The Retrofit Companies Blog

EPA Launches New E-Manifest System


New Regulations for All Hazardous Waste Manifests


EPA E-Manifest Rules Page 1

The EPA is in the final stages of developing their nationwide Electronic Tracking System, with a compliance target date of June 30th, 2018.
Click the button below to learn how TRC is making it easy for you to stay compliant.
EPA E-Manifest Flyer


Choosing a Reputable Partner Minimizes Your Risks for Regulated Waste Related Fines


One of the most important concepts for generators of waste to understand is Cradle-to-Grave.  You can see the EPA’s definition HERE.  But, in a nut shell, this means that the generator of waste is responsible to ultimate disposal.  Nothing will relinquish a generator of this responsibility and there’s no expiration date or time limit.  Hiring someone else to transport and dispose of your waste does NOT transfer responsibility. 

Read more:


Recently, charges have been filed against two vendors who were previously trusted to properly handle their clients’ waste.

Luminaire Environmental and Technologies Inc. Plymouth, MN

Recycletronics Sioux City, IA

Because the actions of your chosen vendors can also negatively affect your company image, as well as result in fines and other additional fees for you, it’s important to know the following about anyone you allow to manage your regulated waste:

  • Can they provide names and contacts to current customers (similar to you) as references?
  • Does the vendor have adequate insurance? They should be able to provide not only commercial liability, but also pollution coverage.
  • Where does the waste go? Can the vendor provide all downstream channel and facility information?
  • What documentation and paperwork is provided? Depending on the waste type, waste profiles and hazardous waste manifests may be required. Certificates of Recycling/disposal should be provided every shipment, and your vendor should be able to provide you with usage reports, as requested.

You should be prepared and have a plan. [Check out our blog for help preparing a waste management plan.] Monitor and manage your plan, and the service provided to ensure you are in compliance should never be overlooked.

At The Retrofit Companies, your environmental compliance is our top priority. We offer a range of environmental services, assisting with material inventories, legal documentation, and access to approved packaging options. In addition to proper shipping procedures and an extensive network of disposal partners, rest assured that your waste handling and recycling needs are covered by TRC. We're here to be the hazardous waste recycling and disposal partner you are looking for.  

Consult our haz waste team


Minnesota Hazardous Waste manifest Updates

Although TRC sent notices along with all the manifests that we generated earlier this year, it may be a good reminder to Minnesota generators that the MPCA is no longer requiring you to mail in the  “Designated Facility to generator’ (3 signature copy) manifest copies. Generators in Scott and Anoka counties still need to send in their copies to their respective Counties.


“For administrative and budgetary reasons, the Minnesota Pollution Control Agency (MPCA), and the Metropolitan Counties of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington (Metro Counties) have changed the requirements for submittal of hazardous waste manifest copies.

Effective April 30, 2016, all hazardous waste generators of any size in Anoka and Scott counties must submit manifest copies directly to their county.

Hazardous waste generators of all sizes anywhere else in Minnesota except Anoka or Scott County should no longer submit any manifest copies to either the MPCA or their county unless explicitly requested.

You may find a detailed discussion of this change in newly revised MPCA Factsheet #w-hw1-07, ‘Manifest Shipments of Hazardous Waste’ at: "


 Questions about compliance or waste solutions? Contact our team today!

Consult our haz waste team


Do you have a room, closet, or cabinet used for chemical storage? Maybe your business has a few old cans of paint, or an entire warehouse aisle of miscellaneous products that sit half-unused year after year, and you're not really sure how to start getting it all cleaned up safely and responsibly?

Keep reading to learn about the TRC process for managing hazardous waste cleanups for our clients, with attention to details, and in compliance with DOT and EPA regulations.

We start in one of two manners, either the client provides a waste inventory, or TRC comes on site to organize waste and create the inventory. Here's how each option works:


Client sorts and inventories their waste, and then provides TRC with that inventory along with SDS sheets for all wastes. The Environmental team likes to have pictures, so they know how much and what types of packaging to prepare for, and to get a clear idea of what is on site. TRC will often ask for that from the customer. TRC is then able to create a recycling and disposal estimate based on that inventory. The actual invoice will be based on the actual waste found on-site, plus time and packaging material needed to prepare the waste according to DOT and EPA compliance. This is certainly not a solution for everyone, and we do provide a simple hazardous waste inventory guide to help clients, but many people choose to have TRC take care of their chemical waste clean up from the start.



