Small businesses face issues with properly disposing of their manufacturing waste just as the larger companies face. All materials from your oils and solvents used to manufacture products to the pesticides and other commercial chemicals used in daily operations can become hazardous waste. You have to properly contain and dispose of these materials to comply with both Federal and State laws.
EPA Definition of Hazardous Waste
The United States Environmental Protection Agency (EPA) defines hazardous waste as a material that contains properties that make it a danger or is capable of producing harmful effects on humans and the environment. It can be generated from several sources and comes in many forms, including sludges, solids, gases, and liquids.
Industrial hazardous wastes can become a danger not only to humans but to the environment in which we live. The United States Environmental Protection Agency has placed restrictions on how industrial chemicals can be disposed. There are three methods typically used by professional waste disposal services:
- Underground injection wells
- Land disposal
Guidelines of the EPA
The United States Environmental Protection Agency (EPA) has created a list of what they consider hazardous materials. These materials are required to be disposed of following strict and regulated disposal methods. The EPA’s list is broken down into four separate categories:
- P and U-list are the unused chemical products your company has, such as pesticides and certain pharmaceutical materials. The P list identifies acute hazardous waste from chemical products. The U list identifies hazardous discarded commercial chemical wastes.
- K-list are your wastes from specific industries such as refining manufactures
- F-list is the waste generated from standard industrial processes. These wastes generally contain solvents or cleaners
- Other hazardous wastes not contained in these four lists include pesticides, mercury-containing equipment, batteries, light bulbs, also mixed wastes such as radioactive materials or those containing other hazardous components
The identification process is complex. Using a professional disposal service will ensure your business is properly classifying your waste materials.
When sorting the hazardous waste at your facility for disposal, you must first determine which class or list it falls under. Some solid wastes have been excluded from the Environmental Protection Agency’s RCRA (Resource Conservation and Recovery Act). If your waste is not included in the list, you do not have to treat it as hazardous. An example of waste you would not find on the list includes used oil filters and agricultural waste.
For a material to be considered a hazardous waste, it must be a solid waste, which can include your semi-solid, gaseous, and liquid materials. So, the first step in the identification process is to determine if your waste is a solid. Solid wastes are refuse or garbage, sludge from air pollution control plant, water treatment plant, or other thrown materials generated from an industrial, mining, agricultural operation, commercial, or other community activity. Almost any act we do leaves some kind of waste. Solid wastes are not limited to those which are physically solid. These wastes can be abandoned, inherent waste, military munitions, or recycled materials.
The next step is to determine if the waste is excluded from the regulation process as a hazardous material. It may save your company money to know which materials are non-hazardous, as there are different disposal regulations for them that may not cost as much to dispose of properly. Even if a waste meets specific criteria, or demonstrates a property of hazardous waste, it may not be classified as one.
When determining if your waste is excluded or not, you have to read the conditions and lists carefully. There are many exclusions to this list based on certain conditions. Having a professional waste disposal company working with you through the determination process will make sure you are complying with all regulations.
Once you’ve determined which list your waste falls under, you need to decide on its characteristics.
How to Determine the Characteristics of Hazardous Waste
There are some mixtures of waste that can be hazardous as a single material of waste, so listing them isn’t always going to be a plausible way to separate them. The RCRA states a waste must have these characteristics in order to be considered hazardous:
- Toxic- A toxic waste is any solid industrial hazardous waste that contains a level of contaminants that go over the accepted EPA guidelines. The allowable contaminant concentration depends on the material in question. It is important; you consult the EPAs official chart for each substance in question.
- Ignitable- There are a variety of solid materials the EPA classifies as ignitable. Liquids that have a flashpoint under 60 degrees Celsius are considered hazardous under the guidelines. Non-liquid solids that ignite under average temperatures from friction, absorb moisture or undergo chemical changes are considered hazardous as well. Oxidizers and any ignitable gases are also classified as hazardous. Examples of dangerous ignitable wastes include ethyl acetate and methanol.
- Reactive- Reactive materials are those which will react with contact to water and create toxic fumes and generate an explosive mixture. They are any materials that demonstrate a violent response when in contact with water. If a material or object will detonate, it also falls under this category.
