Get Consultative Support and Comprehensive Services for Your Hazardous Waste Management

Most waste vendors will send you to a website to self-manage your hazardous waste requirements. Conversely, Hazardous Waste Experts provides consultative support to deliver comprehensive turnkey service to you. This blog entry discusses crucial hazmat-management issues and how we can help you negotiate them easily, legally, and cost-effectively. Q&As include:

1. How do you know if the EPA considers you to have a hazardous waste onsite?
2. What is “cradle-to-grave” responsibility for a hazardous waste?
3. What is a hazardous waste profile?
4. What are EPA “approvals?”
5. Can states make up their own hazardous waste regulations?
6. What are the advantages of a comprehensive hazardous waste management provider?

1. How do you know if the EPA considers you to have a hazardous waste onsite?

Short answer: Call or email Hazardous Waste Experts and we’ll let you know. Longer answer: In the EPA mindset, a waste can be RCRA hazardous in one of three ways:

1. Listed wastes. There are more than 500 substances deemed harmful to human health and/or the environment by the EPA if not managed properly. They are published in the Code of Federal Regulations (40 CFR Part 261) across four separate lists. Ergo, “listed waste.”

2. Acutely hazardous wastes. Some listed wastes are so toxic as to be fatal even in low doses. Hence, they’re called “acutely hazardous.”

3. Characteristic wastes. If a waste isn’t “listed” [per (1) or (2)], it might nonetheless be considered hazardous for one or more of its characteristics. So, “characteristic waste.” Some characteristics that grab EPA attention:

•  Ignitability—it catches fire under certain conditions. E.g., some paints, degreasers, or solvents.
• Corrosiveness—it’s a significant acid or base. E.g., rust removers, certain cleaning fluids, or battery acid.
• Reactivity—it’s prone to explode or release toxic fumes if heated, mixed with water, or pressurized. E.g., certain cyanides or sulfide-bearing wastes.
• Toxicity—it’s harmful or fatal if ingested or absorbed, or it can leach toxic chemicals into the soil or ground water when disposed of on land. E.g., wastes containing cadmium, lead, or mercury.

2. What is “cradle-to-grave” responsibility for a hazardous waste?

“Cradle-to-grave” means that you’re responsible for a hazardous waste from the moment you generate it, its subsequent transportation to a properly licensed storage or disposal facility, its proper treatment, and its proper disposal.

Your lawyer calls this “compliance liability,” which means that it’s solely up to you to ensure that whichever transporter, storage, and/or disposal company you engage to help you with your hazardous waste management is both qualified and properly licensed to do so.

This is no small thing. Because if anything goes wrong, you’ll bear primary responsibility, with all the legal and financial liabilities thereto, not to mention the public‑relations nightmare that goes along with being labeled a “polluter.”

Don’t go it alone. Hazardous Waste Experts offers comprehensive hazardous waste management services—from identification and segregation to secure storage, transportation, and ultimate disposal.

Get help now.

3. What is a hazardous waste profile?

One of the requirements of hazardous waste disposal is an onerous piece of paperwork with the rather opaque name “Hazardous Waste Profile,” formerly called a “Waste Characterization Profile.” We can compose this puppy for you and submit it for approval. But if you want to go it alone…

A Hazardous Waste Profile requires you to list the chemical properties of a waste so as to determine its classification for EPA and DOT shipping requirements.

Bear in mind, a Hazardous Waste Profile is a completely different animal from a Hazardous Waste Manifest. The former documents the chemical constituents of a waste; the latter is used to track it from “cradle to grave.”

The info needed to complete a Hazardous Waste Profile should be alive & well in your Waste Analysis Plan, which you were required to file as part of your EPA permit application to become a hazardous waste management enterprise way back when.

Just remember, this isn’t a place for guesswork. Let us help you complete your Hazardous Waste Profile and submit it for approval. Get expert help developing your hazardous waste profiles.

4. What are EPA “approvals?”

The EPA requires you to apply for “approvals” if your activities include hazardous substances such as fuel, explosives, pesticides, and more. (See Q.1.) The agency also requires certain industrial projects to have an EPA Works Approval for waste discharge, storage, and handling requirements. And you will need site-specific EPA approvals if your activities include PCB cleanup, disposal, or storage.

Don’t know how or where to get started? We do. Get expert help applying for EPA, state, and local approvals.

5. Can states make up their own hazardous waste regulations?

Absolutely. Individual states have the power to adopt hazardous waste management regulations that are more stringent than those of the federal government; and individual states can differ from federal guidelines about what constitutes a hazardous waste per se, as well as how it should be handled.

Examples might be an industry-specific waste in a state where that industry is common; or a unique military waste in a state with a large military facility; or where the federal government allows certain waste to be placed in landfills, some states do not.

Also, different states might have different regulations about “lethality” or “severe toxicity” characteristics when determining if something is a hazardous waste; or they might add to the characteristics already in place per the EPA.

There are other differences:

• Some states require annual as opposed to biennial hazardous waste management reports.
• Notification of “regulated waste activity” might require state-specific paperwork in lieu of federal forms.
• Time intervals between required accumulations might be tighter.
• Central accumulation areas might be required for “un-permitted” hazmat generators where the EPA requires them only for “permitted” generators.

In sum, while it’s necessary to know what the EPA requires for successful hazardous waste management, it’s not sufficient. States can impose regulations that are more restrictive and severe than their EPA counterparts, and they often do.

Running afoul of such local requirements can be expensive, litigious, and time-consuming. You need a consulting partner. Get expert advice.

6. What are the advantages of a comprehensive hazardous waste management provider?

It can be a full-time job in itself to ensure that a hazardous-waste company is adequately experienced to satisfy both federal and state hazardous waste regulations. This includes their financial integrity, insurance, employee-training, as well as proper licensing and “permitting.”

This is especially true as you might need more than one kind of vendor in order to comprehensively manage your hazardous waste stream: transporters, storage sites, treatment facilities, etc.

Hazardous Waste Experts is a comprehensive waste management service provider. We supply a one-stop solution for hazardous and regulated waste removal, transportation, and disposal.

We offer nationwide coverage and unsurpassed expertise managing a wide variety of hazardous and off-spec materials that can help you meet your EPA “cradle-to-grave” responsibilities for hazmat removal, transportation, disposal, and recycling.

Get expert advice today. Or call 1.425.414.3485.

And thank you for reading our blog!