If your hazardous waste clean up project is large or complicated, or if your company doesn't have in-house environmental safety expertise, having TRC work on your chemical waste clean up from the start is a helpful solution. This is a tremendous benefit when internal resources or knowledge are not available to you. Clients simply contact TRC and schedule a time for the TRC Environmental Services team to come on-site. Under a T&M agreement, our professional team will:

  • sort your waste
  • organize wate by type
  • complete an inventory of your waste
  • package the waste in approved transport containers
  • prepare the required paperwork for shipment

Finally, TRC loads the waste onto our truck and hauls it off site to be processed and/or recycled. Our fees for this service include mileage charged to get the team on-site, an hourly labor rate for staff, and cost for packaging used needed, along with the disposal fees. One job, one invoice. We asked one of our recent clients about his experience using this exact service. He recommends, "Hire someone like TRC to handle it from start to finish. It was a big process, and your guys made it so much easier. It takes a lot of pressure off of you by having a qualified company handle it in a proper way."




At this point you have chosen to either create a waste inventory on your own or hire TRC to complete one, and your project will be handed from the account representative over to our environmental services team, the people trained to safely handle and mange hazardous wastes. 


Our team arrives on site at the scheduled time and begin to categorize all of the waste by DOT hazard classes and chemical compatibility. Each category is then inventoried before being packaged into UN-rated drums. The void space in the drums is filled with a loose packing media to prevent items from shifting during transit and to soak up any liquids that may spill. Each drum is assigned EPA waste codes and a shipping description from the DOT Hazardous Materials Table. All items are shipped either on a hazardous materials bill of lading or a Uniform Hazardous Waste Manifest. The on-site team prepares all of the shipping documents, labels, markings, and profiles required to legally transport your waste for disposal and/or recycling. The profile forms describe the waste to the disposal facility to ensure that an appropriate treatment plan is utilized. Clients receive copies of all shipping documents for their records.


Once the waste is shipped from the client's site is it brought back to TRC's licenses, 10-day transfer facility in Little Canada, MN. From there it is placed onto a semi-trailer with waste from other generators (clients) and shipped to the disposal facility for final processing. Upon receipt of the waste, the disposal facility signs the shipping documents and sends a copy of the now completed shipping document back to the original generator (that's you!) to help them maintain compliance.

You can read more about hazardous waste recycling and Envrionmental Services with TRC, or consult our team now with your questions!


Free Hazardous Waste Consultation

Has your old, unused material become Explosive?



We are often asked to properly dispose of hazardous wastes that have collected over many years, for schools and all types of businesses. These are chemicals and products that were used for maintenance, or in a lab or classroom at one time, that have outlived their usefulness. These products often spend many years in a back room, storage closet, or shed, and aren't easy to dispose of alongside standard trash items. It is important to safely and responsibly handle these products, as many product characteristics change over time and some even become unstable and explosive. Today we will share with you a specific type of compound that we come across quite often, that does just that.



Peroxides are a class of chemical compounds with unusual stability problems and are one of the most hazardous classes of chemicals routinely handled in the laboratory.

Peroxides can be formed via intentional chemical reactions (i.e., ozonolysis), but just as hazardous is inadvertent peroxide formation during storage of certain compounds. Some compounds form explosive peroxides. Others are polymerizable unsaturated compounds that can participate in a runaway, explosive polymerization reaction catalyzed by peroxides. To varying degrees, shock, heat, or friction may cause unexpected explosion of peroxidized organic chemicals.

We talked with Nick, one of our Environmental Specialists, and asked a few questions about benzoyl peroxide compounds and the proper way to handle hazardous waste disposal for these chemicals.

Where does this compound come from- why is it dangerous?

The product shown above was originally the cream hardener used to set automotive body filler. The primary active ingredient is an organic peroxide called Benzoyl Peroxide. This type of chemical, along with quite a few others, can form shock sensitive peroxide crystals as they age and dry out. Essentially, they turn into explosives over time. These aren’t stable explosives like C4 that require a large amount of energy to set them off though. They are very unstable and can explode seemingly spontaneously.

Are these compounds prevalent? Aside from the automotive body filler, what sort of products can this happen to?

