Waste Disposal

Waste Disposal

Why is it important to comply with the RCRA waste disposal regulations? Why should companies implement an active regulatory watch on RCRA updates?

Waste Disposal

The Resource Conservation and Recovery Act (RCRA) enables the U.S. Environmental Protection Agency (EPA) to control waste from “cradle-to-grave,” meaning it regulates the generation, transportation, treatment, storage, and disposal of hazardous waste. Solid wastes and underground storage tanks are also regulated under this Act.

RCRA requires industry to maintain and dispose of these wastes pursuant to certain recordkeeping, reporting, and waste management requirements.
The Act also contains specific provisions for land disposal restrictions as well as universal waste and used oil disposal. Other wastes, including medical and biohazard wastes are generally regulated at the state or local level.

Why is it important to comply with the RCRA waste disposal regulations?

RCRA establishes a “cradle-to-grave” management system that requires hazardous wastes to be properly tracked from generation through disposal.
Ensuring that waste is managed in an environmentally sound manner conserves natural resources and reduces the amount of waste generated by industry.
Federal, state, and local governments, in collaboration with covered industrial facilities, must control solid and hazardous wastes that, if managed improperly, can pose significant health and environmental risks.

Important provisions of RCRA

RCRA has four primary provisions: Identification and Listing of Solid and Hazardous Waste; Generator Requirements; Storage Requirements; and Standards for Particular Waste Management.

  • Identification and Listing of Solid and Hazardous Waste: Facilities must determine whether each waste stream generated is hazardous waste, solid waste, or is otherwise exempted from regulation under RCRA to determine how their wastes may be properly disposed.
  • Generator Requirements: Generator requirements vary depending on the amount of hazardous waste generated on-site. Hazardous waste generators are classified as a Conditionally Exempt Small Quantity Generator (CESQG), Small Quantity Generator (SQG), or Large Quantity Generator (LQG). LQGs are subject to the strictest regulation, while CESQG must only meet limited requirements found in 40 CFR Part 261.5. Both LQG and SQG must obtain an EPA identification number, prepare manifests, and properly package and label waste. Certain hazardous waste generators must also prepare emergency response plans, report and maintain certain records, and ensure employees who handle the hazardous waste are properly trained. A generator’s status affects the amount of time waste may be stored on-site before the generator must dispose of it.
  • Storage Requirements: Storage requirements vary based on where in the “cradle-to-grave” timeline you fall in and the quantity of waste that you generate. Generally, LQGs may accumulate hazardous waste on-site for up to 90 days, while SQGs may accumulate hazardous waste for up to 180 days. Exceeding these time limits will subject the generator to heightened regulatory requirements. Generators that store waste in tanks and containers must test the waste’s concentration, abide by emissions standards, and inspect and monitor regulated units. Transfer, storage, and disposal facilities are subject to additional permitting, storage, reporting, inspection, and recordkeeping requirements.
  • Standards for Particular Waste Management: RCRA imposes specific disposal standards for certain types of waste, including universal waste, used oil, and waste being disposed in a landfill. The universal waste provisions distinguish between small and large universal waste generators and impose requirements related to notification, labeling, accumulation time limits, employee training, and transportation.
  • The used oil management standards impose storage, transportation, burning, processing, and re-refining requirements. In addition, Land Disposal Restrictions (LDRs) require that wastes meet certain treatment standards before being disposed of in a RCRA land disposal unit.

Waste Disposal: Importance of implementing an active regulatory watch on RCRA updates

RCRA has been modified since its inception in the 1980s to update solid and hazardous waste definitions and modify waste disposal requirements. Facilities must look to the regulatory definition of hazardous waste to determine whether a waste stream is hazardous, which in turn affects the facility’s waste disposal requirements. Therefore, it is important to stay up to date on changing regulations.

Facilities should also monitor their hazardous waste inventories to determine whether they exceed specific threshold values for CESQG, SQG, and LQG status. Exceeding the monthly threshold for a particular status necessitates complying with additional generator and waste disposal requirements. Assessing hazardous waste inventories is particularly important where a facility introduces activities that may affect a waste stream or increase the amount of waste generated.

How can Red-on-line help with OHSAS 18001 certification?

Part of maintaining an OHSAS-approved occupational health and safety management system is identifying and updating all applicable health and safety regulations.
Red-on-line offers customized EHS legal registers that are constantly maintained and updated to ensure that you have the latest OH&S regulations at your fingertips.

Red-on-line’s team of EHS legal experts will evaluate your activities and determine which health & safety (generally OSHA) regulations apply to you.
We’ll keep an eye on regulatory updates so that you can focus on keeping your workplace safe and create a lasting safety culture. With Red-on-line’s software platform, you can track your regulatory compliance and track and address any health and safety issues you may discover.


Learn more about RCRA and Waste Disposal

Chemicals & Hazardous Products Certifications
RCRA Compliance

Definitions

What are Conditionally Exempt Small Quantity Generators (CESQG), Small Quantity Generators (SQG), and Large Quantity Generators (LQG)?

SQGs are facilities that generate more than 100 kg of hazardous waste per month and less than 1,000 kg per month. LQGs are facilities that generate more than or equal to 1,000 kg of hazardous waste per month. Facilities generating 100 kg or less of hazardous waste per month are classified as Conditionally Exempt Small Quantity Generators (CESQG) and subject to reduced regulatory requirements.

What are Land Disposal Restrictions (LDR)?

LDR standards require all hazardous waste to be treated prior to placement in a land disposal unit (landfill, land treatment unit, waste pile, or surface impoundment).

What is a Transport, Storage, and Disposal Facility (TSDF) ?

A facility that is permitted to treat, store, and/or dispose of hazardous waste in special units, often called hazardous waste management units.

What is Universal Waste?

Universal wastes are wastes with specific management standards, such as batteries, pesticides, mercury-containing equipment, and lamp bulbs. Often, states will include additional materials in the definition of “universal waste.”

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