If you produce any kind of hazardous waste stream, you need to be aware of your EPA generator status and how to legally avoid registering as a large quantity generator. Because this large quantity status comes with a lot of extra fees, paperwork, and hassle, it’s pivotal to avoid—if at all possible.
Large Quantity Generator: What It Is, and Why You Might Not Have to Be One
What Is a Large Quantity Generator?
This is any business that produces hazardous materials over 2,200 pounds per month. If this level is reached or exceeded, that business is liable to pay more fees and file more paperwork. This is why people are so anxious to avoid having to file as such—unless absolutely necessary.
When filing as a generator, the type and amount of waste you’re generating and your physical location determine your EPA generator status, and once that has been established, you’re then assigned your EPA identification number. This EPA ID number must be present on all relevant paperwork.
Can Everyone Avoid Becoming a Large Quantity Generator?
Unfortunately, no. Some businesses produce so much hazardous material that they must legally register with that large quantity status. For these businesses, it is not a matter of improper waste segregation or implementing other waste practices that needlessly bump them into that large status. Due to the volume of hazardous waste they manufacture or produce in their operations, they have no choice but to properly register as the correct generator status.
For these generators, failing to register would be a legal violation, and it could result in serious fines.
How to Avoid Accidentally Becoming a Large Quantity Generator
The following are some waste management tips and best practices that can keep you from needlessly having to reach that large quantity status.
One of the most straightforward ways to avoid that 2,200-pounds-per-month limit is by trying to minimize waste you generate. This often involves using nonhazardous alternatives to potentially hazardous materials.
For example, if you’re dealing with paint or ink, go with the nonhazardous (or, at least, less hazardous) variety. Using latex paint or water-based paint over oil-based paint or solvent-based paint can greatly reduce your hazardous output.
An experienced, reputable hazardous waste disposal company will be able to walk you through this process and create a custom plan for you and your business.
Waste minimization has also happened through improved processes over time. An auto body shop that produced twenty to thirty drums of waste in the early nineties might only produce one or two drums now due to improved machines, improved equipment, nonhazardous chemicals, biodegradable chemicals, and so on.
Proper Waste Segregation
The segregation of waste is one area many people fall down. If you put one ounce of hazardous waste into a drum of nonhazardous waste, that entire drum is now hazardous.
Therefore, always keep your hazardous and nonhazardous waste in separate containers. Some people will put their hazardous material into a nonhazardous bin just to fill it to the top for shipment, but again, that means that entire bin is now hazardous.
To ensure your waste processes go according to plan, every employee must be educated about the laws, best practices, and company policies regarding this storage and disposal. If one employee doesn’t know and improperly segregates your waste, it can push your company over the limit, and you’ll be required to register at that higher generator status.
Improved education across the company will also help ensure best practices, such as using every bit of a chemical or product rather than simply throwing the excess into your accumulated waste.
The global trend is toward waste minimization because it’s better for the environment, people, and a sustainable future. Make sure your employee understand this and can contribute in all ways possible.
Why Work with Hazardous Waste Removal Companies at All?
If you’re on the edge of having to register in the large quantity bracket, working with these hazardous waste management companies can point out the one or two practices that could keep you below the 2,200-pound mark. If the company can successfully help you avoid this, they’ve already made themselves financially worth it.
You also get peace of mind knowing you have the help of professionals to deal with these dangerous materials. As the generator, you assume cradle to grave liability, so you better be sure you’re handling this type of waste safely and legally all the way through to disposal.
For more information about your generator status and how hazardous waste disposal companies can possibly save you money in this regard, please feel free to contact a representative of MCF Environmental Services, a full-service hazardous waste management company.