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Are They Hazardous Wastes… Pesticides and Herbicides?

Pesticides and herbicides are substances used to help control pests like insects, arachnids, rodents, and weeds. Oftentimes used in gardening, they are intended to help us keep these pests both from damaging produce and harming people with bites or stings. While these products are undeniably helpful, they also pose certain dangers.

According to the University of Missouri, accidental exposure to pesticides can occur through ingestion, inhalation, and/or skin absorption. Once exposed, pesticides can harm organisms including pets, livestock, wildlife, and people. Physical reaction varies in relation to the type of pesticide, the amount of pesticide one is exposed to, and the age and health of the victim.

Similar to most kinds of household poisons, children are generally more susceptible to harm from pesticides than are adults, due to lower body weight and increased toxins per pound. “Children are also especially sensitive to the neurotoxins often found in pesticides, because children’s immune systems, organs, brains, and nervous systems are still developing.”

In addition to poisoning, the EPA warns that, “The potential [negative] environmental impacts from pesticide disposal are air, soil, and water contamination from releases and accidental exposure of humans and animals.”

The environmental implications concerning improper disposal are the same as for the application process, except that the concentration of the pesticide may be stronger because of the quantity and mass of the disposed pesticide. The disposal of pesticides is a critical process; if not properly conducted it can have immediate, detrimental effects on the environment. The EPA encourages either storing excess pesticides for later use or returning it to the manufacturer for relabeling or reprocessing into other materials.

If you have any unused pesticides or herbicides the best way to dispose of them is at a Household Hazardous Waste collection event.

Some examples of the types of products to look for are:

  • Non-Aerosol Pesticides and Herbicides
  • Rat Poison
  • Roach Traps
  • Home and Garden Sprays (Non-Aerosol)
  • Roundup
  • Weed-B-Gon
  • Non-Aerosol Sprays
  • Citronella Candles
  • Fertilizer
  • Ant Traps
  • GrubEx
  • Weed and Feed

Is it Hazardous Waste…Batteries?

One of the most commonly known potentially hazardous wastes you can find in homes is batteries. This includes used or spent batteries, such as alkaline or lead-acid car batteries. I know that before I began working for a hazardous waste company I always wondered if I was doing the right thing with my dead batteries.

According to the Duracell website, normal alkaline batteries can, in most cases, be thrown out with your household trash; however, we recommend that you recycle them or take them to an HHW event whenever possible because, although mercury has been removed from most commercial alkaline batteries available today, they still contain toxins that should not be released into the environment.

Additionally, if you do choose to throw away your used batteries, it is important that you do so in small numbers. Even dead batteries are often times not completely drained, so throwing away large quantities of batteries together could still be dangerous. A large group of mostly used batteries can work together to produce a charge.

Lastly, due to the chemicals in battery types other than alkaline, you should make sure to recycle rechargeable, lithium, lithium ion, and zinc air batteries. There are several ways to recycle batteries, and a quick internet search will provide you with plenty of options including Heritage Lifecycle Battery Recycling Kits.

Some examples of the types of batteries you may have in your home are:

  • Car Batteries (Lead-acid)
  • Alkaline Batteries (AA, AAA, C, D)
  • Rechargeable Batteries (Lithium-ion, NiMH, NiCd)
  • Camera Batteries
  • Lithium Batteries
  • Zinc Air Batteries
  • Etc.

So now you know, while it is true that most standard batteries can be disposed of in your regular trash, it is still important to go about it the right way. Throw away only in small quantities and if possible take to a household hazardous waste day instead.

What are the Mixture and Derived-From Rules?

The EPA began developing the RCRA regulations and the definitions of hazardous waste in the late 1970’s. During that time their primary focus was on establishing the listings and characteristics necessary to properly identify which wastes deserved to be regulated as hazardous. As with most things, however, people had questions and concerns.

One such question asked, “Once a waste is identified as hazardous, what happens if that waste changes in some way? If the hazardous waste is changed, either by mixing it with other wastes or by treating it to modify its chemical composition, should it still be regulated as hazardous?” Due to the pressure to make decisions on these types of difficult questions quickly the EPA decided on a fairly simple and strict answer. They developed the mixture and derived-from rules.

