01   /   Can a retail store be a RCRA hazardous waste generator?

If you own or operate a moderately-sized supermarket, hardware store, convenience shop, pharmacy, or any other any kind of retail establishment, you probably don’t think of your business as a RCRA hazardous waste generator—and that’s a hazardous assumption.

Retail establishments characteristically have three sources of hazardous waste that require a protocol for hazardous waste disposal:

    1. Residual and leftover maintenance products
    2. Customer returns that cannot be resold
    3. Products that are past their expiration dates

02   /   What kinds of waste require retail waste management?

While things like pesticides and out-of-date pharmaceuticals are intuitively hazardous, a good deal of retail trash that requires retail waste management wouldn’t necessarily set off anyone’s “hazmat” alarm.

Among these seemingly benign wastes are aerosol cans, cosmetics, hand sanitizers, household cleaners, nail polish, pool chemicals, and more. But consider:


Aerosol cans commonly contain P- or U-listed chemicals, and their propellent is flammable, making them a characteristic


Cosmetics can contain BHA, BHT, or parabens (as preservatives); coal tar dyes (as hair colorants); DEA (as a foaming agent), formaldehyde (as a smoothing agent)


Hand sanitizers are mostly alcohol and therefore flammable


Many household cleaners are corrosive, and poisonous if ingested (e.g. bleach and ammonia)


Nail polish contains DBP, toluene, and formaldehyde


Pool chemicals are corrosive and reactive

03   /   Are retail stores subject to RCRA hazardous waste disposal rules?

Over the last decade, along with state and local governments, the EPA has been aggressively pursuing cases of substandard retail waste management against America’s largest retailers, consequently raising corporate awareness and compliance.

With that achieved, it follows logically that the EPA (along with state and county governments) will increase scrutiny of local and regional retailers in matters of hazardous waste disposal.

Thus, if you operate such a retail enterprise, it’s crucial that you develop a company-wide protocol for hazardous waste management—and a training program to ensure its implementation.

04   /   How do you evaluate waste streams in retail settings?

Retail operators must be able to account for all regulated wastes generated in their stores, as well as how, and from what parts of their operations, such waste originates.

This is because different categories of regulated waste are encumbered by different rules for their legal disposal. Herein we discuss the two most prominent categories: retail hazardous waste and retail universal waste.

05   /   What is retail hazardous waste?

The EPA categorizes some retail wastes as RCRA hazardous, meaning they must be treated, recycled, and/or disposed of according to a large body of rules that differ according to how large a “generator” the EPA considers you to be.

The EPA categorizes hazardous waste generators into one of three categories, the biggest difference among them having to do with the amount of hazmat you can keep onsite for a month before it must be moved to a licensed storage or treatment facility. These categories are:


Very Small Quantity Generator (VSQG)


Small Quantity Generator (SQG)


Large Quantity Generator (LQG)

Typically, transporting hazardous waste offsite to a licensed storage or treatment facility requires strict documentation as proof of secure handling. The Uniform Hazardous Waste Manifest documents the type of waste being transported, instructions for handling it, and the signatures of responsible parties.

06   /   What is retail universal waste?

The EPA created the Universal Waste subcategory to ease the regulatory load on smaller retail stores and other generators needing to collect and transport problematic wastes to a storage or treatment facility. With this category of waste, there’s no requirement for a Uniform Hazardous Waste Manifest.

The agency says it did so to promote the collection and recycling of batteries, pesticides, fluorescent tubes, aerosol cans, televisions, computers, old thermostats, and other things that might otherwise find their ways into municipal trash streams.

But note: “universal” waste differs from “hazardous” waste only in that the rules for transporting the former to a licensed storage or treatment facility are more relaxed. Otherwise, universal waste is nonetheless a category of hazardous waste, and disposing of it improperly will expose you to RCRA fines and sanctions for illegal hazardous waste disposal.

07   /   Get expert help

MCF Environmental Services is dedicated to providing simple, affordable, sustainable solutions for retailers so that you can focus on running your business without the worry of inadvertent RCRA violations.

In sum, we can reduce your operational and compliance risks by managing every aspect of your waste management—be it municipal, universal, or hazardous.

Don’t know where to start? Contact one of our experts today. Or call 866.315.8116.

Robert Losurdo

President, COO