Mailback Program

A Fast and Easy Solution For Your Universal Waste Needs:

Do you need an easy, convenient way to dispose of universal and other common wastes? For many commercial or small industrial companies, knowing if regulations apply, understanding what waste is appropriate for disposal, and finding a trustworthy supplier can be more than scary. Many states have different definitions of universal waste. But for the most part, they are items like batteries and light bulbs which are items found in every business. An easy yet still environmentally friendly way to manage or dispose of items that should not go in the trash is a Mailback program. A Mailback program is a way to purchase containers, pack away waste and mail it out to be taken care of by certified professionals.

What is Mailback?

This is an easy and convenient for individuals or businesses to manage their small-quantity wastes. You can order your size specific containers that are a perfect fit for the waste you currently have or fill it as you go. After ordering, the containers are shipped directly to you, ready to fill. Once you have fully loaded your container, just mail it back and the rest is taken care of.

How Does Mailback Work?

  1. Order: Buy your appropriate sized container that suites your specific needs. Most companies let you pay online to make it easy to get exactly what you need all in one place.
  2. Pack: Safely and securely pack your items into the container. Some companies will include easy to follow instructions to pack your container.
  3. Ship: After you have finished packing your container, it is ready to send back.

Who Can Use Mailback?

Mailback programs make the most sense for businesses who are generating medical waste. Some examples of those companies are: dental and doctor’s offices, pharmacies, tattoo parlors, hospitals and veterinary offices. Mailback programs give these places the opportunity to take care of their pharmaceutical and sharps waste. Expired medications can be taken and disposed of properly without risking them ending up in the wrong hands, or polluting our waterways. Although most users are ones who produce medical waste, there are still many other types of organizations that use a mailback system. A mailback system accepts items like light bulbs and batteries. Being very common items, there are a lot of possibilities for being a good fit for a Mailback program. Any small commercial or industrial business can benefit from this type of program.

Heritage LifeCycle Mailback

At Heritage we offer the LifeCycle Mailback program. You can order and pay for your container in one place on our website. We mail you everything you will need and make it easy to fill it up and send it back. The price for each item is all-inclusive. Along with your container, shipping labels are included with most containers for easy Mailback. Once your LifeCycle items are returned, you will receive a Certificate of Proper Management to ensure that your waste was recycled or handled properly.

Ready to Get Started?

If you feel like the LifeCycle Mailback Program is the right fit for you and your business, it is easy to get started! First visit our Heritage LifeCycle website: and take a look at the containers we have available. If you have some questions before you get started, you can call 1-888-347-7671.


Learn more about our other Hazardous Waste Services.

Preparing for the Unpredictable: Part 4

Natural Disaster Series: Special Requirement for LQG Waste Generators

Over the past few weeks, our blogs have been addressing issues pertaining to emergency response and natural disasters. A Large Quantity Generator (LQG) of hazardous waste must comply with prevention and preparedness standards that address daily management to prevent release, as well as develop a written Contingency Plan that documents how an imminent or actual release, fire, or explosion is mitigated and operations are returned to normal. Moving forward, new LQGs and LQGs updating their Contingency Plans will need to develop and distribute a Quick Reference Guide (QRG).

On November 28, 2016 the Generator Improvement Rules were published in the Federal Register, taking effect on May 30, 2017 in Iowa and Alaska. Over the past few months Pennsylvania, New Jersey, Georgia and Utah have also adopted the new rules. And while states that require legislative action for these changes have up to two years to adopt the more stringent portions, knowing the changes now can prepare you for when they take effect in your state. States are not required to adopt the less stringent requirements, but Quick Reference Guides are considered more stringent.

The Quick Reference Guide is required to be distributed to police departments, fire departments, hospitals and State and local emergency response teams that may be called upon to provide emergency services, and the Local Emergency Planning Committee (LEPC). Following the effective date of this updated regulation, new LQGs would be required to submit a Quick Reference Guide instead of the whole Contingency Plan when they update their Contingency Plans, and LQGs making modifications would only need to submit this new Quick Reference Guide.

Depending on the complexity of the facility, Contingency Plans can be quite lengthy. Contingency Plans include planning and response information which increases the complexity of the document. The size and complexity of the document can prevent first responders from identifying the relevant information needed to respond to an emergency situation. Having a shorter document that provides limited, relevant information for initial response is beneficial to both responders as well as facility operations management.

