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/     Hazardous Waste

01     Compliance

02     Definitions

03     Education and Training

04     Labeling

05     Manifest and Documentation

06     Storage and Accumulation

07     Transport and Disposal

08     Treatment

09     Waste Categorization





Does the EPA require dental clinics to have amalgam separators?

The EPA has mandated that all existing dental practices have amalgam separators installed on dental engines by July 14, 2020 with all new dental practices installing them prior to seeing patients. Liability for mercury amalgam waste rests on the dental practice that generates the waste until you receive documentation from a licensed hazardous waste removal company that certifies it was disposed of properly.


How does the Clean Water Act relate to Dry Cleaners?

The Clean Water Act (CWA) was created to protect the nation’s surface water, including lakes, streams, ponds, and oceans. The CWA controls both direct discharges to surface waters as well as storm water runoff and indirect discharge in the public sewer system. The portion of the CWA most pertinent to dry cleaners involves the statute’s regulation of perc, trichloroethane, and CFC-113, as well as NPDES. Your state water authority, regional EPA office, or local POTW can provide you with additional guidance regarding CWA compliance.


How does the Clean Air Act relate to Dry Cleaners?

Like the CWA, the Clean Air Act (CAA) also regulates pollution, only it focuses on national emissions standards. The CAA regulates the discharge of hazardous air pollutants (HAP), including perc. To remain compliant with the CAA, dry cleaners who use perc must follow several specific prevention steps. CAA compliance requires regular inspection of dry cleaning equipment, leak detection and repair logs, good housekeeping practices, and a record of the total perc amount purchased over the last 12 months. You can contact your local Air Pollution Control District or Air Quality board for additional CAA compliance information.


What is a Hazardous Waste Contingency Plan?

A contingency plan is basically the entire "backup process" you have in place in the event of an accident involving your generated hazardous material. This encompasses both the business-specific system your company has devised, as well as the subsequent written document for training and informing your employees about that protocol.

Everyone who generates hazardous waste is legally obligated to create a Hazardous Waste Contingency Plan irrespective of your EPA generator status and what state the waste is generated (this is a federal mandate)


Who Creates a Hazardous or Non-hazardous Waste Profile?

Whether your generated waste is hazardous or nonhazardous, it’s the responsibility of the waste generator to create the actual profile. It requires a signature from a qualified and trained representative of the business (whether a manufacturer, a hospital or a laboratory) to confirm what’s in the shipment. The paperwork is then sent to the Treatment and Disposal facility, where it’s reviewed to confirm that facility can accept whatever is going to be in that shipment.

Often, the facility requires some form of proof to confirm they are able to accept the shipment. This frequently comes in the form of analytical work or an SDS (Safety Data) sheet in order to confirm the content of the given shipment. This helps the receiving facility ensure they are clear to accept the shipment, and it provides insurance to that facility in case there are ever any discrepancies between what was stated on the profile and what was actually shipped.


How can I be prepared for a Hazardous Waste Inspection?

Firstly, you will not be informed or alerted before a compliance-based inspection. The person leading that inspection will simply show up, ask for the person in charge of your facility, and commence the audit. This can happen at any time.

Because these kinds of inspections can happen without warning, you must be absolutely certain that you comply with all relevant regulations and rules—at all times. Never wing it. Have a thorough, researched hazardous waste management plan, and be diligent about ensuring all employees follow that plan. From using the right hazardous waste label to ensuring you’re using the proper containers, this plan should cover every possible contingency.


What needs to be included in a Hazardous Waste Contingency Plan?

A contingency plan will vary slightly for every company, depending on the type and amount of hazardous waste you produce. Whether you’re a small quantity generator or a large quantity generator, you must adhere to the following guidelines:

Assign one or more people to be the emergency coordinator. Include the contact information for this person (or people) within the plan.
Include the location of both emergency equipment and emergency telephones.
Ensure all employees know this plan exists and are familiar with the procedures. (Obviously, an emergency situation is never planned or expected and can arise at any moment. Therefore, all employees need to be prepared and equipped to respond quickly and accurately to minimize safety hazards.)



