Tips for Managing Incompatible, Ignitable, and/or Reactive Waste
August 3, 2023

If your facility performs container stuffing or containerization of wastes that are incompatible, ignitable, or reactive, you have strict regulations that must be followed. The containerization of these materials is required to follow even stricter guidelines than those set forth under the Code of Federal Regulations 265.177 under Title 40 of the EPA rules. Your facility’s hazardous waste management should include these waste materials being physically separated in order to prevent them from potentially contacting and reacting with other waste materials.

Under the Code of Federal Regulations 265.177, if your containers hold hazardous waste materials which are not compatible with other waste materials that you’ve stored nearby, you are required to separate and protect them from each other. This protection or separation includes the use of walls, dikes, berm, or other devices. You are responsible for ensuring that no other waste has a chance for potential contact which would cause them to react.

Special Requirements for Ignitable and Reactive Waste

There are special requirements for reactive or ignitable waste materials. One of the most important of these requirements is they are to be stored at least 50 feet from your facility’s property line. The reasons for these storage requirements are that keeping these waste materials at least 50 feet from your property line will:
– Reduce or eliminate the general public from being able to come into contact with the materials and protect them from harm should an explosion occur
– Prevent the waste from drifting offsite should a release occur with these hazardous wastes

Distancing the waste is one requirement/regulation, and others include:

– Your facility is required to put precautions in place that will prevent accidental reactions of your reactive and ignitable waste materials
– Your hazardous waste management must include separating and protecting the waste materials from any source of ignition or reaction which include, but is not limited to eliminating any exposure to:

1. Flames or open fire
2. Cutting and welding
3. Smoking
4. Sparks from static, electricity, or mechanical operations
5. Hot surfaces such as machinery engines
6. Spontaneous ignitions from heat-producing chemicals
7. Operators handling the waste have to contain smoking and open flames
8. Sunlight or radiant heat

Your facility is also required to post “No Smoking” signs in conspicuous areas that have ignitable or reactive waste materials.

EPA’s Best Hazardous Waste Management Practices Guidelines

The EPA (Environmental Protection Agency) has set forth guidelines on how to conduct hazardous waste management for your reactive, ignitable, and incompatible waste materials:
– To prevent spills of these hazardous waste materials, you should use a hose or funnel to transfer materials into drums. The funnel should either be dedicated for this use, or rinsed thoroughly after use and the water characterized.
– If your container has a leak or is found to be in poor condition, the materials must be transferred to a new container immediately.
– Containers should be kept cool and dry.
– Make sure all storage areas for your containers are marked clearly and reactive/ignitable waste is in its own area.
– Do not stack containers holding ignitable or reactive wastes.
– A spark-proof bung wrench should be used when opening closed steel drums.
– Do not drag, roll, or push containers. You need to use the proper equipment when moving these storage drums.
– Forklifts, trucks, or other driving equipment should not enter the container storage area unless being used to move containers.
– Create a ‘containment area’ to store the containers that are capable of holding spills. The containment area can consist of walls, dikes, or berm.
– The storage drums should be kept in an area that is easily accessed by both equipment and people and moving around them can be completed easily.

Definition of Ignitable, Reactive, and/or Corrosive Materials

If your facility is having a difficult time identifying hazardous waste materials, talk to the experts at Environmental Marketing Services. These professionals can help you find an innovative and cost-effective solution to all your recycling and waste disposal needs. They will help your facility minimize liability and protect the environment through their hazardous waste management programs.

These are a few definitions to help you recognize ignitable, reactive, and/or corrosive waste materials:

Reactive Waste

A reactive waste is any material that is capable of undergoing a violent reaction or can explode. According to the EPA, reactive waste is:
– A material that will explode or react violently when it is exposed to heat, water, or handled under normal conditions
– A material that will emit toxic fumes or gases when it is exposed to water or under normal handling conditions
– A material that does not meet the DOT’s (Department of Transportation) classification rules
– A material that emits toxic levels of sulfide or cyanide gas when it becomes exposed to a pH range between 2 through 12.5

Corrosive Waste

A corrosive waste is either acidic or alkaline and can dissolve or corrode flesh, metal, or other materials. An excellent example of corrosive waste is automobile batteries as they contain sulfuric acid. If you are unsure which other waste materials fall under the corrosive waste category, talk to EMS (Environmental Marketing Services.)

Ignitable Waste

Ignitable waste is those materials that will catch on fire and sustain combustion. Much of your industrial waste such as cleaners and paints poses these dangers and is considered a fire hazard. Ignitable waste is typically in liquid form but the non-liquid waste is also hazardous as it can spontaneously catch fire when handled normally. Ignitable wastes are one of the most common hazardous wastes.

Consequences for Improper Hazardous Waste Management

Hazardous waste management is complicated, however, the professionals at EMS (Environmental Marketing Services) are here to help your facility navigate any complications.
These are some consequences your facility could face for not following state and federal regulations:

Failed Inspection

If your facility fails an inspection by the RCRA, EPA, OSHA, or other government agency it can cost you a lot of money. A failed inspection can also create a negative impact on your reputation, a hefty fine, or a shutdown of your facility.

Fines/Penalties/Increased Premiums

A failed inspection can create some long-term expenses for your facility. If a person should be harmed or injured on your site, your insurance premiums will increase and the cleanup could be very expensive to repair. Your facility could also face serious penalties and fines from any or several government agencies.

Employee Risks

Reactions, explosions, fires, exposure, or spills of toxic chemicals are serious risks of mismanaging hazardous waste materials. These threats put your employees, students, and others at risk for serious health conditions and even death. When your facility does not comply with state and federal agency requirements for handling these materials, not only are your employees, students, and others at risk, your entire facility’s future is at risk.

Hazard to the Environment

Hazard waste management is essential to protect your community and the environment. Contamination and pollution create negative impacts on the environment and your surrounding community if your hazardous waste is not handled properly.

Make sure your hazardous waste management team is properly handling your facility’s waste materials. Talk to the experts at Environmental Marketing Services for any help you need with your waste disposal or recycling needs. We are here to service government agencies, educational systems, manufacturing facilities, and more. We welcome the opportunity to help you go green, and develop a cost-effective solution to your hazardous waste disposal needs.

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