Required elements of the Quick Reference Guide are:

1. Type/names of hazardous wastes and the associated hazards;

2. Estimated maximum amount of each waste present at any one time;

3. Identification of hazardous wastes where exposure would require unique or special treatment by medical or hospital staff;

4. Map of the site where hazardous wastes are generated and accumulated and route to access the wastes;

5. Street map of the facility in relation to surrounding businesses, schools, and residential areas, how to best get to the facility or evacuate the community;

6. Locations of the water supply (i.e., fire hydrants and flow rates);

7. Identification of on-site notification systems (i.e., fire alarms, smoke alarms, release alarms, etc.); and

8. Name of emergency coordinator(s) and 24/7 phone number.

Heritage recommends submitting the Quick Reference Guide to your private emergency response provider(s) as well.

While the EPA is not formalizing the manner in which the Quick Reference Guide is submitted, they encourage generators to discuss with their local emergency responders how they would like the information conveyed. This could include incorporating the information into an existing application.

Heritage, in a continuing effort to support our customers, has created a model Quick Reference Guide. This document, which is approximately 5 pages in length, is a great place for generators to start in creating their own summary. Click here for the Example Quick Reference Guide 2017

Preparing for the Unpredictable: Part 3

Natural Disaster Series: Business Continuity Plan 

In the first part of this series, we shared three initial steps you can take to begin your natural disaster preparation plan. Part 2 introduced three key plans that can help you, your employees, and your facility quickly respond to an impending natural disaster. Here in Part 3, you will review the basics of preparing a Business Continuity Plan, including preparing for the elevated waste disposal needs that typically follow a natural disaster.

A business continuity plan helps you to be prepared to deal with the aftermath of a natural disaster. One initial concern is identifying an alternative location from where you can conduct administrative functions after a natural disaster. From there you can be in contact with emergency agencies, employees, customers, and suppliers. You will need to maintain an up-to-date list of contact information for those people and businesses and include it in the off-site backup that was discussed in Part 1.

To enable your business to stay operational or get back online, you need to evaluate potential supply chain issues. Your suppliers are a key part of your business operations. Disruption in your supply chain can stall your own recovery. For example, Hurricane Sandy in 2012 affected an estimated 10,000 manufacturing facilities, many of which were not heavily damaged but were forced to temporarily suspend operations due to supply chain disruptions. Prepare for this potential business impact by asking the following questions ahead of time: For each supplier, how long could you go without their supplies or services? What alternative suppliers could you use? Can you inventory a surplus of key products in advance?

The volume of debris and wastes that can be generated by a natural disaster is staggering. Hurricane Andrew generated more than 43 million cubic yards of debris, and the Joplin, Missouri tornado generated more than 1.5 million cubic yards. Although not on the same scale as these regional numbers, your business will undoubtedly need to prepare for out-of-the-ordinary waste disposal needs following a natural disaster. In addition to construction and demolition-like debris, you may have equipment that could release special wastes when damaged—materials such as hydraulic fluid, PCB-containing materials, lead acids, and so forth. Plan ahead by coordinating with your preferred waste disposal provider about post-natural disaster communications, potential waste types and volumes, and other facility-specific issues.

These important topics and more are discussed in the “Business Continuity Toolkit” available from the Insurance Institute for Business and Home Safety (IBHS). The toolkit walks you through the following steps in plan development:

  • – Know Your Risks
  • – Know Your Operations
  • – Know Your Employees
  • – Know Your Key Customers, Contacts, Suppliers, and Vendors
  • – Know Your Information Technology
  • – Know Your Finances
  • – Know When to Update Your Plan
  • – Know When to Test Your Plan

Although the toolkit states that it is particularly useful for small businesses, it can easily be expanded upon to meet the needs of larger operations. You can download the entire toolkit in pdf format, and the toolkit’s forms in customizable format, at this webpage:

We hope this information helps you get started on your preparations for potential natural disasters. If you would like to talk to us about facility-specific strategies, please contact us via our website at or call 877-436-8778. Heritage is here to help you succeed, no matter what Mother Nature may throw at you!