One of the most important things to know about these rules is that they operate differently for listed waste and characteristic wastes. For listed wastes, the mixture rule says that a mixture made up of any amount of a nonhazardous solid waste and any amount of listed waste is considered a listed hazardous waste. So basically, if you have 10 pounds of nonhazardous waste and you mix it with 8 ounces of listed hazardous waste, your entire 10 pounds 8 ounces becomes a listed hazardous waste and bears the same waste code and regulatory status of the original listed component of the mixture. This principle applies regardless of the actual health threat posed by the waste mixture or by the mixture’s chemical composition.

The derived-from rule deals with the regulatory status of materials that are created by treating or changing a hazardous waste in some way. For example, if you have a hazardous waste and you send it to an incinerator, the resulting ash is considered derived-from the initial waste. For listed wastes, this rule means that any material that comes from the changing of a listed waste is a listed waste which bears the same waste code and regulatory status as the initial listed waste.

Basically this all means that if a waste matches a listing description it will never not be considered a hazardous waste, no matter what is done to it. Additionally, any material that comes into contact with a waste that matches a listing description is considered a listed waste, regardless of actual chemical composition.

The reason these rules are so strict it because if the EPA relied on the narrative listings alone to decide when a waste stopped being hazardous, industry might be able to easily go around regulations. For example, a generator or handler could mix two different wastes and say that they no longer perfectly matched the waste description and as such were no longer in need of regulation. This would be dangerous because the chemicals would still pose the same risks to human health and the environment. These rules also help encourage generators and handlers to keep listed wastes well segregated from other nonhazardous or less dangerous wastestreams since the more listed waste you have the more storage, treatment, and disposal you’ll have to pay for.

We mentioned above that the mixture and derived-from rules are different for characteristic wastes. This is because characteristic wastes can change once they no longer exhibit their hazardous characteristic. So, if a flammable waste is mixed with something that makes it cease to be flammable, it is no longer considered hazardous. Similarly, treatment residue or materials derived from characteristic wastes are only hazardous if they continue to exhibit the hazardous characteristic.

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Is it Hazardous Waste… Household Cleaners?

You may remember from some of our previous posts about household hazardous wastes that the rules are different for homes vs. businesses. The primary distinction being that residential homes are not regulated by the EPA. That said, it is still a very good idea to properly dispose of those items in your home which could be considered hazardous.

In the past we’ve written about telling the difference between hazardous and non-hazardous paints as well as knowing when aerosol cans are considered hazardous. Today I want to discuss household cleaners. While the ideal situation is that you would use up the cleaner via its intended purpose, I know that sometimes we buy items that we just don’t like; tile cleaners that don’t quite do the job, window cleaners that leave streaks, etc. When this happens we may find ourselves at a loss for getting rid of it.

The primary concern when it comes to household cleaners is whether or not they can be considered corrosive. A corrosive is any material that can cause skin damage to people or a substance that significantly corrodes metal. They can be liquid or solid and either acidic or caustic in nature.

Many household cleaners (such as bleach and ammonia) are considered corrosive materials. In addition to potentially causing severe skin damage, certain corrosive cleaning materials (such as toilet bowl or tub and tile cleaner) can be poisonous if ingested.

Another danger of cleaning materials is the fumes they give off which can cause significant damage to humans as well as the environment. These fumes can be made worse when different chemical cleaners are mixed, for example, ammonia and bleach. When combined, these two common household items will put off a toxic gas that initially attacks the eyes and mucous membranes. Prolonged exposure can burn the lungs, cause loss of consciousness, respiratory failure, and even death.

Long story short, it’s important to know what is in your cleaners so you can determine the best way to dispose of them. Luckily, many companies are now altering formulas or making “green” alternative options that you can buy. These should be easier to dispose of if need be. If, however, you have an old corrosive material it would be best disposed of at an HHW (household hazardous waste) event.

Hazardous Waste Listing Criteria

If we look back into the annals of EPA history before ever listing any hazardous wastes we will see that in the beginning the Agency had to develop the criteria that would serve as a guide for deciding whether or not a waste should be listed. These criteria are not used by hazardous waste handlers but rather serve as a frame of reference for the EPA when they are deciding whether a specific waste stream is eligible for listing. The lists decided upon and created by the EPA are then utilized by hazardous waste handlers for hazardous waste identification.