What is Characteristic Hazardous Waste? 

Characteristic hazardous wastes possess noxious “characteristics” such as:

    • Flammability—they catch fire under certain conditions, posing obvious transport & storage dangers
    • Corrosiveness—they can disintegrate metals and therefore require storage vessels constructed of (or lined with) anticorrosive materials
    • Instability—they’re prone to explode under heat or pressure; or produce toxic fumes, gasses, or vapors
    • Toxicity—they are harmful or fatal to humans and/or local biota when ingested or absorbed, or can leach into soil or groundwater
    • Reactivity—otherwise benign chemicals might become flammable, corrosive, unstable, or toxic when mixed with others

What are Listed Hazardous Wastes?

Listed hazardous wastes don’t have such intrinsically noxious “characteristics” in and of themselves. Instead, they require hazardous waste disposal because they’re offshoots of manufacturing practices that typically produce a hazardous waste. The EPA keeps two lists of these chemicals, all of them considered a hazardous waste in both their pure and commercial-grade formulations. These are the “P” and “U” lists and contain such everyday meds as warfarin, cyclophosphamide, and lindane.


What are the four types of hazardous waste?

    • When categorizing hazardous waste, the EPA breaks it down by four characteristics
    • Ignitability, or something flammable.
    • Corrosivity, or something that can rust or decompose.
    • Reactivity, or something explosive
    • Toxicity, or something poisonous.

What is an EPA Provisional Identification Number?

Intended for businesses that don't typically generate hazardous waste. A provisional identification number is for locations that need to dispose of hazardous waste right away due to an emergency. Anything, if deemed an environmental hazard, a spill or other kind of emergency, can set into motion the regulatory enforcement of the EPA and require your business to comply with hazardous waste requirements.


When is a hazmat container deemed “RCRA Empty?”

The EPA prescribes three different “emptiness” standards that are necessary and sufficient to avoid hazardous material removal regulations. One is simply for “hazardous waste,” another for “acute hazardous waste,” and a third for “compressed gas hazardous waste.” Part of the challenge with deeming a container "empty" is that you must determine whether removal of the original waste (or its subsequent management) doesn’t in itself produce a hazardous waste. An example might be the residual mixture of waste and cleaning solvent (aka rinsate) left from a triple-wash regimen.


What is a Large Quantity Generator of Hazardous Waste?

LQGs typically generate 1,000 kilograms (approx. 2,200lbs) of hazardous waste per month or more than 1 kilogram (approx. 2.2lbs) of highly-toxic or acutely toxic hazardous waste per month. There is no limit to the amount of hazardous waste an LQG can accumulate on site, though any accumulated waste must be transported or disposed of within 90 days (some exceptions apply). Biennial hazardous waste reports must be submitted by LQGs in order to maintain compliance. Finally, any LQG operation must designate at least one employee as an acting emergency coordinator in case of emergency, and written contingency plans with detailed response measure must be prepared beforehand and be readily accessible to staff and inspectors. 


What is a Small Quantity Generator of Hazardous Waste?

For SQGs, typical hazardous waste generation tends to stay between 100 kilograms and 1,000 kilograms per month. For SQGs, the onsite waste accumulation cannot exceed 6,000 kilograms, though accumulated waste without a permit can be maintained onsite for 180 days or 270 days if shipping of the hazardous waste would require transport over 200 miles. Like LQGs, SQGs must also have at least one employee acting as an emergency coordinator who is available at all times in case of an emergency. SQGs must also provide written contingency plans with detailed response measures available before an emergency transpires.


What is a Conditionally Exempt Small Quantity Generator of Hazardous Waste?

Finally, CESQGs include any operation that generates 100 kilograms or less of hazardous waste per month, or 1 kilogram or less per month of acutely hazardous (highly toxic) waste. Unlike SQGs and LQGs, CESQGs cannot accumulate above 1,000 kilograms of waste over any period of time. In addition, CESQGs must always identify all hazardous waste at their facility. Finally, CESQGs must ensure that any hazardous waste sent off-premises is delivered to a third-party company, landfill, or treatment, storage, and disposal facility (TSDF) has the proper permits and licensing authorizing them to handle and dispose of hazardous materials.


