For many businesses, especially those without access to a dedicated environmental, health, and safety (EHS) professional, hazardous waste management can seem like a complex and daunting task. Here's a breakdown of the essentials to ensure your company handles hazardous waste safely and compliantly.
What is RCRA and Why Does It Matter?
The Resource Conservation and Recovery Act (RCRA) is the main federal law governing hazardous waste in the United States. It sets guidelines for identifying, storing, transporting, treating, and disposing of hazardous materials. Understanding RCRA is crucial to avoid hefty fines and potential environmental damage.
What is Considered Hazardous Waste?
Simply put, hazardous waste is any waste that poses a threat to human health or the environment. This can include:
- Ignitable: Liquids that can easily catch fire (flammable liquids, paint thinners)
- Corrosive: Substances that can eat away at or damage containers and surfaces (acids, bases)
- Reactive: Materials that can readily undergo violent reactions or explode under certain conditions (peroxides, unstable chemicals)
- Toxic: Wastes that can cause or contribute to serious health problems, even in small amounts (heavy metals, certain pesticides, etc.)
Examples of Common Hazardous Wastes
Many everyday products used in businesses can be hazardous waste if not disposed of properly. Here are some common examples:
- Aerosol cans: These contain pressurized propellants that can be flammable or explosive.
- Solvents: Used for cleaning, degreasing, and thinning paints, many solvents are ignitable and toxic.
- Paints and Varnishes: Leftover paints, varnishes, and stains, especially those containing volatile organic compounds (VOCs), can be flammable and toxic.
- Mercury-containing devices: Thermostats, switches, and some fluorescent bulbs contain mercury, a highly toxic metal.
- Pesticides and Herbicides: Improperly stored or discarded pesticides can contaminate soil and water sources.
- Cleaning Products: Drain cleaners, oven cleaners, and other harsh chemicals can be corrosive or toxic.
- Batteries: Lead-acid batteries, common in cars and forklifts, contain hazardous materials.
Listed vs. Characteristic Wastes
The EPA uses two main methods to identify hazardous waste:
- Listed Wastes: The EPA has identified specific hazardous wastes by name (spent solvents, certain discarded commercial products). If your waste matches a listed waste on the EPA list, it's automatically considered hazardous.
- Characteristic Wastes: Wastes are assessed based on their properties (ignitability, corrosivity, reactivity, toxicity). If a waste exhibits one or more of these characteristics, it's considered hazardous.
The Dangers of Improper Handling
Improper disposal of hazardous waste can have severe consequences. Here are some of the risks:
- Environmental Contamination: Leaking or improperly disposed waste can pollute soil, water sources, and air, harming ecosystems and human health.
- Worker Safety Hazards: Mishandling hazardous materials can expose workers to dangerous chemicals, leading to injuries or illnesses.
- Fines and Legal Issues: Violations of RCRA regulations can result in significant fines and even criminal charges.
Taking Control and What You Can Do
Even without a dedicated EHS professional, your company can manage hazardous waste responsibly:
- Employee Training: Educate employees on identifying hazardous waste, proper handling procedures, and emergency response protocols.
- Labeling and Storage: Clearly label all hazardous waste containers and store them in designated, secure areas with proper secondary containment.
- Documentation: Maintain accurate records of your hazardous waste generation, storage, and disposal activities.
- Partner with a Consulting Environmental Professional: Work with reputable companies with experienced professionals who are familiar with RCRA federal law, and have working relationships with companies certified to transport and dispose of hazardous waste according to RCRA regulations. This is a crucial step as where you send your hazardous waste is just as important, if not more so, than onsite waste management activities!
Following these basic steps can help you ensure your company manages hazardous waste safely and compliantly. Remember, responsible waste management protects your employees, the environment, and your business from unnecessary risks and ridiculously expensive fines.
Additional Resources:
For further information on RCRA and hazardous waste management, you can visit the US Environmental Protection Agency's website
Want a fresh look at your industrial wastes? Contact Premier Safety Resources to discuss potential next steps with a waste stream audit!