Preparing for the Unpredictable: Part 2

Natural Disaster Series: Planning Is Key

Part 1 of this series discussed three initial steps you can take to begin your natural disaster preparation plan. In this post, you will be introduced to three key plans that can help you, your employees, and your facility quickly respond to an impending natural disaster. 

“What?! More plans?” you groan. Not to worry, much of the information you’ll need for your natural disaster plan is already available in your emergency response plans and evacuation plans. It is best to pull that information out and put it in a stand-alone natural disaster plan so getting to it is quick and easy—you don’t want to be pouring through three other plans to find the natural disaster information you desperately need.

Every business needs to establish the emergency communications procedures to be used during a crisis. Identify an emergency communications coordinator that will work with specific individuals responsible for communications in distinct parts of your facility. You may also want to establish an emergency alert system for your site. Cellular communications can be easily disrupted during a natural disaster, so have alternative methods of communication established. Make sure your employees are well trained on how your emergency communications plan will work.

The Insurance Institute for Business and Home Safety (IBHS) provides excellent guidance and options you may want to consider using in your emergency communications plan. You can find the IBHS information here:

Know your shelter and evacuation plan. The type of natural disaster will determine if you and your employees need to evacuate the facility or shelter in-place. Include specific procedures and locations for each type of natural disaster you identify as having the potential to strike your site. Make sure your employees are trained on the correct shelter and evacuation procedures and that you provide reminder training before common natural disaster seasons arrive.

Have an emergency shutdown plan for securing materials and equipment that may be at risk during a natural disaster, such as those in outside areas or other vulnerable locations on your site. Identify equipment that needs to be powered down safely, equipment and materials that need to be secured, and utilities that may need to be shut off. If you have adequate warning of an impending natural disaster, arrange for hazardous and other regulated wastes to be removed from your facility by your waste disposal partner.

IBHS offers an “EZ-PREP™ Emergency Preparedness and Response Planning” guide for preparing an emergency preparedness and response plan, including customizable checklists for supplies and emergency preparation and response tasks.  You can download the guide and checklists here:

Next up in this series, we will present tips for getting started on your Business Continuity Plan, a must-have as you prepare for the unpredictable.

Preparing for the Unpredictable: Part 1

Natural Disaster Series: Beginning Your Preparation Plan

The recent hurricanes and earthquakes have affected the lives of millions of people in the Caribbean and North America. For those of us not directly affected by these recent events, it still gives us pause to consider what could happen where we live. Perhaps you are in tornado alley of the Midwest, blizzardy northern latitudes, or wildfire-prone areas. No matter where you live on planet Earth, there is a natural disaster type(s) that Mother Nature tends to throw at your locale.

Natural disasters can have devastating effects on businesses and local or regional economies. The Institute for Business and Home Safety says that 25″ or more of businesses that close due to a natural disaster never reopen. On a global scale, Business Insider reports that from 2000 to 2015, natural disasters cost the global economy $2.5 trillion. Consider these numbers to get an even clearer picture of the effects of natural disasters:

  • In 2016, Hurricane Matthew caused 49 fatalities and more than $15 million in damage in Florida, Georgia, and the Carolinas.
  • In 2015, the Okanogan Complex fire resulted in 3 fatalities and $8 billion in damages in Okanogan County, Washington.
  • In 2011, the Joplin, Missouri tornado resulted in 160 fatalities and more than $3 billion in damages.
  • In 1997, the Red River flood caused more than $2 billion in damages in North Dakota, Minnesota, and southern Manitoba.
  • In 1994, the Northridge earthquake resulted in 57 fatalities and $23 billion in damages in the greater Los Angeles, California area.

Although natural disasters are difficult if not impossible to predict, preparing for them is still an important part of every smart business operation. It doesn’t have to be expensive or time-intensive. Consider the following steps to get started on your natural disaster preparation.

Identify potential natural disasters that could affect your business locations. You’re probably already aware of the recurring biggies—tornadoes, hurricanes, and so forth. But also think a little broader to identify those that occur less frequently, such as local flooding during exceptionally wet springs or wildfires during exceptionally dry summers.

Consider the locations of your key supply and distribution partners. Map their locations and transport routes so you can see at a glance where natural disasters at other locations could indirectly affect your operations. Make sure you update your map annually to reflect changes to your supply and distribution chains. This simple map, along with news reports of potential or sudden natural disasters, can provide you with a heads-up that business disruptions could occur even when all is calm at your facility.