I come across chemicals that we suspect have become explosive fairly regularly. In addition to automotive body filler, we see these types of chemicals in other common products. Many types of activators and catalysts for two part systems contain either benzoyl peroxide or methyl ethyl ketone peroxide, both of which can become unstable. In addition, there are a number of common laboratory solvents which can form unstable peroxide crystals. The two most common solvents we come across that exhibit these characteristics are tetrahydrofuran and ethyl ether.

What do you do when you arrive on a job site and find them?

When we encounter these materials we segregate them as safely as possible and work with the customer and a team of reactive specialists to safely remove the materials from the site.

What should our clients do if they find something like this or think they might have one of these compounds on site? How can they safely address this or identify a safety concern?

In the case of an emergency, they should always call 911. If it is a non-emergency situation, then we can help. It is important not to disturb the materials any more than necessary. I typically recommend that the area be quarantined to the best of the customer’s ability. Once you notify your TRC Environmental Representative, we will work to find a resolution ASAP.

Thanks, Nick. That was really helpful! 

If you have old material that is not being used at your facility, it is probably time to safely remove it! Click below to read the interview with one of our clients who had this waste in their facility. Find out how they were able to safely manage and properly dispose of it!

Managing Haz Waste in Schools Interview

Interview: Chemical Waste Clean Up in Schools


Today we talk to Dan Swanson, Building and Grounds Supervisor at Hermantown Schools about his recent first experience with The Retrofit Companies’ environmental services division. Dan is very near his retirement and working to tie up loose ends before he leaves his facility to the new supervisor. One of his looming jobs was to safely and responsibly take care of special wastes that had accumulated over the years. He chose to hire TRC for the first time ever to handle this chemical waste clean up project, and was willing to take some time to share the story with us. Let’s see what he has to say!


How did you hear about TRC? 

Your rep contacted me by e-mail. The timing was right, we needed the service, so I got in touch with them.


What made you decide to work with us? And what services did TRC provide for you?

We had a fair amount of hazardous waste build-up. There were a lot of things to take care of: paint, cleaning solutions, lights, etc. Our local waste company required us to inventory all the waste prior to disposal, but with TRC, they came and did all that.


Was TRC staff experienced & knowledgeable; were we able to provide a meaningful partnership and make your chemical clean up successful?

They did a great job. We had a short time line and everything just worked out. Our district is building new schools, and I’m set to retire shortly. It was important to take care of the waste before the new guy takes over.


How responsive was your TRC Sales Rep to your questions or concerns?

They are very responsive. Our clean-up project was taken care of in just a couple weeks from the first time I called.


Tell us about scheduling your cleanup – Were we able to fit your ideal schedule?

I had a small window of time and TRC was very helpful in meeting that time requirement. It took the stress away.


Tell us about your perception of value for the hazardous waste recycling service provided. Was it a good value compared to any other vendors that also provided quotes for the same project?
TRC was competitively priced, and we were happy with the quality of their service.


What advice would you give to other schools that wish clean out their chemical wastes?

Hire someone like TRC to handle it from start to finish. It was a big process, and your guys made it so much easier.


Would you recommend us to your colleagues? If yes, what was the greatest benefit you received by working with us?
Yes.  It takes a lot of pressure off of you by having a qualified company handle it in a proper way.


Thanks for the interview, Dan! We're happy to hear that your experience was a good one. It really does sound like managing hazardous waste was made simpler by working with TRC.

When you are ready to clean up the hazardous and chemical waste in your facility, learn how to choose a reputable hazardous waste vendor or get our inventory kit for free!

Hazardous Waste inventory help

MPCA Rule update for Haz Waste Paperwork Burden


A new rule was handed down from the MPCA (Minnesota Pollution Control Agency) affecting hazardous waste generators in some metro area Minnesota counties. In short, it relieves some of the paperwork burden for our hazardous waste generator customers.

With the exception of Anoka and Scott counties, generators are no longer required (unless specifically told to do so) to send any copy of a Uniform Hazardous Waste Manifest in to the MPCA.The requirement for mailing three signature copies to Anoka and Scott counties does not apply to PCB manifests. In all instances it is still required that all generators retain copies of all Manifests for a minimum of 3 years. Read on for more details and links:


Do I have to send copies of my manifests to anyone?

*As of April 30, 2016, the MPCA and Carver, Dakota, Hennepin, Ramsey, and Washington Counties no longer require generators of any size to send any manifest copies to them, unless explicitly requested. Do not submit a copy unless explicitly requested. Copies voluntarily submitted will not be reviewed or retained.

