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Basic RCRA Waste Regulations

For starters, I want to apologize for missing a day of blogging last Thursday. I attended a Heritage RCRA refresher course in downtown Indianapolis and was without internet for most of the day. On the plus side, attending the course gave me ideas for several different blog posts!

Over the coming weeks, I will be singling out some of what I learned and sharing it on here. To begin, I will go over the basic federal requirements set forth by RCRA. It is always important to remember, however, that each state likely has additional requirements that must be met.

The first thing you will want to do is make some basic determinations. On an ongoing basis you should be asking and answering the following questions:

  • In relation to identifying waste streams –
    • What are all the wastes being generated at my facility?
    • What are the different departments generating?
  • In relation to hazardous waste determination –
    • According to the regulatory definitions, which of the wastes being generated are classified as hazardous?
  • In relation to determining regulatory categories –
    • How much waste do you have on site and what is done with it? (see form 8700-12)

Next, you will want to make sure your containers are up to standard. It must be ensured that containers are:

  • In good condition (not rusty, no corrosion, no leaking)
  • Compatible with the waste (you want to make sure the waste will not react with the container)
  • Labeled or marked “hazardous waste”
  • Marked with an accumulation start date
  • Kept closed (as a rule of thumb this means you could tip it over and it wouldn’t leak)
  • Managed to avoid damage and releases
  • Kept free of incompatible wastes; incompatible wastes must never be placed in the same container

The third thing to check is that you are following regulations regarding accumulation areas. For this section you will need to make sure:

  • Ignitable and reactive wastes are at least 50 feet from the property line
  • “No Smoking” signs are posted
  • Incompatible wastes are separated or protected from each other
  • Emergency equipment is available
  • There is adequate aisle space maintained (at least 2½ feet)

Additionally, someone needs to:

  • Inspect container accumulation areas weekly
  • Inspect emergency equipment at least monthly
  • Make shipments every 90 days if you are a large quantity generator
  • Make shipments every 180 days if you are a small quantity generator

Lastly, you must follow the compliance documentation rules. These rules include:

  • Having a contingency plan
  • Having personnel training program and records
  • Documentation of inspections
  • Manifests and LDR forms
  • Biennial Reports
  • Waste analyses/determinations
  • Documented waste minimization program on site

Remember, these guidelines are just a starting point. To ensure compliance you must look into all regulations as they apply to your business, both at federal and state level. Keep checking the blog in the coming weeks for more information about RCRA.

Plastic Identification: How to Categorize Your Waste

Information for this weeks post was found via the The Green Guide. Below, you will find the different classifications of plastic, common items in each category, and information about recycling. To read more from The Green Guide Network click here.

 

1

Plastic #1: Polyethylene terephtalate, also known as PETE or PET.  Usually clear in color, the vast majority of disposable soda and water bottles are made of #1 plastic. This plastic is considered generally safe and is picked up by most curbside recycling programs. However, the porous nature of its surface allows bacteria and flavor to accumulate, so avoid reusing these bottles as makeshift containers.

 

2

Plastic #2: High-density polyethylene, or HDPE.  Most milk jugs, detergent bottles, juice bottles, butter tubs, and toiletries bottles are made of HDPE. Usually opaque in color and picked up by most recycling programs. This plastic is considered safe and has low risk of leaching.

 

3

Plastic #3: Polyvinyl chloride, or PVC. It is used to make food wrap, bottles for cooking oil, and the highly common plumbing pipes. PVC, although tough in terms of strength, is not considered safe to cook food near. PVC contains softening chemicals called phthalates that interfere with hormonal development. Never cook using food wrap, especially in a microwave oven. This plastic is rarely accepted by recycling programs.

 

4

Plastic #4: Low-density polyethylene (LDPE) is used to make grocery bags, some food wraps, squeezable bottles, and bread bags. While considered safe it is unfortunately not often accepted by curbside recycling programs.

 

5

Plastic #5: This is polypropylene. Common items produced with it include yogurt cups, medicine bottles, ketchup, syrup bottles, straws and similar wide-necked containers, as well as water bottles with a cloudy finish. This plastic is also considered safe, and is increasingly being accepted by curbside recycling programs.

 

6

Plastic #6: Polystyrene, or Styrofoam, from which disposable containers and packaging are made. Also found in disposable plates and cups. Overwhelming evidence suggests that this type of plastic leaches potentially toxic chemicals, especially when heated. Try to avoid the use of #6 plastic as much as possible. It is difficult to recycle and most recycling programs won’t accept it.

 

7

Plastic #7: This category basically means “everything else” and is composed of plastics that were invented after 1987 – the use of plastic in this category is at your own risk since you don’t know what could be in it. Polycarbonate falls into this category, including the highly toxic BPA. Products produced include baby and water bottles, sports equipment, medical and dental devices, CD’s, DVD’s, and even iPods. It is wise to dispose of any food or drink related product that is known to contain BPA. It is difficult to recycle #7 plastic and most curbside recycling programs won’t accept it.

 

Where do you recycle your plastics?