There are four different criteria the EPA utilizes as a basis for deciding whether or not to list a waste as hazardous. And while it may seem like they would correspond to the four different lists wastes can be split into, they are not directly related. According to the EPA the four criteria are:

  • “The waste typically contains harmful chemicals, and other factors indicate that it could pose a threat to human health and the environment in the absence of special regulation. Such wastes are known as toxic listed wastes.
  • The waste contains such dangerous chemicals that it could pose a threat to human health and the environment even when properly managed. Such wastes are known as acutely hazardous wastes.
  • The waste typically exhibits one of the four characteristics of hazardous waste described in the hazardous waste identification regulations (ignitability, corrosivity, reactivity, or toxicity).
  • When EPA has to cause to believe for some other reason, the waste typically fits within the statutory definition of hazardous waste developed by Congress.”

The EPA can decide to list a waste as hazardous for any and all of those four reasons. The majority of listed wastes, however, fall into the toxic waste category. According to the EPA, “to decide if a waste should be a toxic listed waste, EPA first determines whether it typically contains harmful chemical constituents. Appendix VIII of Part 261 contains a list of chemical compounds or elements which scientific studies show to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms. If a waste contains chemical constituents found on the Appendix VIII list, EPA then evaluates 11 other factors to determine if the waste stream is likely to pose a threat in the absence of special restrictions on its handling. These additional considerations include a risk assessment and study of past cases of damage caused by the waste.”

The second most common reason for a waste stream to be listed it that it is an acutely hazardous waste. The EPA designates those materials which contain constituents found in Appendix VIII, which are fatal to humans or animals in small doses, as acutely hazardous.

In order to indicate why a waste was listed as it was the EPA assigns a hazard code to each waste listed on the F, K, P, or U lists. These codes are:

Listed Waste Codes

The different codes assigned to wastes affect the regulations that apply to handling them. Acutely hazardous wastes (H) for example are subject to stricter management standards than most other wastes.

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

What are Hazardous Waste Listings?

Hazardous waste listings are used to describe wastes that the EPA has deemed dangerous enough to necessitate regulation. Hazardous waste listings describe wastes from various industrial processes, wastes from specific sectors of industry, or wastes in the form of specific chemical formulations.

In order to determine if a hazardous waste listing needs to be created the EPA must thoroughly study a waste stream and the threat it potentially poses to human health and the environment. If the threat is significant enough the EPA will include a specific description of the waste on one of the hazardous waste lists in the regulations. After the initial inclusion, any waste that fits the original listing description is considered hazardous regardless of its chemical composition or any other potential variable.

There are both advantages and disadvantages to using listings when defining hazardous wastes. For example, listing makes the hazardous waste identification process easy for industrial waste handlers since only knowledge of the wastes origin is needed to determine whether or not it is listed. This means there is no need for laboratory analysis. All one must do to determine if a waste is hazardous is to compare it to the narrative listing descriptions.

All that said, there are still some disadvantages. For instance, when initially determining whether or not a waste should be listed extensive study and resources are demanded of the EPA. Since resources are limited the listings can’t adequately address every dangerous waste. Additionally, hazardous waste listings are very firm. Each listing designates a waste as hazardous if it falls within a particular category or class meaning that the actual composition of the material need not be considered as long as the criteria for listing are met. Because of these weaknesses, hazardous waste characteristics are utilized to help address the shortcomings.

The EPA has studied and listed hundreds of different waste streams. These are all broken down into one of 4 different list types.

  • The F list – According to the EPA, “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 K list – EPA defines K listed wastes as solid wastes from certain specific industries. K listed wastes are known as waste streams from specific sources.
  • The P and U lists – The last two categories are generally lumped together due to their similarities. Both of these list pure or commercial grade formulations of certain specific unused chemicals as hazardous.

These individual lists may contain designations of anywhere from 30 to a few hundred different types of hazardous waste. Each different waste is assigned a waste code which consists of the list letter and a three digit number. So numbers may appear as, F001, K004, P007, etc. These codes play an important role in the managing of hazardous waste and as such it is vital to assign the correct code to your waste stream.

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

Hazardous Waste Counting

Last week we posted about the three different classifications of hazardous waste generators; small quantity generators (SQGs), Large Quantity Generators (LQGs), and Conditionally Exempt Small Quantity Generators (CESQGs). These three categories are broken down based on the quantity of hazardous waste generated in a calander month.

Since hazardous waste generators are divided into these three separate categories based on the amount of waste they generate, it stands to reason that waste counting would be an important aspect of hazardous waste generation.

