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FAQ’s

Our Comprehensive FAQ library is designed to help you navigate waste disposal, treatment and handling
requirements in line with regulations. If you don’t see what you’re looking for, please reach out and one of our
experienced waste experts will be able to assist you.

Hazardous Waste

Storage and Accumulation
Manifests and Documentation
Transport and Disposal
Treatment
Labelling
Waste Categorization

Storage and Accumulation

How do I desiginate 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 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.

 

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.

 

Chemical Waste

Lab Packing
Definitions
Treatment

 

Lab Packing

What is a Lab Pack?

Lab packing is a chemical collection and transport method that utilizes smaller inner containers inside a larger outer container for packing and shipping. This process enables cost and space efficiency in transport when shipping “like” materials while ensuring that no incompatible chemicals are mixed together. If you have small containers intact and contained within their own primary container, then these items could be placed into a drum that is equal or lesser than 55 gallons and “lab packed” together with inert packing material (typically packed in vermiculite or another compatible absorbent). It should be noted however that there are specific requirements for the amount of packing material required in each specific size drum per D.O.T regulations, and combining bottles of chemicals in the same outer container can be dangerous if not done correctly.

What are the regulations around transporting Lab Packs?

Universal wastes are hazardous wastes that are generated across multiple sectors of society, these materials contain harmful chemicals which, if put in the trash may harm people or the environment. Universal wastes include:

Common Batteries
Fluorescent Tubes and Bulbs and Other Mercury-Containing Lamps
Thermostats
Electronic Devices. These devices often contain heavy metals like lead, cadmium, copper, and chromium.
Electrical Switches and Relays
Pilot Light Sensors. Mercury-containing switches are found in some gas appliances
Mercury Gauges – Some gauges, such as barometers, manometers, blood pressure, and vacuum gauges
Mercury Thermometers
Non-Empty Aerosol Cans that Contain Hazardous Materials

Can all Lab Packs be treated in the same way?

Lab packs that contain highly dangerous chemicals such as cyanide or arsenic and/or container toxic heavy metals are subject to special treatment requirements. Generators are not required to determine underlying hazardous constituents (UHCs) when using the alternative treatment standard for lab packs.

Does my school need a Lab Pack service?

Chemistry laboratories in educational institutions (including but not limited to community colleges, high schools and universities) store many toxic, corrosive, flammable, reactive, and poisonous chemicals that are used in class demonstrations and training. With a clear shelf life, these chemicals must be disposed of at the end of each semester or school year. Lab packing is both the safest and most compliant means of packaging and transporting hundreds of different lab chemicals at once.

When should I Lab Pack chemicals?

Chemicals should be designated for Lab Pack disposal if they meet the following criteria:

Within six months of expiration (this should be captured on the label of the chemical container). Best practice irrespective of expiration date is to not keep hazardous chemicals for longer than five years.
When the condition of the chemical’s storage has been compromised, for example if the chemical was stored in an unsuitable temperature or without being properly sealed.
If you do not need or use the chemical regularly or it poses an unsuitable hazard risk.

Can all Chemicals be Lab Packed together?

It is the responsibility of the “Lab Packer” to identify and properly segregate each substance based on the US Department of Transportation’s regulations. Many flammable substances cannot be packaged with other chemicals because they are in different hazard classes, for example, picric acid is one chemical that becomes explosive with age and must be handled with extreme caution and expertise. It is therefore imperative, whether for a Chemist or a Hazardous Waste partner, that the person responsible for lab packing has knowledge of the substances they are working with.

Can any Waste Company provide Lab Pack Disposal?

Only transportation companies permitted under the U.S. DOT hazardous materials regulations and the U.S. EPA’s hazardous waste regulations can transport hazardous waste. It is the responsibility of the waste generator to confirm that their nominated transporter is fully permitted, being aware that some service providers outsource transportation to a third party. Using a third party can add an additional layer of risk when considering lab pack disposal.

What is Lab Packing?

Lab packing is the process in which chemicals are placed into a DOT approved container and transported to a permitted waste disposal facility. Because many of these substances are hazardous and even more dangerous when accumulated with other chemicals, it is important that only an individual who has expertise in lab packing operations performs them. A trained lab packing technician will have knowledge of how to handle and segregate chemical substances in a way that is safe and regulation compliant.

Who utilizes Lab Packs?