Review your insurance policy to ensure you have adequate coverage for the natural disasters that could strike your business. The coverage should include employees, buildings, machinery, equipment, and any other significant materials housed at your location, at a minimum. Business interruption coverage is also a good item to include in your insurance policy. It covers operating expenses such as utilities, and compensates you for income lost when a temporary business closure is needed. You may want to consider having a qualified insurance consultant review your insurance policy in light of the natural disasters you identified as potential risks for your location.

Back-up your tax, accounting, payroll, customer, vendor, and production records, and any other vital information to an off-site location at least 100 miles away from your business. Make sure this backup is completed routinely—ideally use continuous backup in real-time. If you use a remote backup service, make sure you know exactly where it is located so you understand the potential for backup issues should they be hit with a natural disaster.

In the next part of this series of blog posts, we will discuss some of the specific planning that will help you prepare for the unpredictable. In the meantime, here are two good sources of information on disaster preparedness and response: Insurance Institute for Business and Home Safety (; for Business (

No Smoking Signs

Signage Requirements of the Generator Improvements Rule

Authored by Angie Martin, Terry Ferril and Elizabeth Dillon.  


On May 30, 2017 the EPA’s Hazardous Waste Generator Improvements Rule became effective in Alaska and Iowa. New Jersey and Pennsylvania have already picked up the new rule, as well.  Over the next 12-24 months the remaining 44 states will have the opportunity to either incorporate the new rule in its entirety or piecemeal the rule contents, as long as each state adopts the more stringent parts of this new rule. One of the more stringent aspects of the new rule is the use of “No Smoking” signs for Large Quantity Generators (LQGs) with ignitable and/or reactive wastes.

40 CFR 262.17 (a)(1)(vi)(B) of the new rule states the following (emphasis added):

The large quantity generator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction including but not limited to the following: Open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat-producing chemical reactions), and radiant heat. While ignitable or reactive waste is being handled, the large quantity generator must confine smoking and open flame to specially designated locations. ‘‘No Smoking’’ signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.

For individuals who have been working in the hazardous waste industry for the last 20 years or so, you may recall that “No Smoking” signs have been raised as a non-compliance issue by some state inspectors. In fact, many state agencies have been enforcing a reference to a note indicated in the existing regulations. The regulations (§265.176) did not require “No Smoking” signs as a requirement for LQGs, only for treatment, storage and disposal (TSD) facilities (§265.17(a)). Clarification was requested and an EPA letter of interpretation was sent to Rosemary Cantwell at the Indiana Department of Environmental Management (IDEM) on June 8, 1995. This letter (RCRA online #14036) clarifies that signs are only a requirement of interim status and permitted TSD facilities not LQGs. It additionally states that IDEM could not issue a notice of violation based on a comment in the regulations if the generator was not otherwise required to comply. In other words, state regulators could not enforce a reference to a note. It is important to note at this time that some states have written into their own regulations that “No Smoking” signs are required for LQGs who have ignitable or reactive hazardous wastes. So while this new regulation may have to be adopted in some states, it may already be a requirement in others (i.e., Alabama, Arizona, Connecticut, Massachusetts, Minnesota, New Hampshire Rhode Island, Vermont).

Who does this affect? This new regulation will only affect LQGs who have ignitable or reactive hazardous wastes. Ignitable hazardous wastes are D001 characteristic wastes, or K or F listed wastes that have an “I” in the third column (i.e. F003, F005, K108, K171, K172). This also includes P and U listed wastes (virgin or obsolete chemicals) that also have an ignitable characteristic. You can refer to the product’s Safety Data Sheet (SDS) as to the flashpoint (<140˚F qualifies as D001), but you must verify that the flashpoint was conducted as a “closed cup” test. Reactive (D003) hazardous wastes are those that:

  • Are normally unstable or can change violently without a detonating;
  • React violently with or form potentially explosive mixtures with water;
  • When mixed with water, generate toxic gases, vapors or fumes;
  • Generate toxic gases, vapors or fumes and is a cyanide or sulfide bearing waste exposed to pH conditions between 2 and 12.5 s.u.;
  • Are capable of detonation or explosive reaction if subjected to a strong initiating source or if heated under confinement;
  • Are readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure;
  • Are a forbidden DOT Class 1.1, 1.2 or 1.3 explosive; and/or
  • Have an “R” in the third column of K or F listed wastes, or in parentheses for P- or U-listed wastes.
  • So what does this mean for LQGs moving forward? Based on past experiences, we anticipate that facility audits will likely include a line item for proper signage. The good news is that this requirement is an easy one to meet and maintain.

