UPDATED MARCH 2017
Hazardous Waste Management shouldn’t be taken lightly, and it is important to address each disposal, recycling, handling, and transportation interaction with care and concern. Waste can become more reactive and dangerous overtime, and not every business has Environmental Health and Safety personnel on their staff, so it is important to find a qualified vendor to answer your specific questions about the wastes you come across in your facility and the waste you generate in your business processes.
Today, we are sharing a handful of commonly misunderstood aspects of properly disposing of haz waste. “My product is labeled non-hazardous, that means I can throw it in the trash, right?” There is a very good chance you cannot, but why? First, it is important to know what hazardous waste is. Wikipedia defines it as a “waste that poses substantial or potential threats to public health or the environment. In the United States, the treatment, storage and disposal of hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA).” These wastes could include items such as those listed below and more:
- Expired Products
- Maintenance Chemicals
- Vendor Samples
- Process Waste
- Spill-response Waste
- Research Waste
- Lab Waste
- Paints & Cleaners
- Abandoned Mfg Supplies
- Solvents and Thinners
- Cleaners and Washer Chemicals
- Oils and Absorbents
"My product is labeled as non-hazardous; I should be able to just throw it in the trash, right?"
A: While many manufacturers are using non-hazardous ingredients in the formulations of their products, ALL wastes must be evaluated prior to disposal. Some municipalities regulate business wastes as an industrial waste; rules which could be more stringent than state or federal rules. Check with your local environmental regulators before choosing a disposal method. Form an internal process for inventorying, evaluating, storing and managing each waste type to avoid confusion. TRC can help you build a program for managing wastes, if one does not currently exist for your business.
"If I choose to send my waste as a Non-Hazardous Industrial waste, I will not have a paperwork trail to show proper disposal."
A: If your requirement is to have a cradle-to-grave tracking method for all waste sent out from your facility, be sure to specify this with your disposal or recycling vendor up front. Sometimes there is an additional fee for this type of paperwork, but a reputable vendor will be able to provide this service. For example, TRC can ship non-hazardous waste on several types of paperwork which will afford you a direct link to the disposal facility.
"I am just signing a Hazardous Waste Manifest for my employer, I don’t need DOT training."
A: Every person involved in the shipping of hazardous waste is required to have DOT training once every 2 years. This includes any packaging, loading, labeling, handling or paperwork preparation for wastes. The Minnesota DOT has an excellent on-line training program that is free of charge: http://www.dot.state.mn.us/cvo/training.html
"When my hazardous waste is accepted at a disposal facility, I am no longer responsible for it."
A: All generators have “Cradle to Grave” responsibility for their wastes. Under the CERCLA legislation, even after you have paid for proper disposal you are liable for a cleanup. Read more at the EPA website about CERCLA and superfund sites to better understand your potential liability for mishandled wastes.
"I can just pour old paint on cardboard, let it dry and throw it away?"
A: In Minnesota, it is forbidden to dry oil based (flammable) paints and throw them away. It is possible to dry Latex (water based paint), but the waste may be considered an Industrial waste and regulated by your local county. With paint and most other questionable wastes, it is recommended that the most responsible waste disposal or recycling effort is made to limit your current and future liability.
Do you have other questions about proper handling, storing or disposing Hazardous Wastes?