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Cashins & Associates Blog

Hazardous Waste Management

Posted by Mike Cashins on Fri, Sep, 13, 2013 @ 16:09 PM


How do I dispose of this waste?  Is it hazardous?  What is universal waste?  Which waste regulations apply to my facility?

The topic of hazardous waste is confusing to many people, and rightfully so.  Both the Federal Government (EPA) and the State of Massachusetts (MassDEP) regulate hazardous waste, and each agency has countless requirements and details to sort through.  This article serves as a starting point for individuals who want to learn more about hazardous waste. 

Which agency governs my facility and my waste? 

In Massachusetts the Mass Department of Environmental Protection (MassDEP) is the overarching authority in the case of hazardous waste.  MassDEP hazardous waste regulations are stricter than the EPA regulations, so compliance with the MassDEP ensures compliance with the EPA.  The MassDEP hazardous waste regulations are found in 310 CMR 30.0.

First things first:  Is this material a waste?

It may sound silly, but it’s important to understand the regulatory definition of waste.  The MassDEP defines waste as “any discarded material”.  It can be a solid, liquid, semi-solid, or contained gaseous material.  It can also be in the form of a sludge which is generated at wastewater treatment plants, water supply plants, or air pollution control facilities.  It could also be garbage or rubbish that contains chemicals or items which meet the definition of hazardous waste.  That’s why it’s important to understand your waste streams and segregate them accordingly (hazardous, non-hazardous, recyclable, etc.)

It’s important to note that materials that are abandoned – or are accumulated or stored prior to being discarded are also considered to be waste.  Take some time to look around your facility to see if unused chemicals are hidden in out-of-the-way places.  Know which chemicals have expiration dates, and dispose of them in a timely manner.  Chemicals stored beyond their expiration date can decompose, become less stable, and in the case of peroxide-forming chemicals can be explosion hazards. These expired chemicals can become safety and industrial hygiene hazards. 

Is my waste hazardous?

Here’s where things get interesting – and somewhat complicated.  Your waste is hazardous if it meets any of the following criteria:

  1. It has any of the following hazardous characteristics:  ignitability, corrosivity, reactivity, or toxicity.  Specific requirements must be met for your waste to have any of these characteristics.  For example, “corrosivity” means any aqueous solution with a pH less than or equal to 2, or greater than or equal to 12.5.  In addition, “corrosivity” includes liquids which corrode steel (Type SAE 1020) at a rate greater than 6.35 mm per year at a test temperature of 55ºC. 
  2. They are on one of the lists published by the DEP.
    1. The “F” list includes wastes which are generated in certain industrial operations such as degreasing and electroplating.
    2. The “K” list addresses wastes that are produced by specific industries.
    3. The “U” list summarizes commercial chemical products – in either pure or “off-spec” form – that are hazardous when they are discarded.
    4. The “P” list is also known as the Acutely Hazardous list. Chemicals on this list are extremely toxic or reactive and must meet additional, stricter requirements.

What about oil?

MassDEP regulations for waste oil are stricter than EPA regulations.  There are different disposal regulations and options for oil, depending on the type of oil in question:  used waste oil, used oil fuel, specification used oil fuel, off-specification used oil fuel, etc.  Some oils can be recycled.

Speaking of recycling, what other items can be recycled?

Scrap metal, electronics, and many other items including some unused commercial chemical products and some types of sludge can be recycled.  MassDEP regulates these recycling activities.

What is universal waste?

Batteries, pesticides, and mercury-containing devices such as thermostats and fluorescent lights are defined as universal waste.  These wastes are still hazardous, but are regulated differently than other types of hazardous waste.

OK, so I have hazardous waste.  How do I comply with the regulations?

There are many details to sort through.  The list below gives general guidance on how to get started.  Please note that some of the requirements below vary – or are not required – by your generator status.

  1. Determine your generator status – are you a large quantity generator (LQG) of hazardous waste, a small quantity generator (SQG), or a very small quantity generator (VSQG)?  The generator status is determined by how much waste you generate each month. 
  2. Apply for an EPA facility ID number.  The MassDEP coordinates this application process.  Call 1-800-462-0444 for MassDEP assistance.
  3. Know and manage your accumulation time limits, which are determined by your generator status.
  4. Use licensed haulers and treatment, storage, and disposal facilities to dispose of your hazardous waste.
  5. Understand your waste manifest obligations.  Manage and retain them accordingly.
  6. Make sure your hazardous waste storage areas meet all the requirements listed in the MassDEP regulations.  Inspect these areas each week.
  7. Ensure that any containers and tanks which are used to store hazardous waste comply with MassDEP requirements.
  8. Designate an emergency coordinator who is on call at all times to coordinate hazardous waste emergency responses.
  9. Implement the emergency preparation and response requirements.
  10. Train employees who handle hazardous waste or would participate in emergency response actions.
  11. Notify your local authorities (police, fire, board of health, etc) of the types of hazardous waste at your site, the types of injuries that could result from accidents involving hazardous waste, your site layout with entrances and evacuation routes, and other key information.

If you require assistance in complying with the MassDEP hazardous waste regulations, Cashins & Associates, Inc. can help. Contact us today to speak with an in-house professional who can help you understand the regulations, manage your hazardous waste program, and ensure compliance. Click below to submit your inquiry! We will get back to you within one business day.

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