- Corrosive- Materials classified as corrosive are done so due to their corrosive properties. An aqueous material is classified as corrosive if its hazardous pH level is less than or the same as 2, or more than equal to 12.5. A liquid is considered corrosive if it is able to corrode steel at a rate of more than 6.35 millimeters in a year at a temperature of 55 degrees Celsius.
This characteristic list means that even if your waste has been classified as a ‘listed’ waste, it must also be evaluated to determine if it is a characteristic waste. The rules are different for listed and characteristic wastes.
The determination of hazardous waste is a complicated process. Your hazardous waste disposal company will help in making the right choices and make sure you are properly disposing of your industrial manufacturing hazardous waste materials.
Properly Disposing of Your Industrial Hazardous Waste
There are severe consequences for not properly following hazardous waste disposal regulations. If you are in any way uncertain about how to handle your disposal, you should work with a reputable hazardous waste disposal company to avoid unnecessary penalties.
Not being aware of laws and regulations will not excuse your company from not following federal and state laws regarding proper hazardous waste disposal. You will still be subject to punitive actions as well as fines when found not to be in compliance.
Not only are the rules on how to ‘list’ and ‘characterize’ your waste materials complicated, but it is also challenging to store, transport, and dispose of the waste. This process has high consequences for not complying with regulations, and can even add increased costs for mislabeling waste. Work with a reputable hazardous waste management service, and you will ensure proper identification, storage, transportation, and disposal of your industrial hazardous waste is handled properly.
Non-hazardous waste also needs to be disposed of correctly. Your non-hazardous waste is any form of industrial waste that cannot be put into your dumpster or down the sewage lines. Examples of what your non-hazardous waste could include are lactic acids, sugars, carbonates, bromides, and many others.
Most of what is considered household garbage are non-hazardous. Disposal protocol and regulations for non-hazardous materials are much less strict than those for hazardous ones. This does not mean it can be thrown away; you are still required to use a reputable disposal service to get rid of this waste.
Methods of Disposing of Industrial Hazardous Waste
There are several techniques used to manage hazardous wastes safely:
- Recycling – Some waste materials become raw materials and are able to be used for other processes, can be reused, sold, or recovered.
- Incineration- Some hazardous waste materials can be burned. This process has its drawbacks as when the waste is burned, it creates hot gases that go into the atmosphere. These gases have the potential of carrying toxic materials that have not been consumed by the flames.
- Reduction- Reduction involves reducing the waste stream at the start of operations. Generators of waste can change their materials and manufacturing to cut down on the amount of waste they create. An example would be a food packaging plant replacing their solvent-based adhesives with water-based adhesives to seal their packages.
- Treatment- There are a number of biological, thermal, and chemical processes that can be applied to toxic compounds to neutralize or destroy them. An example of this method is chemicals or microorganisms that can remove hydrocarbons from water that has been contaminated.
- Land disposal- Certain hazardous waste materials can be buried in landfills. Federal and state regulations mandate these materials to be pretreated before they can be disposed of in a landfill. The materials can then only be placed in specially designed landfill disposal facilities.
Industrial Waste and Toxic Chemicals
The TRI (Toxics Release Inventory) was created under the Emergency Planning and Community Right-To-Know Act in 1986. This act requires certain industrial facilities that use toxic chemicals to report their waste management activities annually. If your company uses these materials, you are required to report your toxic chemical releases.
In the year 1988, the TRI requirements were extended to a second group of industries. The second group consists of metal and coal mining industries, electric utilities burning either oil or coal, wholesale chemical distributors, petroleum terminals, bulk storage facilities, solvent recovery services, and RCRA subtitle C hazardous wastewater treatment disposal facilities. Those who are required to submit this report has to have ten or more full-time employees and use a certain threshold of the toxic chemicals.
Local and state governments also have regulatory responsibilities established for proper disposal of industrial hazardous waste. These regulations are sometimes the same as the EPA, and in some locations, they are in addition to the ones established by the EPA. One example of these additional laws are in the State of Texas. In Texas, they categorize non-hazardous industrial waste into three classes. Each class is determined by the potential harm to human health and the environment. Working with a hazardous waste disposal service will ensure your industrial waste disposal complies with all regulations.