Education and Training

What employee training is required for SQG's generating Hazardous Waste?

Under the RCRA guidelines, an SQG must ensure that all employees are educated in the proper waste handling and emergency procedures relevant to their responsibilities. Large quantity generators (LQG), on the other hand, must have a formal personnel training program in place in accordance with the requirements in 265.16 and 262.34(a)(4). This requires initial training and annual review that teaches proper waste management and familiarizes them with procedures, equipment, and systems to effectively respond to emergencies.



What is the proper labeling for hazardous waste containers?

Every drum filled with hazardous materials requires a yellow hazardous waste label that includes, 1. The words “hazardous waste.”, 2. Your generator information, 3. Any relevant EPA hazardous waste code, 4. Proper DOT shipping name and the Hazardous Waste Accumulation start date.

Does the Accumulation Start date have to be written on a Hazardous Waste Container Label?

Yes! A large quantity generator has to ship all hazardous material every ninety days. Therefore, the label must include that important accumulation start date. If you’re ever inspected or audited, this number must not only be present on the label but be accurate. Failure to comply with regulations can bring financial consequences or even stricter penalties, depending on the severity of the offense and if this is your first violation versus being a persistent problem.


Manifests and Documentation

What are the differences between manifests and bills of lading?

In the field of hazardous waste management, a waste manifest is a piece of paperwork required by the federal Environmental Protection Agency (EPA) and the Department of Transportation (DOT) in order to legally transport hazardous waste materials.

A bill of lading, on the other hand, is used to transport other materials such as biomedical waste. This waste is also known as regulated waste, regulated medical waste, or even red bag waste. These documents can also be used to transport empty containers or containers or boxes of documents for destruction. Essentially, a bill of lading in this industry is simply paperwork that often accompanies waste that is not deemed hazardous.


What are MSDS Sheets?

MSDS stands for Material Safety Data sheets; paperwork that essentially identifies the type of chemical you’re using and how to safely handle that chemical. It can include information such as:

    • The exact chemical constituents of the material.
    • The proper protocol if spilled.
    • The proper protocol if that chemical is ingested, gets in one’s eyes, or gets on one’s skin.
    • Whether the chemical constitutes hazardous material.
    • The concentration of the chemicals.
    • Proper waste disposal methods for that product.

Where do I get MSDS Sheets?

An MSDS (or, now, SDS - Safety Data Sheet) comes directly from the manufacturer of that product. If you need to secure materials safety data sheets for the products you’re using, one approach is to contact the manufacturer directly.


Does my facility require a hazardous waste manifest when shipping hazardous waste off-site?

A hazardous waste manifest must accompany all hazardous waste that is shipped off site. Designed as a multipart form, a hazardous waste manifest is designed to track hazardous waste from generation to disposal (i.e. from when it leaves your facility to the point it arrives at its intended destination)


How long am I required to keep hazardous waste manifests for?

You must retain hazardous waste manifests for three years. In addition, the following records must also be retained for that timeframe:

    • All notices and documentation associated with Land Disposal Restrictions
    • Biennial Reports
    • Exception Reports
    • Any test results, waste analyzes, or similar information related to the waste shipped off-site
    • Your inspection schedule and reports. (Specific inspection requirements are found in 40 CFR 265.15.)

Do I need a Generator’s EPA Identification Number?

An EPA identification number is only applicable if you're generating hazardous waste, furthermore it depends on the following criteria:

    • Your location (specifically what state or district)
    • Whether the waste is hazardous or not
    • How much of the hazardous material needs to be shipped

It is only If you generate less than 220 pounds per month of hazardous materials, that your facility is considered a conditionally exempt small quantity waste generator, and you don’t need an EPA ID number. If you generate over 2,200 pounds of hazardous waste every month, you are a large quantity generator and (like small quantity generators that accumulate in excess of 220 pounds), you need an EPA ID number to legally ship that waste irrespective of what state your business is based in.


