Some Year-End Hazardous Waste Management To-Dos

Perhaps immodestly, we years ago named our company Hazardous Waste Experts because that—after all—best describes who we are and how we do it. 

Just sayin.’ 

But that doesn’t mean we don’t listen to and learn from our myriad of commercial & industrial customers whom we help with hazardous waste management. That’s how we became hazardous waste experts in the first place.

All that said: the arrival of November means that we’re staring down the barrel of a new year, arriving in less than 60 days. And we’ve learned from our best & smartest customers that this is a good time to zero-in on your hazardous waste management.

Why, you might ask. Let us count the ways.

Fool your CFO

A pecuniary perversion of budgeting logic in large organizations is that if, as a manager, you’ve been prudent in the use of your resources, and so actually have money left over in your budget at year’s end, you’ll be rewarded by having said budget reduced by the amount you saved. 

So it’s almost a moral imperative to use as many of the hazmat dollars you’ve been allotted for use between last January and now. After all, you didn’t make up the rules. And failure to follow them can effectively underfund your future hazardous waste management efforts. 

So how to use those funds wisely?

Don’t be hoarding hazmat

Bear in mind that the EPA allows you to accumulate hazardous waste onsite only for a relatively short period of time prior to its disposal or recycling, otherwise you need a TSDF permit. 

So what are you saving it for? If you have barrels languishing onsite, a sudden swell in hazmat volume—whether for good or bad reasons—can push you over the limit.

When the permit-requirement kicks in depends on whether the EPA considers you either a VSQG (producing 220 lbs. or less of hazardous waste monthly) or an SQG (producing more than that up to 2200 lbs. monthly).

You can accumulate up to 13,228 lbs. of hazardous waste onsite for up to 180 days without a permit—or up to 270 days if you have to move it more than 200 miles for recovery, treatment, or disposal. Different quantity limits apply to acutely hazardous wastes.

If you exceed these limits, you’ll be considered a “treatment, storage, and disposal facility” (TSDF) and required to obtain the appropriate operating permit to carry on without fines and other ugly legal ramifications. 

In sum, getting all hazmat offsite before year’s end is a prudent way to use leftover budget.

Follow the science: psychology

The prospect of a new year somehow evokes resolutions from people for revival and renewal: a “new beginning,” “getting organized,” and—of course—joining a gym, which they’ll visit just once and pay $10 monthly forever.

Thereby, for whatever reason, people—employees—are more receptive to changing their behaviors come January than they are during other times of the year. So carpe diem. Now’s the time to initiate improvements to your hazardous waste management.

You can dedicate excess budget to updating employee training relative to hazmat generation vs. storage vs. transport. It’s also a good time for good housekeeping. For example:

• Tending to missing or non-compliant hazmat labels
• Checking for improper waste consolidation 
• Ensuring all hazmat containers have proper lid covers

Make sure you’re ready for an audit

There are core pieces of paperwork an EPA inspector will want to see when he or she visits your site. They should be organized together in a common space: in the same electronic file in the case of digital documents, or in the same filing-cabinet drawer in the case of hardcopies. 

Now is a good time to make sure you have at-the-ready:

1. Contingency plan for hazardous waste management. This paperwork is required of all hazardous waste treatment, storage, and disposal facilities (TSDF).
2. Hazardous waste training records for LGQ personnel. These must be on file for each person trained, and extant for minimally three years subsequent to his or her attrition.
3. Records of waste determination. You must document how you identified something as hazardous waste and what danger it poses.
4. Generator’s biennial report. This must be extant for three years after the due date: generally March 4 of even-numbered years.
5. Hazardous waste manifests. You must keep a copy of the manifest signed by the transporter for three years.
6. Land disposal restriction documentation. Certain records must be kept onsite for three years subsequent to your shipping hazardous waste offsite.
7. Tank and storage area inspection records. If hazardous waste is managed in tanks, inspection records must be on file until the facility closes.
8. Incident reports. (Let’s not go there right now).

 Get ready for that annual report

Every two years the EPA requires LQGs and TSDFs  to report the “nature, quantities, and disposition” of hazardous wastes they handle—a hazardous waste management form-filling exercise with the unusually straightforward moniker: Biennial Report.

It’s also called the Hazardous Waste Report in some official communications, and known to EPA hepcats by its alphanumeric appellation, 8700-13A/B. 

But whatever you call it, the report needs to be submitted to your “authorized state agency or the EPA Regional Office” by March 1st of every even-numbered year. 

We did the math. Divide 2022 by 2 and you get no remainder. It’s even.

There’s required paperwork that’s fairly common across different kinds of businesses that generate hazardous waste, and that you’re supposed to have on file for viewing on demand by the EPA. If these are up to date, they can be harvested for much of the information you’ll be asked for in your biennial report. Three of the most useful are:

• Records of waste determination. You must document how you identified something as hazardous waste and what danger it poses. (Just as importantly, you should document how you identified something as not being hazardous waste in the event you’re challenged about it.) Such records must be extant for three years subsequent to the last treatment, storage, or disposal of a material.
• Hazardous waste manifests. These are integral to most hazardous waste inspections. As a hazardous waste generator, you must keep a copy of the manifest signed by the transporter; a confirmation copy of the manifest with the TSDF’s signature must also be kept on file after the waste is accepted by the transporter. Both must be extant for three years.
• Land disposal restriction documentation. Certain determination and notification records must be kept onsite for three years subsequent to your shipping hazardous waste offsite to be treated before disposal.

The upshot

The advent of a new year is a good time to initiate changes that can improve your hazardous waste management. 

• It’s a good time to use any leftover budget. 
• It reduces the chances you’ll be inadvertently classified as a larger hazardous waste generator than you really are. 
• Your records will be in good shape for any audits. 
• And your employees’ psyches are more likely to be amenable to change at the start of a new year than they might be later on.

Contact us for expert advice. Or call (425) 414-3485. 

And thank you for reading our blog!