All generators of any size in Anoka and Scott County must submit a copy of the Designated Facility to Generator Copy (3-signature copy) to their county within 40 days of the designated facility’s receipt of the waste.

Note: The submittal requirements for Anoka and Scott County do not apply to manifests used for shipping only PCB wastes. Instead, keep these copies in your records and ensure you meet any additional PCB requirements. See MPCA fact sheet #w-hw4-48d, Manifest and Dispose of PCBs, at:


Learn more about Manifest Shipments of Hazardous Waste with this guidance document.

If you have specific questions about this rule or others, you can contact our Haz Team any time!


Consult Hazardous Waste Professionals


Interview: Safely Managing Hazardous Waste in Schools

Safely managing hazardous waste in schools

photo source

For as long as students have been in schools, the methods and tools of teaching have evolved and changed. Today we're sharing a short interview with a small school district that came up against a confusing, and potentially dangerous set of chemicals in their science labs that needed to go. The chemicals had eclipsed their classroom usefulness, and while they had been sitting idly on a shelf for some time the threat of their presence was real. The story is not unique, but not many clients we've worked with are willing to share. We're lucky to have this insight from a small district in South Dakota and hope it helps you.

If you're not interested in the interview, skip right ahead to get the Hazardous Waste Inventory Kit now and you'll receive:

  • A two page users guide to accurately inventory waste 

  • MSDS (Material Safety Data Sheet) Quick Facts

  • 3 ways to Find MSDS Sheets you need

Roxanne is the Business Manager for a small school district in South Dakota. Her job includes a wide range of responsibilities, which is something many of us are familiar with these days. Many times in our jobs, we are asked to make decisions, buy products, or hire vendors outside our personal scopes of expertise. Roxanne tells us more about their chemical waste disposal project, and how she found and decided to work with TRC. We also interview one of the TRC service techs about safely managing hazardous waste.


TRC: What was the nature of your project? Why did you hire TRC?

Roxanne: We had several old chemicals that needed disposal. Our school liability insurance carrier had instructed us (after an inspection) that the old chemicals would pose a liability issue to the school if anything should happen, like an explosion or fire. During the project, your tech discovered a chemical TRC could not dispose of. It was a very old chemical used in making bombs. [Editor: TRC does not handle explosive, radioactive, or bio-hazardous wastes.] The tech instructed us on who to contact and how it would be taken care of. We contacted the Sioux Falls, South Dakota, bomb squad and they set up a date to come down and dispose of the chemical.


TRC: How did you hear about us and what made you select TRC as a vendor for your project?

Roxanne: I spoke with your representative at a South Dakota Association of School Business Officials conference in Pierre, South Dakota. When we realized the need for this project TRC was the only vendor I had for this type of service.


TRC: Did you feel that TRC did a good job with project management, your budget, and helping you understand the process changes when the unexpected chemicals were found?

Roxanne: We are 100% satisfied with the service provided by TRC. We have received all the necessary documentation needed to show our liability insurance company that the volatile chemicals were removed from the school and disposed of correctly. The project was completed on time. We were quoted a price and were billed for the exact quoted amount.


TRC: What is the primary benefit you have experienced by using TRC as your service provider? 

Roxanne: After the TRC disposal visit, we are confident that the remaining chemicals we have are safe for the school environment.  We were contacted several times before the visit (to set up the date and time of visit) and several times after the disposal date (to check on our satisfaction and to check on the remaining chemical that was to be disposed of by the bomb squad of Sioux Falls).


TRC: Thanks, Roxanne. We really appreciate you sharing your story with us! 


That sounds like a pretty serious set of chemicals that Roxanne was dealing with, so we decided to talk directly to the TRC tech, Nick. He took care of the lab packing on site for this hazardous waste recycling project. 


TRC: What was the chemical that you found in the school? And why were you unaware of it before you came to do the lab pack?

Nick: They had solid benzoyl peroxide. We usually see organic peroxides in solution instead of as a solid.

TRC: How often do you find chemicals like this, are they really common? Where are they likely to be hiding out?

