Hazardous Waste Disposal In Large Distribution Facilities

Large distribution facilities (e.g., an Amazon or Walmart warehouse hub) can sometimes require expert advice & help with hazardous waste disposal. This entry discusses how, why, and when. Q&As include:

1. When should the manager of a large distribution facility consult a hazardous waste management company?
2. What is a RCRA hazardous waste in a large distribution facility?
3. What materials are considered to be hazardous wastes?
4. What does the EPA consider to be hazardous waste in a large distribution facility?
5. What does the DOT consider to be hazardous waste in a large distribution facility?
6. What are some warehoused materials that might be considered RCRA hazardous when disposed of in quantity?
7. How can antifreeze be considered a hazardous waste in a large distribution facility?
8. How can dry cells or batteries be considered a hazardous waste in a large distribution facility?
9. How can e-cigarettes be considered a hazardous waste in a large distribution facility?
10. How can hand sanitizer be considered a hazardous waste in a large distribution facility?
11. How can oil-based paint be considered a hazardous waste in a large distribution facility?
12. How can ready-to-wear be considered hazardous waste in a large distribution facility?
13. How can beer be considered a hazardous waste in a large distribution facility?
14. Where can you get advice & help about managing large unanticipated amounts of hazardous waste in a large distribution facility?

1. When should the manager of a large distribution facility consult a hazardous waste management company?

Over time, a warehouse manager will inevitably face a large and unanticipated amount of material that needs to be disposed of (e.g., pallets of expired or damaged products). Such materials might seem totally benign but nonetheless considered a RCRA hazardous waste. (See Q.2)

If you were to throw away such materials into your usual waste stream, you would be in violation of EPA mandates and thereby exposed to any number of serious and expensive legal sanctions. As well, being cited as a “polluter” will militate against your company’s brand image in a very big way. Consider this headline: Whole Foods Reaches $3.5 Million Hazardous Waste Settlement.

It appeared in hundreds of news outlets in September 2016. Whole Foods strives to make environmental sustainability a major constituent of its brand image. Such values logically correlate with their target customers, who prefer additive-free “whole food” that is minimally processed or refined.

The company agreed to the settlement with the EPA regarding how they disposed of customer returns and out-of-date products that were no longer shelf-worthy. These included such innocuous goods as nail polish remover, hand sanitizer, liquor, vitamins, and other products that the EPA classifies as hazardous waste once they can no longer be used for their intended purpose.

There was no criminal intent. Nonetheless, there was significant damage to the Whole Foods brand image—especially since the settlement tossed the ecologically self-conscious company into the same shopping cart with Walmart, which perpetrated a similar brand fiasco upon itself three years prior (see source).

In sum, if you need dispose of warehouse-sized amounts of unusable motor oil, electronics, paints, batteries, light bulbs, smoke detectors, thermometers, “vape” cartridges, beer, and other seemingly innocuous garbage—you need expert advice about how to do so in full RCRA compliance.

2. What is a RCRA hazardous waste in a large distribution facility?

The primary law governing the disposal of solid and hazardous waste in the United States is the 1976 Resource Conservation and Recovery Act (RCRA) (see source). It authorizes the EPA to develop “regulations, guidance, and policies” for controlling hazardous waste from “cradle-to-grave,” including its generation, transportation, treatment, storage, and disposal (see source).

The initialism “RCRA” is often used interchangeably with “EPA.” The difference—albeit picayune—is that “RCRA” refers to “congressional intent” (aka, “the spirit of the law”) while EPA regulations accommodate that intent via explicit, legally enforceable requirements for waste management.

Those regulations—by the way— are conveniently available for your consideration as Parts 239 through 282 of Part 40 of the Code of Federal Regulations. Should that be too opaque for your bedtime leisure reading, you can visit the RCRA Tools and Resources webpage to find RCRA guidance and policy directives.

Be advised: Hazardous waste cognoscenti self-identify by transmogrifying the initialism RCRA into a tortured acronym pronounced rick-rah. Thus, if a material is considered hazardous by the EPA, those in the know will say it’s rick-rah hazardous.

3. What materials are considered to be hazardous wastes?

This is an intricate subject that goes beyond the purview of this blog entry. But generally speaking, the EPA and the DOT have their own (overlapping) ways of classifying something as a hazardous waste. (See Q.4 and Q.5)

4. What does the EPA consider to be hazardous waste in a large distribution facility?

For the EPA, there are (at least) three ways a material might be considered RCRA hazardous. To wit:

• The EPA deems a material RCRA hazardous if it displays one or more noxious characteristics such as corrosivity, ignitability, reactivity, and/or toxicity. In EPA parlance, any one of these is called a Characteristic Waste.
• However, there are certain materials that exhibit none of these five characteristics but are nonetheless listed as RCRA hazardous because they’re byproducts of processes that typically produce Characteristic Waste. Prosaically, these are individually referred to as a Listed Waste.
• And then there’s a nebulous category called Universal Waste, which is reserved for garbage that mightn’t be considered RCRA hazardous in household quantities, but as either a Characteristic Waste or Listed Waste in warehouse-sized accumulations. (This is another place where we always feel the obligation to counsel: Get expert advice.)