Where do you need signs? We recommend you begin by doing a facility walkthrough to create/review your hazardous waste areas where ignitable or reactive wastes are present. Such areas may include those where the waste is accumulated. Doing a facility walkthrough with this specific goal in mind will give you a fresh perspective on where signage is required.

What kind of signs do you need? Select signs that are large and have easily-readable print even from a distance. Given your workforce, signs in multiple languages may be necessary. Signs should be visible upon entering the area where the reactive and/or ignitable wastes are present and that routine operations in the area will not cause the sign to be blocked from sight (e.g., a parked forklift at the end of a shift).

Finally, make sure the signs are checked regularly to ensure they are still solidly mounted, undamaged, and conspicuous. You may want to incorporate this into your weekly inspection checklist. Hint – think like an auditor as you evaluate the areas and signs.

We hope you find these tips helpful as you navigate this new requirement. If you would like to talk to us about facility-specific strategies, please contact your local representative or reach out via our website.

Mercury Lamp Waste Management

A common inquiry we receive concerns proper management of spent mercury-containing lightbulbs or “lamps” and how lamp crushers can be used in the waste management process.

Mercury is a hazardous material. All fluorescent lamps and compact fluorescent lamps (CFLs) contain elemental liquid mercury, as do high-intensity discharge (HID) lamps such as mercury vapor, metal halide, and high-pressure sodium lamps. When a lamp is broken, the mercury vaporizes into an invisible, odorless, and tasteless vapor. Inhaling mercury vapor is extremely dangerous to human health. If released to the environment, the mercury can be transformed to methylmercury, which is more toxic than elemental mercury and which bioaccumulates within food chains.

Normal handling of intact lamps presents a very low risk of mercury exposure. Repeated exposure to broken lamps or a one-time exposure to a large number of broken lamps increases the risk. The key is to protect lamps from accidental breakage and properly manage spent lamps.


Since January of 2000, the USEPA has allowed spent mercury lamps to be managed as universal waste. A lamp generator can be a Small Quantity Handler of Universal Waste (SQHUW) or a Large Quantity Handler of Universal Waste (LQHUW) depending on the number of spent lamps accumulated at one time. See for the federal universal waste handler requirements in 40 CFR 273 Subparts B and C. Recycling of mercury lamps is strongly encouraged. If a facility does not choose to manage their mercury lamps as universal waste, they must then be disposed of as a full RCRA hazardous waste.

In addition, some states require broken lamps to be handled according to full RCRA hazardous waste regulations. Be sure to check with your state’s environmental agency for up-to-date waste handling requirements. The National Electrical Manufacturers Association (NEMA) makes available an interactive map with links to state environmental agencies and fact sheets. You can access the map at A USEPA table of links to state universal waste regulations is also available at

Sections 273.16 and 273.36 of the Universal Waste Rule discuss the general employee training requirements for small and large quantity handlers of universal waste. Specifically for mercury lamp management, the Association of Lighting and Mercury Recyclers (ALMR), with support from USEPA, developed an easy-to-use “Training Module (1-hour version) for Generators and Handlers of Fluorescent and Mercury-Containing Lamps (and Ballasts).” The document is available for download at

Lamp Crushers

Crushing is the intentional, controlled breaking of mercury-containing lamps into an appropriate storage container. Crushing itself is not recycling, but it can be part of a facility’s lamp recycling program. Crushing lamps can have several benefits: reduced risk of accidental lamp breakage during packaging and shipping of whole spent lamps; reduced handling time by eliminating the need to package and ship whole lamps; reduced storage space requirements.

A drum-top crusher is a mechanical device that is mounted on the top of a 55-gallon drum. The lamps are fed into the crusher and the crushed components are stored in the drum until ready for pickup for recycling or disposal. A 55-gallon drum typically can hold 1,000 or more crushed 4-foot lamps or the equivalent amount of other lamp types.