Nick: Organic peroxides are fairly common, but the vast majority of them are not explosive when they are initially purchased. More often when we come across explosive peroxides, they are materials that have been kept well past their expiration date and have become explosive over time. Cream hardeners for automotive body repair, ethyl ether, tetrahydrofuran, and picric acid are a few of the most commonly found items.

TRC: What is the best first step you would recommend to anyone trying to safely manage hazardous wastes or get a clean-up in motion?

Nick: For ongoing waste management it is important to be aware of what you have in your facility. Keeping a live inventory of chemicals and their expiration dates will help to ensure that chemicals are disposed of in a timely manner once they are no longer usable. Also, labeling of secondary containers is very important. Disposal of unknown chemicals is always a scary proposition, and for the most part it can easily be avoided by simply labeling containers. Finally, if you already have a large stockpile of chemicals that you no longer need, act quickly. Unfortunately, proper disposal of chemical wastes rarely gets cheaper over time and the risk of spills, reactions, and complications grows the longer you sit on them.

TRC: Thanks, Nick! 

 Are you dealing with a unique waste situation, or curious what it will take to clean up at your facility. Contact TRC today to talk to one of our environmental services specialists.

Free Hazardous Waste Consultation

Preparing A Hazardous Waste Management Plan

Hazardous Waste Management & Chemical Cleanup Resources for Businesses

There are a few obstacles to overcome when safely handling and disposing special waste and preparing a hazardous waste management plan. Aside from the obvious health risks, hazardous waste generators must also be aware of concerns that range from handling and storage to transportation and recycling. This article will help you understand what aspects to consider when deciding on a plan of action to dispose of your business’s special waste, including when to consult a certified Hazardous Waste Recycler.

Chemicals that are not frequently used often accumulate and are overlooked when it comes re recycling on a regular basis. These can be small bottles of miscellaneous chemicals, expired products, aerosols, or even cans of old paint. If you have ever generated any of these things you will remember that finding a recycling outlet can be difficult. Items like these not only tend to collect in our personal basements, but in the storage closets and cabinets at businesses as well. You must be aware that most chemicals, solvents, or any oil based waste are considered Hazardous Waste by the EPA. Your normal garbage company will not take these, so finding a safe and legal disposal method will be up to you.

What hazardous wastes might I have?

The chemical items we previously mentioned are classified as Hazardous Waste for a reason. Exposure to these chemicals or products could be detrimental to the environment and the health of others. Be sure you are properly trained before handling any hazardous waste.  While most businesses have minimal needs for chemical clean outs, there are a few industries where this service is practical and necessary:

  • Manufacturers – Expired products, maintenance chemicals, vendor samples, process wastes, spill waste
  • Educational Institutions – Research waste, lab waste, cleaners, maintenance chemicals, science department chemicals
  • Property Management – Expired products, old paint, expired cleaners, abandoned miscellaneous waste
  • Link to Top 40 Chemical Offenders

Storing & Handling Hazardous Wastes the in Workplace

The easiest way to find information on any chemical you come across is by referencing its Material Safety Data Sheet (MSDS). An MSDS is required to be provided with any potentially dangerous product. Every MSDS provides the following information:

    • Supplier Information (manufacturer of the product)
    • Hazardous Ingredients
    • Physical and Chemical Characteristics
    • Fire and Explosion Hazard data
    • Reactivity Data
    • Health Hazards
    • Safe Handling Precautions
    • Control Measures

There are multiple databases on line where you can look up the MSDS if you do not have a physical copy. The Material Safety Data sheet will be the first request from any Hazardous Waste Recycler. Download our

Having the proper paperwork is only useful if your employees are aware of it. Anyone who deals with hazardous chemicals or materials should know of their whereabouts. Store these documents in a convenient location so any employee can reference them if need be. Information is the most important tool when it comes to storing and handling your waste. Train employees on the proper safety procedures when using each waste. When it comes to accidents involving Hazardous waste, education is always the best prevention.

What Are the Benefits of Professional Hazardous Waste Disposal Service?

Disposing of Hazardous Waste is a time consuming, detail oriented process. Many of the chemicals listed above are not common recycling items. If you are unfamiliar with the chemicals you need recycled, it is likely that you are unfamiliar with the handling, packaging, and transportation regulations to dispose them. Also, if cleaning out your old chemicals is a rare occurrence, there could be a multitude of different wastes. Due to the potential risks, all Hazardous Wastes must be legally documented, packaged, and transported according to the Department of Transportation. This can be an overwhelming undertaking for the inexperienced.

