Alert, Alert: Updated CA “SB14” HazWaste Minimization Reports Due September 1, 2019!

(Note: this post was originally published in January of this year. We are re-posting due to the deadline’s imminence.) California Senate Bill 14 (SB14), the Hazardous Waste Source Reduction and Management Review Act of 1989, requires certain California hazardous waste generators to prepare hazardous waste minimization plans. We designed the above graphic to help you understand your reporting requirements. Under SB14, you are a qualifying generator if you...

• Generated more than 12,000 kg of hazardous waste (including RCRA and non-RCRA); or
• Generated more than 12 kg of extremely hazardous waste in 2018; and
• Your hazardous or extremely hazardous waste streams are not exempt from SB14 requirements. (Motor vehicle wastes, non-routine waste, universal wastes, excluded recyclables and some other wastes are not counted.)

There are 3 parts to an SB14 plan:

1. Source Reduction Plan (the “Plan”) – review of significant waste streams and waste reduction goals with respect to 2018 totals (checklist alternative for small businesses)
2. Performance Report – a summary of waste minimization results with respect to the previous (2014) baseline year (EPA Biennial Report alternative for small businesses)
3. Summary Progress Report (SPR) – concise summary of information contained in Plan and Performance report

SB14 plans are based on designated reporting years, on a 4-year cycle. Updated Plans, Performance Report and SPRs are due by September 1, 2019, for the 2018 reporting year. These must be maintained on-site and be available for review by regulators as requested. Current SB14 Cycle.... What is it all for? SB14 Plans focus on pollution prevention, source reduction and waste minimization, as opposed to recycling or treatment. Qualifying generators first prepare block-flow diagrams or similar process descriptions for their major hazardous waste streams (>5% of total hazardous waste). Next, source-reduction measures are identified for each major waste stream and evaluated for feasibility. Possible source-reduction measures include (but are not limited to):

• Input changes that reduce hazardous materials entering the production process
• Operational improvements and production process changes that improve efficiency or reduce amount of waste generated
• Product reformulation to reduce or eliminate use of hazardous materials in the production process
• Administrative steps such as inventory control or incentives that reduce waste generation

Finally, a forward-looking, four-year numerical goal should be set for feasible waste reduction measures and a schedule for implementation should be established. The numerical goals can be an overall reduction in waste or a reduction in waste per part or unit. Once prepared, the Plan can be amended as needed based on production or process changes. The Performance Report is a retroactive review of waste minimization performance with respect to the previous period’s Plan. The deadline is approaching quickly – if you need help or have questions, the ACTenviro EMS team is at the ready! Contact us with any SB14-related inquiries at [email protected].