5. What does the DOT consider to be hazardous waste in a large distribution facility?

As they’re in the transit biz, the DOT has its own system for classifying hazardous waste, designed to inform transporters about what procedures to follow and precautions to take for a particular kind of hazmat in transit. This system sorts hazardous materials both within & across the three EPA categories described above. (See Q.4) They are:

1. Explosives
2. Gases
3. Flammable liquids
4. Flammable solids
5. Oxidizing substances, organic peroxides
6. Toxic or infectious substances
7. Radioactive material
8. Corrosives
9. Whatever doesn’t fit into 1-thru-8

6. What are some warehoused materials that might be considered RCRA hazardous when disposed of in quantity?

It’s not hyperbole to say that virtually any material can be considered RCRA hazardous if you have enough of it to get rid of. [Would you believe beer? (See Q.13.)] Thus, it’s virtually impossible to compose a comprehensive list of stuff that you shouldn’t load willy-nilly into one of those 40-yard dumpsters behind the warehouse. But some common culprits are listed below, each considered RCRA hazardous (in warehouse-sized quantities) when expired, spoiled, damaged, or otherwise unsaleable. They are:

• Antifreeze (Q.7)
• Dry cells (aka “batteries”) (Q.8)
• E-cigarettes (Q.9)
• Hand sanitizer (Q.10)
• Oil-based paints (Q.11)
• Ready-to-wear (Q.12)
• Beer (Q.13)

7. How can antifreeze be considered a hazardous waste in a large distribution facility?

The main ingredient in antifreeze (aka, radiator coolant) is usually ethylene glycol (aka, ethane). It’s an organic compound that’s odorless, colorless, flammable, and viscous. Unfortunately, it’s also toxic. Along with raising the boiling- and lowering the freezing-point of the coolant, ethylene glycol acts as a lubricant and anti-corrosive agent (see source). [Some types of coolant use propylene glycol instead of ethylene glycol, which is less toxic, but should nonetheless be handled with care (see source)].

If you have large amounts of antifreeze to dispose of, you need to get expert advice.

8. How can dry cells or batteries be considered a hazardous waste in a large distribution facility?

There are many kinds of dry cells and batteries. The present discussion is limited to the kinds of lithium-ion cells typically found in the home that might expire en masse in a warehouse (e.g., D, C, A, AA, AAA cells).

For retail consumers, the EPA doesn’t regulate the disposal of batteries in small quantities, although local jurisdictions might have specific rules for electronic waste disposal. This is because it’s dangerous to toss lithium-ion batteries into a trash or recycling bin. How so?

Once inside a refuse or recycling truck, surrounded by dry paper and cardboard, pressure and heat can cause lithium-ion batteries to spark, causing a rolling inferno. In fact, lithium-ion batteries are one of the leading causes of recycling-truck fires (see source).

For commercial and industrial users, the recycling of large quantities of batteries is regulated under the Universal Rules of Hazardous Waste regulations (40 CFR PART 273), which are imprecise enough about batteries to require careful interpretation and expert advice. Consider:

Universal waste must go to a “destination facility,” which is an entity designated to treat and dispose of universal waste—and manage it in accordance with the requirements and conditions of their hazardous waste facility permit.

Two examples of destination facilities are hazardous waste landfills and hazardous waste recycling facilities. But you just can’t shovel a ton of spent AAA cells into the corporate truck and dump them off at a destination facility. Instead, you need to employ the services of a universal waste handler that specializes in collecting, storing, receiving, and shipping universal waste.

If you have large amounts of dry cells or batteries to dispose of, you need to get expert advice.

9. How can e-cigarettes be considered a hazardous waste in a large distribution facility?

E-cigarettes have three main components: a cartridge that holds the flavored nicotine solution, a heating element, and a lithium-ion battery, each of which, in quantity, requires hazardous waste management.

The vaping liquid is a flavored nicotine solution that can be a threat to domestic pets and wildlife should it find its way into the environment, and even to children, should they find the discarded cartridges and play with them.

