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Things You Think You Know About Hazardous Waste – Pt. 1

Over the next few weeks we are going to be doing a series about things you think you know about hazardous waste (that are actually wrong). These posts have been contributed by our 10-year Heritage Compliance Manager, Mike Karpinski. So without further ado, our first common misconception:

All hazardous wastes are “hazardous”

One of the key thoughts we try to convey in employee safety training at Heritage Environmental Services, LLC is the fact that the terms “hazardous waste” and “non-hazardous waste” are simply regulatory terms. There are many stipulations in the regulations that can classify a very dangerous chemical as a non-hazardous waste and a relatively benign waste a hazardous waste.

For example, there is a part of the EPA hazardous waste regulation commonly called the “mixture rule” for listed hazardous wastes that essentially states “the mixture of any listed hazardous waste with any other solid waste will result in the entire mixture being a listed hazardous waste.”

Reasoning by analogy, this means that if you take a swimming pool of water and add a thimble full of a listed hazardous waste you have created a swimming pool of listed hazardous waste. The swimming pool is probably still very safe to swim in but the water is a listed hazardous waste nonetheless (The swim suit you used for your dip in the pool and the water you used to shower off with after your dip will also be listed hazardous wastes until properly disposed of at a permitted hazardous waste treatment/disposal facility).

Some other common materials that may qualify as hazardous wastes include:

– Nicotine Patches

– Finger Nail Polish

– Hand Sanitizers

– Mosquito Spray

– Silly String

– Windex/Formula 409

– Teeth Whitening Strips

– Pool chemicals

– Gasoline

– Oil based paint

– Rechargeable Batteries

– Fluorescent Lighting

But don’t worry; men in dark suits are not on their way to take you away if you have thrown any of these things out at your home. Households are excluded from the hazardous waste regulations. If you are a business disposing things like these though you should probably stop and call a company like Heritage to help you manage these materials properly.

Household Hazardous Wastes

According to the EPA website, hazardous waste is waste that is dangerous or potentially harmful to our health or the environment. Hazardous wastes can be liquids, solids, gases, or sludges. They can be discarded commercial products, like cleaning fluids or pesticides, or the by-products of manufacturing processes. Although it may surprise you, many of these products could be sitting in your cabinets right now.

What to Look For

If the product you have says any of the following, you may have a hazardous waste on your hands: Flammable, Volatile, Toxic, Corrosive, Caustic, Reactive, Poison, Contains Phosphates, Eye Irritant, Harmful if Swallowed, or Do Not Mix. Once you identify a product with one of these warnings, make sure to take extra care when using it.

Some Common Household Hazardous Wastes

– Ammonia

– Drain cleaner

– Mothballs

– Oven cleaner

– Spot removers

– Window cleaner

– Aerosol spray

– Nail polish remover

– Toilet bowl cleaner

– Tub & tile cleaners

– Glues & cement

– Household batteries

– Paints & stains

– Brake fluid

– Lighter fluid

– Motor oil

– Transmission fluid

– Herbicides

– Insect repellents

– Pesticides

What Should You Do?

If you have a hazardous product, the best thing to do is make sure you use all of it for its intended purpose. If you can’t do that though, there are several organizations that sponsor hazardous waste drop-off events where you can bring your old products and be assured that they will be properly disposed of. The US EPA website is a good place to start finding a time and location that will work for you.

Top Ten Hazardous Waste Generator Violations (And How to Avoid Them): Part 3

This week we will finish the article about the Top 10 Hazardous Waste Violations (And How to Avoid Them) written by Patty Smith, CHMM (Certified Hazardous Materials Manager).

4. Used Oil Labeling Violations   

          AVOID this by:

1.) Understand the definition of used oil.

2.) Any container or tank utilized to hold used oil should be labeled “Used Oil”.

3.) Ensure fill pipes used to transfer used oil to a UST are marked “Used Oil”.

3. Universal Waste Violations

-Violations for Spent Batteries:

1.) If universal waste batteries are in poor condition, they must be stored in a closed container.

2.) Labeled “Universal Waste Batteries”, “Waste Batteries”, or “Used Batteries”.