What is a Waste Analysis Plan?

A business requires an RCRA permit if it generates, treats, or stores hazardous materials or is involved with hazardous waste removal. Applying for this permit requires you to create a Waste Analysis Plan (WAP). A Waste Analysis Plan is essentially a step-by-step guide for treating, storing, and disposing hazardous wastes including corrosives, flammables, explosives, gasses, poisons, etc. In developing the guide, you need to outline by what methods you determined the materials to be hazardous, how you defined its specific nature and how you determined that the hazardous material must be handled.

Whoever designs your Waste Analysis Plan must be trained in RCRA regulatory requirements and highly knowledgeable about waste characterization and hazardous waste disposal.


What is an EPA Hazardous Waste Profile?

A Hazardous Waste Profile, formerly known as a “waste characterization profile,” requires you to list all chemical properties of the particular type of waste you intend to dispose of or transport. The hazardous waste profile must be presented to the treatment & disposal facility prior to its arrival, otherwise it’s illegal for the disposal facility to accept receipt of your hazardous waste.


Storage and Accumulation

How do I designate a hazardous waste storage area?

    • Select an area that is:
    • Close to where the waste is generated and easily accessible
    • Under the control of lab personnel
    • Removed from normal laboratory activities
    • Labeled with a “Danger – Haz Waste” sign. 

How much Hazardous Waste can I store at my facility?

Both conditionally-exempt small quantity generators (CE-SQG) and small quantity generators (SQG) have limits on how much hazardous waste they can store at their facility at the one time. If you go above these prescribed limits, you will need to comply with the requirements of the next higher generator category.

For non-acute hazardous waste, this limit is 1000 kg or 2,200 lbs for a CE-SQG and 6000 kg or 13,200 lbs for a SQG.

For acute hazardous waste, the limit is the same for both: 1 kg for an acute hazardous waste or 100 kg for spill residue from an acute hazardous waste. Thus, if your hospital accumulates just 1 kg of a p-listed waste on site, you will need to comply with all the RCRA Subtitle C requirements since you will be treated as a large quantity generator (LQG).

An LQG can store as much hazardous waste as it wants on site. There is no quantity limitation.


How long can hazardous waste be stored at my facility?

The duration of time that hazardous waste can be stored on-site at a facility varies depending on the facility's generator status:

    • There are no time limits placed on a CE-SQG for the storage of hazardous waste.
    • [Although there is a limit on how much hazardous waste a conditionally-exempt small quantity generator (CE-SQG) can accumulate on site.
    • Small quantity generators (SQG) can only keep their waste on–site for 180 days or 270 days if their treatment, storage, and disposal facility is more than 270 miles away.
    • Large quantity generators (LQG) can only store their waste for 90 days without obtaining a permit as a storage facility.

What is a Satellite Accumulation Area?

A satellite accumulation area is an area at or near the point of hazardous waste generation that is under the control of the operator of the process generating the waste. In this area, wastes are permitted to be temporarily stored for 3 days before being moved to the main hazardous waste storage area.


How much Hazardous Waste can be stored in Satellite Accumulation Areas?

Up to 55 gallons of non-acute hazardous waste or one quart of acute hazardous waste can be collected in a Satellite Accumulation area at any one time. When these quantity limits are reached, the containers must be dated so that the generator can move the hazardous waste to the main hazardous waste storage area, or ship the waste off-site within 3 days of the limit being reached.


What Hazardous Waste Inspections are required for my facility?

RCRA requires that SQGs and LQG generators of hazardous waste inspect containers in storage (not in satellite accumulation areas) at least weekly for signs of corrosion, leaks, or other deterioration; such inspections are required to be recorded in a log and must include the date and time of inspection, the name of the inspector, documented observations made, and the date and nature of any repairs or other remedial actions.


How should a facility determine the total weight of hazardous wastes it generates per month?