In order to properly determine their generator classification, generators must count the quantity of waste produced each month. The regulations about which hazardous wastes must be counted in a generators monthly determination can be found in 40 CFR §261.5 (c) and (d).

According to the EPA, “a generator must include all hazardous waste that it generates, except hazardous waste that:

  • Is exempt from regulation in §§261.4(c) through (f), 261.6(a)(3), 261.7(a)(1), or 261.8
  • Is managed immediately upon generation only in on-site elementary neutralization units,
  • Is recycled, without prior storage or accumulation, only in an on-site process subject to regulation in §261.6(c)(2)
  • Is used oil managed under the requirements in §261.6(a)(4) and Part 279
  • Is spent lead-acid batteries managed under the requirements in Part 266, Subpart G
  • Is universal waste managed pursuant to §261.9 and Part 273.”

In order to avoid double counting, §261.5 allows for some wastes not to be counted when determining generator classification. All of these wastes are counted when initially generated. These include:

  • Hazardous waste when removed from on-site storage.
  • Hazardous waste produced by on-site treatment (including reclamation) as long as the hazardous waste was counted once.
  • Spent materials generated, reclaimed, and subsequently reused on site, as long as the spent material is counted once during the calendar month.

All information for this blog post was gathered from the EPA document, “Introduction to Generators.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

What is a Hazardous Waste Generator?

The Resource Conservation and Recovery Act (RCRA) is responsible for regulating hazardous waste from its point of generation through its final disposal. This “cradle-to-grave” system begins with hazardous waste generators. The EPA has developed generator standards for several aspects; from on-site accumulation of hazardous waste, to manifesting, to labeling, recordkeeping, and reporting.

Because hazardous waste generators produce waste in different quantities Congress broke them down into three distinct categories. These categories are Large Quantity Generators (LQGs), Small Quantity Generators (SQGs), and Conditionally Exempt Small Quantity Generators (CESQGs). The extent to which each type of generator is regulated is dependent upon the amount of hazardous waste each generator produces. All that said, the first thing to look at is what qualifies someone as a generator.

According to section 260.10, a generator is “any person, by site, whose act or process produces hazardous waste, identified or listed in Part 261 or whose act first causes a hazardous waste to become subject to regulation.” In order to make this statement more palatable, it helps to break it down by three integral terms you will need to understand.

By Site

The first term we need to look at is“by site.” This refers to where a hazardous waste is generated. It is important to note, however, that the regulations do not expressly define the word site. Since the EPA tracks hazardous waste generation by “individual generation site,” they issue unique identification numbers to each generation site. To do this they issue unique identification numbers to identify generators by site.

This is important because one owner or operator can have several sites being regulated. For example, if one owner/operator has 4 buildings on a single plot of land, each producing a hazardous waste, those four buildings can all have the same EPA identification number. If that same owner/operator has 4 buildings on four different pieces of property, however, each will need its own EPA ID number.

So, each individual “site” requires its own identification.

Person

The second important term is “person.”  260.10 defines person as “an individual, trust, firm, joint stock company, federal agency, corporation (including government corporation), partnership, association, state, municipality, commission, political subdivision of a state, or any interstate body.” As you can see, the definition is much more far reaching than you might anticipate. The definition of person as it relates to RCRA encompasses any entity involved with a process that generates a hazardous waste.

Act or Process

The third, and final, part to look at is the definition of the phrase “act or process.” According to a training module available from the EPA, “because a generator is defined as the person whose act or process first causes a hazardous waste to become subject to regulation, sometimes the generator of a waste may not necessarily be the person who actually produced the waste. For example, if a cleaning service removes residues from a product storage tank excluded in §261.4(c), the person removing the residues is the first person to cause the waste to become subject to regulation, not the owner of the tank (i.e., the person who produced the waste).” This example is also a good illustration of co-generators.

Co-Generators

Co-generation happens when more than one person can be considered a generator. In the cleaning example, even though the person removing the waste is not the owner/operator, he or she can still be considered a generator since they were the first person to cause the waste to become subject to regulation. In that same vein, the owner/operator is responsible because, “the act of operating the unit led to the generation of the hazardous waste.”

“In cases where one or more persons meet the definition of generator, all persons are jointly and severally liable for compliance with the generator regulations. The parties may through a mutual decision have one party assume the duties of generator, but in the event that a violation occurs, all persons meeting the definition of generator could be held liable for the improper management of the waste.”