-Violations for Spent Lamps:

1.) Universal waste lamps must be stored in a closed container.

2.) Labeled “Universal Waste Lamps”, “Waste Lamps”, or “Used Lamps”.

AVOID this by:

1.) Understand the regulations for universal waste.

2.) Train employees on proper universal waste handling procedure.

2. Open Container Violations

AVOID this by:

1.) Rule of Thumb- if the contents would spill if the container was overturned, then the container is considered open.

2.) Close and latch funnels; screw in bungs; use drum rings and tighten bolts.

3.) Train employees to close containers when not adding or removing waste.

 1. Storage Area Accumulation Date Violations

-Containers of hazardous waste in a 90 or 180-day storage area must be marked with an accumulation date.

 AVOID this by:

1.) Once 55 gallons of hazardous waste or 1 quart of acute hazardous waste is exceeded at the satellite accumulation area, storage area dating requirements apply after three days.

 2.) Make sure all containers of hazardous waste in storage are marked with waste accumulation dates during weekly inspections.

 In General:

• Familiarize yourself with the regulations.

• Know your generator classification.

• Select the best storage method for your hazardous waste.

• Train employees so compliance is a team effort.

Top Ten Hazardous Waste Generator Violations (And How to Avoid Them): Part 2

With the start of the new year, we return to the Top 10 Hazardous Waste Violations (And How to Avoid Them) written by Patty Smith, CHMM (Certified Hazardous Materials Manager). We covered numbers 10, 9, and 8 a few weeks ago and this week we will look at 7, 6, and 5. So, without further ado:

7. Contingency Planning Violations

Small Quantity Generator Requirements:

1.) Designate an emergency coordinator and post contact information.

2.) Post the location of emergency equipment.

3.) Post emergency telephone numbers.

4.) Ensure employees are familiar with emergency procedures.

Large Quantity Generator Requirements:

1.) Written plan on-site and up to date.

2.) List name, address, phone number (home and office) for designated emergency coordinator.

3.) Submit to local authorities.

        AVOID this by:

1.) Designate an emergency coordinator.

2.) Keep information up to date and on-site.

3.) Ensure all required elements are included.

4.) For LQG’s, document submittals to local authorities.

6. Satellite Accumulation Area (SAA) Labeling Violations

Either with “hazardous waste” OR Words describing the container contents

AVOID this by:

1.) Review and understand the definition of a satellite accumulation area.

2.) Label your container once the first droop of hazardous waste is added to the container.

5. Storage Area Labeling

Containers in a 90 or 180-day storage area must be marked with the words “Hazardous Waste”

AVOID this by:

1.) Once 55-gallons of hazardous waste or 1 quart of acute hazardous waste is exceeded at the satellite accumulation area, storage area labeling requirements apply after three days.

2.) Ensure all hazardous waste containers in the storage are marked “Hazardous Waste” during the weekly inspections.

Top Ten Hazardous Waste Generator Violations (And How to Avoid Them)

Over the next few weeks, we will be talking about a list of common hazardous waste violations provided by Patty Smith, CHMM (Certified Hazardous Materials Manager). Patty has been selling hazardous waste transportation and disposal services for over 20 years in the Tennessee, Kentucky and Alabama markets. Each article will offer a few tips (in a descending numbered list) about hazardous waste identification and proper disposal practices. These tips will help companies who often generate waste during business to properly identify and handle it.

10. Failure to Make a Hazardous Waste Determination

AVOID this by:

1.) Make a determination on all waste generated on-site.
2.) Treat unknown material as a hazardous waste during the determination process (label, close, date, etc.)
3.) Keep necessary documentation for both hazardous and non-hazardous waste.

9. Failure to Have a Hazardous Waste Reduction Plan On-Site

AVOID this by:

1.) Keep a copy on-site
2.) Update annually to ensure accuracy
3.) Management signature
4.) Ensure all applicable elements are included in plan

8. Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas

AVOID this by:

1.) Perform the inspections on the same day every week
2.) Mondays and Fridays are not a good choice
3.) Have a back-up inspector
4.) Document inspections on an inspection log

Got any tips of your own to share? Tell us about them in the comments section below!