A facility must determine the amount of hazardous waste it generates within a calendar month by adding together the volumes of hazardous wastes and the volumes of acutely hazardous wastes generated by each department
located on-site. Off-site facilities must separately determine the amount of hazardous waste they generate. The hazardous waste rules are site-specific therefore each hazardous waste generator, by site, must account for the hazardous wastes generated at their facility.


How often do I need to ship my hazardous waste?

Legal requirements for shipping frequency depends on your generator status:

    • Conditionally exempt: no limits or restrictions
    • Small quantity: 180 days or less; 270 days or less when transporting more than two hundred miles
    • Large quantity: 90 days or less

Failure to comply with these shipping times could result in an EPA fine being handed down to your place of business.


Transport and Disposal

How should Hazardous Glass be Disposed of?

Before you can properly dispose of your hazardous glass waste, you must first ensure all your disposal items have been adequately identified. The most common types of laboratory glass waste include pipettes, slides, plastic ware, syringe bodies, and any broken containers. Hazardous glass and plastic waste should never be placed directly into the trashcan or other garbage receptacles. Because of the high risk of contamination, specially designed containers should be used. Plastic-lined cardboard boxes that are sturdy and leak proof are the best options.


What penalties should you be aware of when handling or disposing of hazardous waste?

Administered by the EPA, the Resource Conservation and Recovery Act (RCRA), generators of hazardous waste must ensure complete compliance in the handling and disposal of RCRA hazardous waste. A partial list of potential infraction includes:

    • Dumping a hazardous waste down the drain.
    • Missing or incomplete hazardous waste manifests
    • Failing to train employees in hazmat generation, handling, transport, and emergency preparedness.
    • Missing or non-compliant labels
    • Uncovered hazmat containers
    • Improper waste consolidation

What waste container should I use for my hazardous waste?

Waste containers come in a variety of materials, and some are simply incompatible with certain waste types. For example, corrosive waste can’t go into a metal drum or container. It can eat through that metal and cause minor or severe leaking. Plastic containers are the safer, more suitable option for anything corrosive. Similarly, flammable waste is best contained to steel drums or pails. Whether you’re dealing with hazardous materials or non-hazardous waste, you must use a UN-rated container. You’ll know it’s UN rated because it will have the specific UN number on the bottom. If you choose the incorrect container, and it leaks or has a massive structural collapse, you are absolutely liable to pay for any damages or cleanup associated with that spill. It doesn’t matter if it wasn’t leaking when it went on the truck; it doesn’t matter if you didn’t realize you couldn’t use that type of container; the liability rests with you.



How is Hazardous Waste Treated?

Hazardous waste can be treated by chemical, thermal, biological, and physical methods. Chemical methods include ion exchange, oxidation and reduction, precipitation and neutralization. Among thermal methods is high-temperature incineration, which not only can detoxify certain organic wastes but also can destroy them. Specific types of thermal equipment are used for burning waste in either solid, liquid, or sludge form, including the rotary kiln, liquid-injection incinerator and fluidized-bed incinerator.


Can Hazardous Waste be Landfilled?

Hazardous wastes may only be deposited in "secure landfills", which provide at least 3 meters (10 feet) of separation between the bottom of the landfill and the underlying bedrock or groundwater table. A secure hazardous-waste landfill must have two impermeable liners and leachate collection systems that prevents the accumulation of leachate trapped in the fill and prevents environmental damage. To further reinforce against environmental contamination, an impermeable cap or cover is placed over a finished landfill.


Waste Categorization

Can I dispose of nicotine as non-hazardous waste?

You can only if your state has adopted the SubPart P amendment and the nicotine is in the form of patches, gums or lozenges.


What pharmaceuticals are classified as Hazardous Waste?

"Between 5% to 10% of pharmaceutical products are correctly classified as hazardous waste. There are four questions that must be answered to determine if a pharmaceutical product is regulated by the EPA as a hazardous waste:
1) Is it a solid waste?
2) Does it qualify for an exemption?
3) Is it a characteristic waste?
4) Is it a listed waste?"




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