Various jurisdictions stipulate that waste containing any amount of nicotine requires hazardous waste management. For example, in Minnesota, there’s no minimal amount or concentration of nicotine-containing material that’s exempt from regulation. Regulations cover:

• The vaping liquid itself
• Shipping or storage containers for e-cigarette cartridges
• Used e-cigarette cartridges that have not been triple-rinsed
• Wastewater from triple-rinsing e-cigarette cartridges
• E-cigarettes themselves

If you have large amounts of e-cigarettes to dispose of, you need to get expert advice.

10. How can hand sanitizer be considered a hazardous waste in a large distribution facility?

Due to its high alcohol content, warehouse-sized amounts of hand sanitizer require hazardous waste disposal. This is for the usual environmental reasons & rules. But also submitted for your consideration:

If you pour fifty or so gallons of alcohol-based sanitizer down the drain, you’ll be introducing enough flammable-vapor generating liquid into the local sewer system to blow the manhole covers off their rings and up & away into the air.

Folks in the neighborhood will not be amused. The local and national press will have a field day. Such an event will garner a lot of unfriendly attention from federal, state, and local authorities. And seven-digit fines are the norm—not the exception.

If you have large amounts of hand sanitizer to dispose of, you need to get expert advice.

11. How can oil-based paint be considered a hazardous waste in a large distribution facility?

Oil-based paint is nowadays relatively scarce and usually sold only in small quantities (i.e., less than one quart). Composed of pigment particles suspended in oil, its viscosity depends on such solvents as turpentine or white spirit; and varnish might be added to increase glossiness. Unfortunately, these are RCRA hazardous wastes in and of themselves.

Also, VOCs such as mineral spirits, naphtha, and lacquer thinners are also constituents of oil-based paint, all of which have been in EPA crosshairs since the 1990s.

If you have large amounts of oil-based paint to dispose of, you need to get expert advice.

12. How can ready-to-wear be considered hazardous waste in a large distribution facility?

A million different ways. But for illustrative purposes, the topic here is limited to nylon.

Nylon is an extraordinary invention that’s probably the world’s most versatile synthetic substance. Essentially a simple plastic made from coal, water, and air; it’s the main constituent in a myriad of household, consumer, industrial, agricultural, and military products.

Perhaps inevitably, the ubiquity of nylon in our environment has its downside. While not an in-your-face candidate for hazardous material disposal, as a polymer, nylon doesn’t break down easily. So, it’s there to stay when it finds its way into our landfills and waterways.

Compounding the problem, nylon recycling is difficult. Consider:

Metal, glass, and other “recyclables” must be melted at high temperatures to be rendered into a reusable form. This provides the collateral benefit of incidentally purging any contaminants they might contain, such as microbes, bacteria, and non-recyclable materials.

Conversely, nylon cannot tolerate high heat, and it melts at a much lower temperature. This allows contaminants—organic or otherwise—to remain alive or otherwise unscathed. For this reason, nylon needs to be thoroughly cleaned before it can have a second life as a raw material.

If you have large amounts of nylon ready-to-wear to dispose of, you need to get expert advice.

13. How can beer be considered a hazardous waste in a large distribution facility?

We knew you were going to ask that.

Beer is brewed with yeast—and therein lies your hazardous waste disposal liability. Consider:

• Biochemical oxygen demand (BOD). Materials disposed of into water bodies or systems will decompose. Decomposition requires oxygen. Different substances consume more or less oxygen than do others. The metric for this is called Biochemical Oxygen Demand (BOD). Too much high-BOD waste can create an oxygen shortage that kills aquatic life: from microorganisms to fishes. (The EPA will not be amused.)
• Total suspended solids (TSS). Remediation of excessive suspended solids (per Clean Water Act standards) requires treatment or removal—probably both—and is expensive. (In Texas, two small breweries were each fined $5000 for their TSS peccadillos.)
• pH levels. Adding beer (and its attendant yeast) into a water body or system will affect pH levels, consequently making its acid or base levels inhospitable to important biota. (You so don’t want to do that).

Thus, warehouse-sized quantities of stale beer require hazardous waste disposal. Be it ale, larger, pilsner, porter, stout, or whatever, they’re all made with yeast and so require hazardous waste disposal in large enough quantities.

If you have large amounts of beer to dispose of, you need to get expert advice.

14. Where can you get advice & help about managing large unanticipated amounts of hazardous waste in a large distribution facility?

As in all things concerning hazardous waste, the experience, knowledge, and technical resources of a reputable hazardous waste management company are essential to keeping you safe and legal.

Remember, you’re responsible for a hazardous waste “from cradle-to-grave,” which means that selecting a transportation company that meets EPA muster is totally your responsibility.

Don’t take chances with your Company’s good name and fortunes. Get expert advice!

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