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Do your staff and employees know how to identify hazardous solid waste? Do they know the difference between hazardous waste characteristics? Are they aware that hazardous solid waste that is corrosive, flammable, or potentially toxic poses a serious threat to the health and safety of humans, animals, and the environment?
Not all waste is created equal, so how can you tell when your waste falls under regulations of federal and state laws for handling, shipping, and disposal processes?
01 / Who Defines Hazardous and Non-hazardous Waste?
Under the Resource and Conservation and Recovery Act (RCRA) the EPA regulates not only hazardous wastes but manufacturing solid wastes, industrial wastes, and ordinary household wastes.
The RCRA regulates and controls any hazardous waste, from its point of origin or generation to its final disposal. This is called the ‘Cradle-to-Grave’ approach to safe and compliant hazardous waste management and disposal processes.
Per the EPA, hazardous waste is defined – in a nutshell - as anything that contains properties that can make that waste dangerous or harmful to human health or to the environment. The agency has broken down primary characteristics of hazardous waste for easier identification.
Under the RCRA, solid waste materials that qualify as hazardous must be regulated. Subtitle C of the RCRA focuses on hazardous solid waste, while Subtitle D focuses on non-hazardous solid waste rules.
Solid waste is a broad category that includes everything from discarded used tires and military munitions to sewage and antifreeze. Basically, any refuse resulting from industrial, commercial, mining, or agriculture activities meets the criteria, along with any materials generated from community activities that have been abandoned or are unable to be recycled.
02 / What makes a Waste Hazardous?
Per the classifications of the EPA, hazardous solid waste is clearly defined. Waste is considered hazardous if it is identified to contain one or more of the following characteristics:
Ignitable – it can burn or is potentially flammable
Corrosive – it can rust or eat through metal, such as an acid
Reactive – it can be an unstable substance, it might cause a reaction when it comes into contact with water, or might emit toxic gases, or explode when heated
Toxic – it can be harmful if absorbed on the skin, inhaled, or ingested
Each of the categories includes additional refinements intended to more accurately classify the type of hazardous materials being disposed of and the possible risk associated with those materials. You can find additional details here.
Liquids with a low flash point temperature, like alcohol, gasoline, acetone, and solids that spontaneously combust. Oxidizers and compressed gases are also considered ignitable and are considered a hazardous waste.
Acids, rust removers, and liquids capable of corroding steel are some examples of corrosive materials that must be regulated as hazardous waste.
Unstable, toxic materials that might - when mixed with water or other chemicals - are considered reactive and are therefore dangerous.
Finally, any poisonous material that could adversely affect humans or the environment are considered toxic, and include contaminants included in the EPA’s toxicity characteristics list.
03 / What Wastes are excluded from Solid Waste Regulations?
Any waste that does not meet the definition of solid waste is not subject to regulation under the RCRA. There are many reasons why these waste materials are excluded, such as public policy, management by other laws, or the impracticability of regulatory oversight. Both the EPA and Congress are empowered to eliminate specific materials from the solid waste definition.
Familiarity with the RCRA is highly recommended for any generator producing or generating even small amounts of hazardous waste.
For example, according to the EPA, criteria for defining solid wastes and solid and hazardous waste are specific. If the waste is solid and is excluded from the definition of solid or hazardous waste, it is not subject to RCRA regulations under Subtitle C.
However, if the waste is listed as a hazardous waste based on its characteristics (review the characteristics of hazardous waste), or if the waste has been delisted (turn to CFR Title 40 260.22), it is subject to RCRA Subtitle C regulations.
Some materials which are not considered solid wastes for the purposes of RCRA enforcement include sewage, radioactive waste, scrap metal, and certain condensates and point source discharges associated with certain industrial, agricultural, and mining activities.
The EPA also exempts certain solid wastes from the definition of hazardous waste even when the materials they contain meet the listed characteristics used to define hazardous waste. For example, some household wastes and automotive byproducts are omitted from RCRA regulation, as are CFC refrigerants, landfill leachate, and agricultural waste. You can find out more about these exclusions in 40 CFR section 261.4(b).
04 / A Word about Regulating Non-hazardous Waste
Many by-products of industrial, commercial, or agricultural activities may not meet the hazardous waste criteria but are nevertheless be regulated. Some examples of non-hazardous waste subject to additional regulation include sugars, lactic acid, bromides, and carbonates. While these types of materials do not pose the same risks to the environment or human health and safety, they must still be collected and disposed of in compliance with RCRA regulations.
The EPA provides guidelines for the storage, handling, shipment, and destruction/disposal of non-hazardous solid waste. Review the guidelines found in the Code of Federal Regulations (CFR Title 40 Parts 239-259) for details.
05 / Properly Handle and Dispose of Hazardous Waste
To ensure proper handling, identification, and disposal processes when it comes to hazardous solid waste, turn to the expertise of an experienced and reliable hazardous waste management company like MCF Environmental Services.
When you partner with us, you can rely on the skills and knowledge built over three decades in the industry. We understand the paperwork, keep track of current rules and regulations, and employ a team of expert problem solvers able to identify problems before they start.
We offer customized, comprehensive hazardous waste management disposal at affordable costs. Because we don’t rely on middlemen or subcontractors, we manage and monitor the entire waste disposal stream from cradle-to-grave. Contact one of our knowledgeable representatives today to learn more about how our organization can help streamline your waste management processes and enhance your business operations.
Robert Losurdo
President, COO