Once it has been determined that a person is a generator, they must be classified into one of three categories. I think we’ll save that for another post though!

All information for this blog post was gathered from the EPA document, “Introduction to Generators.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

The Hazardous Waste Identification Process

The cornerstone of a successful hazardous waste management system is the proper identification of hazardous wastes. RCRA regulations at 40 CFR 262.11 require that any person who produces or generates a waste must determine if that waste is hazardous. 262.11 also provides four steps for generators to utilize in the process of hazardous waste identification. These are:

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

So, in order to properly identify hazardous waste, it stands to reason that we should work our way through those four points.

Is the waste a “solid waste”?

As with many things, the first step in hazardous waste identification is pretty intuitive. We must first determine if the material is a waste. After all, if it is not a waste it can’t be a hazardous waste. That said, determining whether or not something is a waste can get tricky. Take glass bottles for example, one person could see them as something to discard while another may see them as valuable due to their ability to be recycled.

Because of this ambiguity, the EPA developed a set of regulations to assist in determining whether or not a material is a waste. RCRA uses the term “solid waste” in place of “waste. Under RCRA, the term “solid waste” means any waste, whether it is a solid, semisolid, or liquid. The first section of the RCRA hazardous waste identification regulations focuses on the definition of solid waste and is a good place to look if you are confused about this step.

Is the waste excluded?

While solid wastes are rather abundant, just a small percentage of them qualify as hazardous wastes. You might think that distinguishing between hazardous and nonhazardous wastes is a simple matter of chemical and toxicological analysis. This, however, is not the case. We must first consider other factors before evaluating the hazard posed by the chemical composition of a waste.

Due to the fact that regulating some wastes may be impractical, unfair, or otherwise undesirable, the EPA has created exclusions. Household waste, for example, can contain dangerous chemicals, like solvents and pesticides, but making households subject to the strict RCRA waste management regulations would create a number of practical problems. Congress and EPA exempted or excluded certain wastes, like household wastes, from the hazardous waste definition and regulations.

Determining whether or not a waste is excluded or exempted from hazardous waste regulation is the second step in the RCRA hazardous waste identification process. Only after determining that a solid waste is not somehow excluded from hazardous waste regulation should the analysis proceed to evaluate the actual chemical hazard that a waste poses. Check 40 CFR to see if the waste you generate is excluded for any reason.

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.

The third step in hazardous waste identification is determining which (if any) of these lists your waste belongs on.

Does the waste exhibit a characteristic of hazardous waste?

We’ve talked about the characteristics of hazardous waste before. There are four different characteristics; ignitability, corrosivity, reactivity, and toxicity. If you need a refresher on the definitions of these characteristics check out our “Characteristics of Hazardous Waste,” post or our infographic depicting them.

The final step in the hazardous waste identification process is determining if your waste displays any of the four hazardous waste characteristics.

A Q&A About Hazardous Waste Containers

If a generator accumulates more than the satellite limit, when should they date the container?

When exceeded, not started.

What is meant by 3-days?

Three days means three consecutive days. It does not mean working days or business days.

Originally the EPA proposed 72-hours as the time limit, but realized that determining when 72-hours elapsed would require the container to have both date and time labeled.

The leg of a PPE suit is hanging out from under the secured lid of a container. Is the container open or closed?

Open.

Do containers in satellite areas have to comply with air emission standards?

No.

Do satellite containers need to be inspected?

The do not need to be although we recommend that you that you do so on a regular basis anyway.

Can a facility have more than one satellite accumulation area?

Yes, The regulations do not limit the number of SAAs. Likewise, the regulations do not limit the total volume of waste that can be accumulated at various SAAs. Regulation only limits to 55 gallons (1 quart) per SAA.

Can a satellite accumulation area contain more than one container?

Yes, It is permissible  to have more than one container, as well as more than one waste type in a SAA. Good management practice dictates how this should be done. SAA is limited to a total volume of 55 gallons (1 quart).

When a facility has equipment that discharges hazardous waste to an attached container, do the attached containers need to be in compliance with satellite accumulation regulations?

Yes.

Are the dirty uniform bins considered satellite accumulations of hazardous waste?  What about maintenance gloves?

No, Contaminated wipes, gloves, or uniforms being commercially laundered and subsequently reused are not discarded; therefore, they are not a hazardous waste.

So, how many could you answer correctly?