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01   /   Introduction: states’ prerogatives and the EPA

The Resource Conservation and Recovery Act (RCRA) is the federal law that regulates the disposal of solid waste and hazardous waste. Although a federal law, it’s peculiar for requiring that the Environmental Protection Agency (EPA) delegate primary responsibility for implementing federal hazardous waste regulations to the individual states.

Thus, individual states can differ from federal guidelines about what constitutes a hazardous waste and how it should be handled. More importantly, in many states hazardous waste management regulations are more stringent than those of the federal government.

Also, different states might have different regulations about “lethality” or "severe toxicity” characteristics when determining if something is a hazardous waste; or they might add to the characteristics already in place per the EPA.

Thus, while it’s necessary to know what the EPA requires for successful hazardous waste management, it’s not sufficient. States can impose regulations that are more restrictive and severe than their EPA counterparts, and they often do.

For this reason, as a service to our customers nationwide, we occasionally zero-in on a particular state to review its regulations for hazardous waste disposal; and the present blog focuses on Florida hazardous waste regulations.

02   /   Florida hazardous waste identification & evaluation

All generators of waste in Florida must determine whether said waste is hazardous, as well as evaluate the “listed” or “characteristic” attributes that make it so. This requires inventorying your wastes and categorizing them as “sewered,” unusable, recycled, or otherwise byproducts of your enterprise.

03   /   Florida hazardous waste generator sizes

The amount of hazardous waste you generate or accumulate in Florida determines your hazardous waste generator category; and each category has its own requirements.

I. Conditionally exempt small quantity generator (CESQG) or very small quantity generator (VSQG). You fall into this category if you generate less than 100 kilograms (220 pounds) per month of hazardous waste, and no more than 1kg (2.2 lbs) of acutely hazardous waste in a calendar month. If you’re a CESQG or VSQG, you don’t need an EPA/FDEP identification number. Florida hazardous waste regulations covering this category also require that you:
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Perform a hazardous waste determination on all your waste generated

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Do not generate more than allowed per calendar month

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Do not accumulate more than 100 kg on your site

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Dispose of your waste only at a site approved by FDEP
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Keep waste disposal/management records at your facility for at least three years

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II. Small quantity generator (SQG). You fall into this category if you generate between 100 kg (220 lbs) and 1,000 kg (2,200 lbs) of hazardous waste, and no more than 1kg (2.2 lbs) of acutely hazardous waste, each in a calendar month. Florida hazardous waste regulations covering this category also require that you:
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Perform a hazardous waste determination on all your waste generated

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Do not generate more than allowed per calendar month

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Place wastes in compatible containers that are in good condition, not leaking, and properly labeled “Hazardous Waste.”

Florida application forms for EPA/FDEP numbers can be obtained from the FDEP Tallahassee office, any FDEP district office, or the FDEP website.

Note: The EPA/DEP I.D. number is site specific. So if you move to a new location, you must get a new one.

For further information, contact:

Florida Department of Environmental Protection Division of Waste Management

2600 Blair Stone Rd. Bob Martinez Center, MS-4560 Tallahassee, FL 32399-2400
Phone: 850-245-8707
www.dep.state.fl.us/waste

III. Large Quantity Generator (LGQ). If you produce 1,000 kgs (2,200 lbs) or more of hazardous waste per month, you’re an LGQ and Florida hazardous waste management regulations for such large quantities are significantly different from those for CESQGs or SQGs—and necessarily beyond the scope of this blog entry. You can get expert advice here. Also, see Florida Hazardous Waste Compliance and Enforcement.

04   /   Florida hazardous waste disposal options

Florida hazardous waste management regulations don’t require all hazardous waste to be shipped offsite for treatment or disposal. There are alternatives. However, according to FDEP guidance, “you should conduct further research at both the federal and state level to confirm their allowance and understand the specific operational requirements.” That said, the alternatives are:

  1. Domestic sewage exclusion. This exemption might allow you to discharge water containing certain dangerous wastes into a publicly owned wastewater treatment works (POTW) that will mix it with sanitary wastes prior to storage or treatment.
  2. Elementary neutralization. For wastes that are hazardous solely for being corrosive, this process uses tanks (or other vessels) to instigate a chemical reaction in which water is formed along with a precipitate (salt compound) through the mutual destruction of the ions that characterize acids and bases, rendering the waste relatively benign.
  3. Recycling. Per the EPA, this is using or re-using a waste as an ingredient in a process; or otherwise harvesting or reclaiming it for energy recovery or other use.
  4. Treatment in accumulation containers. Generators can treat contaminated media in waste accumulation tanks or containers in accordance with applicable requirements. In addition to adding absorbents, you can use any recognized and approved technique to treat waste while accumulating it (e.g., compacting, filtering, or settling) so long as you comply with all applicable requirements.
  5. Burning in small boilers and industrial furnaces. Hazardous waste boilers or incinerators are heavily regulated under the EPA's Clean Air Act and RCRA. Nonetheless, incineration is cited by the EPA to be the best technology for disposing of most organic hazardous wastes because it safely and effectively destroys their toxic constituents and reduces their volume.

05   /   The upshot

You need a hazmat solution that will maximize efficiency, lower the cost, and minimize the compliance risks of doing business in your state. And with over 30 years of nationwide experience specializing in hazardous waste management, you can trust MCF specialists to know what might make Florida—or any other state—unique in matters of hazardous waste disposal.

Don’t go it alone.

We can help you develop a hazardous waste management protocol that takes into careful account the regulatory complexities of your particular state or region to achieve the highest standards of sustainability.

For more information, contact us today. Or phone 866.315.8116

And thank you for reading our blog!

Robert Losurdo

President, COO

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