With over one billion tons of municipal solid waste generated worldwide every year, industrial waste management is serious business. Because improper waste treatment and disposal can lead to environmental pollution, and create serious ramifications for human health and safety, all generators of industrial waste need to implement strategic, professional industrial waste management. While dealing with industrial waste streams can be complicated and overwhelming, understanding the right methodologies and procedures can go a long way towards easing anxiety and providing a framework for action.
Identifying Your Waste
When creating an industrial waste management plan, the first step involves defining your waste stream. According to the EPA, hazardous waste includes any waste with the potential to cause harm to human health or the environment. Hazardous waste can be solid, liquid, or gas, or can be the by-product of a manufacturing process, discarded, or unused commercial products including solvents and pesticides.
The typical types of hazardous waste generated by small businesses range from dry cleaning chemicals, construction materials, pesticides and other industrial solvents and chemicals. Equipment repair and auto shops must often work to prevent spills and ignitable wastes, while photo processors and laboratories deal with acid regenerators, heavy metals, and contaminated materials. The Universal Waste Rule also considers wastes commonly disposed of in households or small businesses, such as batteries, thermostats, lamps, and pesticides as hazardous waste.
For regulatory purposes, hazardous waste includes any waste appearing on one of four RCRA hazardous waste lists. Materials not on the RCRA lists can still be considered hazardous waste if they have one of four characteristics: ignitability, corrosiveness, reactivity, or toxicity. Part 261 of the Code of Federal Regulations (CFR) includes a detailed list of all materials considered hazardous waste.
Determining Your Generator Category
The amount of waste you produce each month determines your waste generator category. The three main generator categories established by the EPA include Conditionally Exempt Small Quantity Generators (less than 220 lbs. per month), Small Quantity Generators (between 220 and 2200 lbs per month), and Large Quantity Generators (anything over 2200 lbs. per month).
To measure the amount of waste you generate, you need to take into account all waste accumulated on your property before disposal, as well as any materials packaged and transported away from your businesses. Sludges and still bottom residue occurring in storage tanks must also be measured, as well as all materials placed in designated disposal units. Items you do not need to include in your measurements include exempted items like reclaimed lead-acid batteries, bulbs, universal waste, and used oil.
Managing Waste Onsite
Special containers, properly labeled, sealed and maintained, must be used to store all waste on site. Unless the hazardous waste meets the EPA’s Land Disposal Restrictions (LDR) standards, it cannot be “land disposed” and must instead be treated to reduce any hazardous constituents to a level approved by the EPA. Under the Domestic Sewerage Exclusion (DSE), hazardous waste can be recycled or disposed of on-site as long as the waste generator can “flush” the wastes by mixing it with domestic sewage and discharging the mix into publicly owned treatment works.
In some cases, on-site recycling or treatment of hazardous materials is allowed without a permit as long as the organization complies with the accumulation time limits and waste collection regulations outlined in 40 CFR §§. All other waste must be transported and treated off-site.
Off-site Waste Management
When hazardous waste must be treated off-site at an approved treatment, storage, or disposal facility, special attention is given to the mode of transportation. Because of the danger of spills or “midnight dumping” (abandoning waste at random locations), the law now requires proper labeling and tracking of all hazardous materials.
While trains are still sometimes used to transport hazardous waste, the most common method involves moving containers in trucks over public highways. Trucks made of steel or aluminum alloy are authorized to carry hazardous waste container with average capacities of up 92, 55-gallon drums.
Hazardous waste transportation also requires manifest documentation. The manifest records all the details of the waste pickup and delivery, volumes, quantities and waste descriptions.
Summary of Requirements
In order to ensure your industrial waste is properly managed, the EPA suggests the following these steps:
- Identify all hazardous waste you generate
- Measure the amount of hazardous waste you produce
- Obtain your EPA Identification Number
- Prepare your waste for shipment by properly packaging and label your waste containers
- Follow the required timeline for waste storage on-site
- Engage a qualified waste transport provider to handle any waste treated offsite
- Maintain accurate, detailed records and provide regular biennial reports of your waste management activities
Because of the complexity involved in the collection, transportation, and processing of industrial waste, partnering with an experienced, professional waste management service makes sense. Qualified waste management providers can handle all of the intricacies involved in the proper collection, treatment, transportation, and disposal of industrial waste, including regulatory compliance. By outsourcing waste collection, transportation and disposal to qualified experts, companies can mitigate risk and maintain focus attention on core business operations.
With regulations constantly changing, it is hard to stay on top of all the requirements and protocols. Responsible waste management helps organizations maintain safety in the workplace while also protecting the environment and limiting liability.
With almost three decades of experience in waste management and disposal, MCF Environmental provides the expertise and capabilities you need to properly handle your industrial waste.