Hazardous waste management is an area that many organizations struggle with. The reasons vary, but they’re generally rooted in a lack of regulatory understanding or complacency.
While hazardous waste products may be dismissed as unimportant byproducts of an experiment or process, these materials need to be thoroughly reviewed and handled carefully. Poor hazardous waste management can lead to serious hazards and compliance issues that result in costly spills, exposures, and/or fines.
Unlike other components of your safety program, hazardous waste leaves the facility. Since the generator is responsible for waste from “cradle to grave”, incorrectly managed waste remains a liability even after waste removal.
Seven Steps to Effective Hazardous Waste Management:
All hazardous waste generators must conduct a thorough review of their hazardous waste streams. Reviews are generally conducted in coordination with a contracted hazardous waste hauler and documented in “Hazardous Waste Profiles” (aka “Waste Information Profiles” or “Waste Characterization Profiles”). Each profile needs to be specific to a single waste stream and should be reviewed and updated on a regular basis (at least annually).
RCRA regulations require clear labeling of all waste containers as “Hazardous Waste” with each constituent identified by using the full chemical name. Regulations prohibit any abbreviations, symbols, or other methods of identification. For instance, simply writing “Waste chemical name” on the existing label (or a piece of tape) is not sufficient. The most effective management programs utilize dedicated hazardous waste labels with pre-printed constituents to reflect commonly used waste streams.
All hazardous waste collection areas need appropriate signage. This includes signage for the Main Accumulation Area, Hazardous Waste Storage Area, and all Satellite Accumulation Areas. These signs should also clearly identify emergency contacts and PPE requirements for these areas.
Hazardous waste containers need to remain closed. Funnels left in drums or waste containers represent one of the most common violations of hazardous waste management. If this is a problem for your program, consider screw-on funnels equipped with a compliant (latched) lid.
The primary reason for the segregation requirement is to keep incompatible waste streams from mixing and creating additional hazards. For this reason, all incompatible waste streams (e.g., flammable vs. corrosive) must be contained in independent secondary containers. Spill trays or decks represent the most common segregation method. It’s also important to segregate hazardous waste and stock chemicals. That said, it’s acceptable to use the same storage cabinet as long as there’s a clearly delineated separation.
All hazardous liquid waste containers must be in secondary containment. Secondary containers must adequately contain waste volumes. This means having a containment capacity of 110% of the largest waste container. When collecting multiple compatible waste streams in the same secondary container, keep in mind that the available volume decreases each time you add containers.
All hazardous waste generators need to actively track waste generation volumes. This ensures waste is accounted for and allows facilities to anticipate changes in their waste generator status. Since hazardous waste management requirements increase as generator status increases, it is very important to be proactive about waste tracking to ensure compliance. The important thresholds to remember are 220 lbs (~27 gallons) per month for the jump from Very Small Quantity to Small Quantity Generator and 2200 lbs (~270 gallons) per month for the jump from Small Quantity Generator to Large Quantity Generator.