The lamp components are not separated during crushing, so the drum will contain mercury, phosphor powder, glass, and metals. The mercury will tend to evaporate, so an activated carbon filter is used to capture mercury vapor before it can be released to the ambient atmosphere. Dust filters and HEPA filters are also used to prevent particulate release.

Proper filter disposal depends on the specific type of crusher you use. The technical specifications for each type of crusher being considered or used should be carefully studied and understood to ensure filters are installed, checked, changed, and disposed of properly.

Monitoring and PPE

Areas in which a lamp crusher is used should be monitored for mercury vapor and mercury-containing particulates. The monitoring can be accomplished using various methods such as wipe sampling and air sampling.

At a minimum, Level D PPE should be used by employees operating the crusher or otherwise working in the immediate area. Higher levels of PPE may be required depending on the specifications of the specific crusher and area monitoring results.


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Spill Response Step-By-Step

If a spill happens at your facility are you prepared to handle it properly? Heritage Vice President Angie Martin, PE, CHMM, has broken spill response down into three distinct sections; what you can do before a spill occurs, what to do while a spill is happening, and what to do after the spill. While this list is not comprehensive (checking with state and local authorities is paramount) it is a good starting point for your Spill Response Preparation. Being fully prepared for any ER situation is the first and best step you can take to help mitigate risk to human health and the environment.

Before a Spill

There are several precautions/preparations you should have in place at all times. Doing so will help to minimize the risk for spills and the negative impact should a spill occur. These include:

1) Inventory your petroleum and hazardous materials. Knowing what materials you have at any given time will increase efficiency in case of a spill.

2)  Complete any regulatory required spill plans (Contingency Plan, SPCC Plan, RMP, FRP, etc.) and know where to access them.

3) Notify Local Emergency Planning Committees (LEPC) in Tier II as necessary.

4) Inventory, purchase, and inspect spill control equipment.

5) Train employees as needed (Hazardous Waste Operations and Emergency Response [HAZWOPER], RCRA, DOT, Confined Space, SPCC, etc.)

6) Conduct drills. Drills are imperative when it comes to spill preparedness. Remember, much of the world learns best through action, ensuring that all pertinent employees know how to respond in a spill situation will best protect everyone.

7) Contract with emergency responders. Have someone in place that can help you if a spill gets out of hand.

During a Spill

What if the worst has happened and your company is experiencing a spill right now? Start with these steps:

1) Safely identify and stop the source.

2) Notify appropriate authorities (National Response Center [NRC], LEPC, state environmental agency, local fire department, etc.)

3) Call your contract ER provider to request help or put them on notice.

4) Clean up the spill.

After a Spill

You’re through the worst of it but there are still some things to take care of.

1) Dispose of collected materials.

2) Replace any spill response inventory that was utilized in clean-up.

3) After action review. Analyze what happened during the spill. How did you respond? What went well? What needs improvement?

4) Amend plans as necessary. Think about anything that could have gone better and incorporate solutions in your spill plan.

Limited Quantity (LQ) and ORM-D Mini Primer

The following post is an excerpt from our September 2015 Regulatory Corner, a new Heritage news bulletin we will be including in future e-newsletters. To subscribe to our newsletter (and never miss an upcoming Regulatory Corner) click here.

In the January 19, 2011 Federal Register, DOT announced the elimination and replacement of the ORM-D marking for small quantities of hazardous materials shipments. The ORM-D marking has been mostly replaced with Limited Quantity (LQ), which is a diamond-shaped marking with black tips on the top and bottom. ORM-D may still be used, but only for ground shipments, until the deadline of December 31, 2020 (see January 7, 2013 extension notice). Additionally, to take advantage of ORM-D provisions your material also has to meet the DOT definition of a consumer commodity. This definition will also be removed, and is not a requirement to use the newer LQ designation.    

The usage of ORM-D/LQ has benefits which can include:

  • Shipping a DOT hazardous material without a shipping paper/hazardous materials bill of lading;
  • Shipping a DOT hazardous material without applying a Proper Shipping Name (PSN) to the package; and
  • Shipping a DOT hazardous material in a strong outer packaging rather than a DOT specification package.

How does ORM-D/LQ work?

