accumulation to prevent the waste from potentially causing harm to your health and the environment.

What type of waste generator is your business?

Before you decide on the method of waste disposal, it’s important to understand the kind of waste generator your business falls under, based on EPA regulations. Regulatory compliances are different for each category of waste generators. The EPA identifies three kinds of waste generators.

Type Waste Generation per Month
Very Small Quantity Generators (VSQGs) Less than 220 lbs. (100 kg)
Small Quantity Generators (SQGs) Between 220 lbs. (100 kg) and 2200 lbs. (1000 kg)
Large Quantity Generators (LQGs) More than 2200 lbs. (1000 kg)

How to obtain an EPA Identification Number

VSQGs are exempt from some of the hazardous waste regulations that apply to small and large quantity generators (SQGs and LQGs). If you are either an SQG or LQG, it is mandatory for you to obtain an EPA Identification Number, which is a 12-character number that helps the EPA track and monitor hazardous waste activities.

You can obtain an EPA Identification Number with the following steps:

  1. Call or write an email to your regional EPA office regarding your requirement. First, fill the EPA form, which can be obtained from your EPA office. Visit the EPA’s How to Obtain EPA Identification Numbers page to find the form and additional information.
  1. In the form, you must list the hazardous wastes generated by your business along with their EPA Hazardous Waste Code. This code can be obtained from 40 CFR Part 261 or your regional EPA office. You need to submit a different form for each site where hazardous wastes are generated as each site receives a unique EPA Identification Number.
  1. Submit your form to your state hazardous waste contact. After evaluating and processing the form, the EPA will assign a number to your site. You can continue with the same number if you shift to a new site, but you need to notify to EPA. Otherwise, you will be assigned a new number.

What’s the EPA doing to help small businesses handle violations?

  • The EPA’s eDisclosure program began a portal in 2015 that has allowed businesses to report self-disclosed violations of environmental law easily. This step resulted in a 75% increase in annual self-disclosures over the first two years.
  • The agency is renewing its emphasis on self-disclosed violations and plans to supplement Frequently Asked Questions on eDisclosure and audits.
  • The agency also offers opportunities to improve compliance and flexibility to new owners who self-disclose violations and also has a penalty reduction program for small entities.

EPA hazardous waste guidelines for Small Quantity Generators (SQGs)

As small businesses, it’s important to make sure you know the guidelines laid down for SQGs by the EPA. 

  1. You cannot accumulate more than 13,228 lbs. (6000 kg) on-site for more than 180 days without a permit. Only under special cases, such as the disposal facility being more than 200 miles away from your site, can you accumulate the waste for 270 days. If the waste generated exceeds 55 gallons near the point of generation, it must be shifted to the point of accumulation (180/270 days accumulation site) in 3 days or less. 
  1. You can only store your waste in tanks or containers that meet EPA requirements. These requirements are as follows:
      • The container should be labeled as ‘HAZARDOUS WASTE’ along with the date it was generated
      • The container should be made of or lined with a material that does not react with the hazardous waste
      • With the exception of adding or removing waste, the container must be kept closed. The handling, storage, and opening of the container must in no way cause rupturing or other physical damage, which can lead to a leak.
      • The area in which the container is stored must be inspected frequently for leaks or corrosion-related deteriorations
      • If the container faces any damage, the contents of the tank must be immediately shifted to another tank that meets EPA regulations
      • You must not mix incompatible waste or materials in the container which might lead to potential hazards

Consult and source containers and tanks from certified manufacturers that are EPA compliant.

Adapting to new hazardous waste management and handling regulations might seem daunting. However, working with the EPA, understanding their guidelines, and partnering with experts in hazardous waste transport, containment and disposal using the right equipment can help you meet business goals without worrying about violations. If you are looking to rent or buy liquid storage tanks and spill containment berms for your business, get in touch with us at Ironclad Environmental Solutions.