Consulting a reputable Hazardous Waste Recycler is a simple solution. Experts will come on site and identify, sort, and take a detailed inventory of all of you Hazardous waste. They provide the required shipping documents, packaging, and labeling for each item. Their service does not stop there. After the necessary preparation, your waste is transported to vetted, licensed, and audited end facilities. Keep in mind: generators have “Cradle to Grave” responsibility for their Hazardous wastes, so having a trusted waste handling partner is important. Under the CERCLA legislation, even after you have paid for proper disposal you are liable for a cleanup. A  Hazardous Waste Handler will ensure all end facilities are a trusted, proven outlet for all wastes.

Do Your Research

Generators are legally responsible for their Hazardous Waste. It is crucial that you seek out a reputable Hazardous Waste Recycler when you are liable for any malpractice. Do some research. There are some credentials that you should look for when searching for this service:

  • Your Hazardous Waste Recycler should have a valid EPA ID number.
  • They should have at least a satisfactory rating from the Department of Transportation.  
  • A clean record when it comes to inspections is a must.
  • Recyclers that do not comply with the laws are shut down instantly.

 A Hazardous Waste Recycler’s reputation in this industry is invaluable. Full disclosure should be the selling point. Check what companies are registered locally when seeking out a professional service. The right Hazardous Waste Recycler can provide all of the necessary knowledge to properly dispose of your waste. Most importantly, they can provide peace of mind.

Our team is always standing by to help answer your questions. Contact us today!


Free Hazardous Waste Consultation

Troubling Waste News & A 500 Year Old Beauty Gets a Makeover // June Links

She’s 500 years old, but the new lighting is really doing wonders for her looks!

Lawmakers agree on an energy bill with a solar energy standard, but what will be the cost to energy consumers?

Here’s a little more insight on the background of  H. F. No. 956, with comments from German utility CEO regarding the country’s experience with solar power.

“Since Wisconsin launched a program for recycling electronic waste three years ago, the state has collected more than 100 million pounds of e-waste, exceeding targets by several million pounds.” 

For a little sweetness in your day, enjoy this! St. Paul’s Candyland as illustrated by WACSO (Walking Around Checking Stuff Out) “Even the Lights are Candy”

Don’t get caught disposing of illegally disposed hazardous wastes, like this company did!

Exterior lighting and landscaping, and how manufacturers have finally figured out how to ‘warm up’ colors of LED lighting.

EPA fines lighting recycler $72K for PCB contamination. Have you audited your recycling vendor lately? 

Newton North High School has the most efficient light bulbs and a sophisticated on line system that allows workers to control energy use remotely. But turning off the hallway lights in the state’s most expensive high school poses a problem. Read more

How LED lighting could be affecting your sleep patterns, and what one scientist is doing to make sure you get your Z’s! 

Looking for new ways to shine on the job and do something positive for your company’s bottom line? How Retrofitting Can Advance Your Career

7 Jobs That Make the World a Better Place…is your job on the list?

Can you trust your energy services vendor to deliver? Several municipalities in the state to have paid money for energy upgrades that were never delivered.

Energy efficiency is of paramount importance, but lighting innovations on the horizon range from smart lampposts that can sense gas hazards to lights harnessed for office productivity or even to cure jet lag!


MUST HAVE: Hazardous Waste Recycling Resource Guide

Hazardous Waste Recycling R

We've compiled this helpful Hazardous Waste Recycling Resource Guide as a way to keep some important reference information at hand when you are looking to learn more about hazardous waste disposal in Minnesota. 

When you download this resource guide, you will receive our thirteen page document that includes:

  • 4 online sources for searching MSDS (Material Safety Data Sheets)

  • MPCA Fact Sheet: Managing Universal Wastes Guidance (Minnesota)

  • MPCA Fact Sheet: Managing PCBs in Ballasts and Small Capacitors

  • MPCA Fact Sheet: Basic Hazardous Waste Requirements for Businesses

DOWNLOAD NOW: Hazardous Waste Recycling Resource Guide

For more information about Hazardous Waste Services:
Also, get our Haz Waste Inventory Kit

TRC clears up 5 myths to ensure proper chemical waste handling and disposal.


hazardous waste recycling.jpg

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

chem pails.jpg

"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:

"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? 

Consult Hazardous Waste Professionals


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