Lab packs are typically used by universities, laboratories , dry cleaners or other industries that produce chemical waste. When disposing of multiple chemicals with different hazardous properties, lab packs are a convenient and cost-effective option for shipping hazardous chemicals off-site. The large lab pack container gets filled with various smaller-quantity containers of materials or chemicals that are similar to each other, such as acids, flammables and oxidizers. The container is then marked with its assigned shipping name for easy sorting.

What materials can be transported in a lab pack?

Common materials that would be transported in a lab pack include toxic, flammable, corrosive, pyrophoric or explosive materials, acids, aerosols and compressed gas, solvents, oxidizers, chemical reagents, cleaning and disinfecting agents, radioactive materials, organic peroxides, paints, paint thinners, varnish strippers and reactive materials from metals.

How is a Lab Pack Loaded?

To load the lab pack (drum), small vials and containers (anywhere from one-quarter ounce to gallon jugs) are packed together into the larger container which must be packed according to waste type, so the waste segregation process is vital. For example, flammable items should be packed with other flammable items. Corrosive waste should be packed with similar corrosive waste. You should never mix flammable, corrosive, or reactive materials within one large container.

What is a Lab Pack Inventory?

Before packing any chemical containers into the lab pack, a qualified individual must create an inventory of every expired, damaged, or out-of-date chemical to be disposed of. This inventory should accurately detail everything that’s going into the pack in order to properly – and safely – dispose of chemicals that are no longer needed.

What does a turnkey Lab Pack Service include?

A turnkey lab pack service (which is what MCF offers) typically involves the following:

Identification of all materials within the lab.
Inventory creation of those materials.
All DOT-certified containers.
Necessary paperwork (profiles, shipping manifest, labels, placards, and so on).
All labor associated with the pack.
All travel expenses associated with transport.

Definition

How do I determine whether a chemical waste is “hazardous” or “extremely hazardous”?

“Handling and Disposal requirements are different for hazardous and extremely hazardous chemical waste.
Check the list of Known Hazardous and Extremely Hazardous Wastes for your material here: http://www-ehs.ucsd.edu/hazwaste/Blink_Haz_Waste_list.htm

Is Chemical waste always considered hazardous?
Chemical waste is largely composed of harmful chemicals. This does not mean, however, that it is classified as hazardous.

For it to be considered hazardous, it must have an ignitability, corrosivity, reactivity or toxicity characteristic, according to the U.S. Environmental Protection Agency.

 

Treatment

How is Chemical Waste Treated?

Treatment for chemical waste disposal is accomplished by one of four processes: Biological, Chemical, Physical or Thermal. Chemical treatment methods include ion exchange, precipitation, oxidation and reduction, and neutralization, however the most common type of thermal treatment method is incineration.

Universal Waste

Storage and Accumulation
Definitions
Waste Categorization

 

Storage and Accumulation

How long can I accumulate Universal Waste at my facility?

A waste handler may accumulate universal waste for no longer than one year from the date the waste was generated or received from another handler. If for the purpose of accumulating quantities to facilitate proper recovery, treatment, or disposal (40 CFR 273.15 and 273.35), handlers may accumulate universal waste for longer than one year.

 

Definitions

What is Universal Waste?

Universal wastes are hazardous wastes that are generated across multiple sectors of society, these materials contain harmful chemicals which, if put in the trash may harm people or the environment. Universal wastes include:

Common Batteries
Fluorescent Tubes and Bulbs and Other Mercury-Containing Lamps
Thermostats
Electronic Devices. These devices often contain heavy metals like lead, cadmium, copper, and chromium.
Electrical Switches and Relays
Pilot Light Sensors. Mercury-containing switches are found in some gas appliances
Mercury Gauges – Some gauges, such as barometers, manometers, blood pressure, and vacuum gauges
Mercury Thermometers
Non-Empty Aerosol Cans that Contain Hazardous Materials

 

Waste Categorization

How Do I know if an electronic device can’t be disposed in the trash?

A complete list of universal waste products, and information about disposal and recycling options, is available on the DTSC Web site at http://www.dtsc.ca.gov/HazardousWaste/UniversalWaste/Index.cfm

What materials are considered Universal Waste?

The universal waste regulations can vary between states and states can add different types of wastes. EPA compiled a list of which universal wastes which universal wastes states have adopted and which materials some states have added to their universal waste program. Link here https://www.epa.gov/hw/state-universal-waste-programs-united-states#additions. You should check with your state to be sure which materials are currently universal wastes in your state.