Hazardous Waste — Definitions

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

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.

• 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.

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.

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.

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.

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.

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.