A full discussion of these requirements is outside the scope of this post, but the key steps are as follows, using UN1759 Corrosive Solids, NOS as an example:

  • Determine what Proper Shipping Name (PSN) would normally apply to the material intended for shipment.
  • Review Column 8A of the Hazardous Materials Table (HMT) for your PSN to determine if a packaging exception is available. If no exception is identified in column 8A, then your hazardous material is mostly likely ineligible to be a Limited Quantity/ORM-D. Most exceptions are found in the 49 CFR 173.150s range of the DOT regulations. The PSN entry for UN1759, PGII and PGIII reference 49 CFR 173.154 in column 8A, however UN1759, PGI does not have an exception for LQ.
  • Read the exception and check that there is a Limited Quantity or ORM-D portion, such as 49 CFR 173.154(b) in our example above.
  • Ensure that your package conforms to the inner container limits for the applicable packing group, and that your gross package weight is within the limits (66 pounds gross weight maximum in most cases).
  • Apply the Limited Quantity diamond DOT mark to your package and ship.

As mentioned above, these are the key steps only, and many different situations may be applicable. For example, if you are shipping RCRA hazardous wastes or exceed a DOT Reportable Quantity (RQ) for a single package, in most cases you will only be able to take advantage of the no DOT specification package aspect of the Limited Quantity/ORM-D exception provisions. Please review the requirements for each particular situation and ship your hazardous materials with a focus on safety.

How Do You Make a Hazardous Waste Determination?

For sites that generate potentially hazardous wastes it is imperative that they make a hazardous waste determination for each and every waste generated. The determination process, also called the hazardous waste identification (HWID) process, is one of the first and perhaps the most important step for properly managing waste materials. To make a proper waste identification a generator must ask four questions:

  • Is the material a solid waste?
  • Is the waste specifically excluded from RCRA?
  • Is the waste a listed hazardous waste?
  • Does the waste exhibit a characteristic of hazardous waste?     

After answering each of these questions a generator will be prepared to facilitate compliant storage and disposal of any wastes generated.

Is the material a solid waste?

In order to answer the first question, 40 CFR Part 261.2 defines materials that are solid wastes and those that are not solid wastes. RCRA §1004(27) defines a solid waste as, “any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities.”

Additionally, the EPA provides several tools, including a Definition of Solid Waste (DSW) decision tool that can help walk you through this first step.

Is the waste specifically excluded from RCRA?

There are some types of solid wastes that the EPA excludes from the definition of hazardous waste. These materials, regardless of meeting a listing or exhibiting a characteristic of hazardous waste, cannot be considered a hazardous waste. According to §261.4(b), excluded wastes include:

  • Household Hazardous Waste
  • Agricultural Waste
  • Mining Overburden
  • Fossil Fuel Combustion Waste (Bevill)
  • Oil, Gas, and Geothermal Wastes (Bentsen Amendment)
  • Trivalent Chromium Wastes
  • Mining and Mineral Processing Wastes (Bevill)
  • Cement Kiln Dust (Bevill)
  • Arsenically Treated Wood
  • Petroleum Contaminated Media & Debris from Underground Storage Tanks
  • Injected Groundwater
  • Spent Chloroflurocarbon Refrigerants
  • Used Oil Filters
  • Used Oil Distillation Bottoms
  • Landfill Leachate or Gas Condensate Derived from Certain Listed Wastes
  • Project XL Pilot Project Exclusions

Many of these exclusions are conditional and often specific to an industry or type of waste. Careful reading of the conditional exclusions is necessary when making these determinations.

Is the waste a listed hazardous waste?

The EPA has studied hundreds of different waste streams and listed the wastes accordingly. Listed wastes are described or listed on four different lists that can be found at 40 CFR 261, Subpart D. These four lists are:

  • The F list — The F list designates particular solid wastes from certain common industrial or manufacturing processes as hazardous. Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources. The F list is codified in the regulations at §261.31.
  • The K list — The K list designates particular solid wastes from certain specific industries as hazardous. K list wastes are known as wastes from specific sources. The K list is found at §261.32.
  • The P list and the U list — These two lists are similar in that both list pure or commercial grade formulations of certain specific unused chemicals as hazardous. Both the P list and U list are codified in §261.33.

Does the waste exhibit a characteristic of hazardous waste?    

There are four characteristics of hazardous waste. These characteristics help us understand what the waste is capable of/how it poses a danger. The four characteristics are ignitability, corrosivity, reactivity, and toxicity. Full definitions of these characteristics can be found here.


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