(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].

California Assembly Bill 1429, which was signed into law in July of 2019, effected a variety of changes in reporting requirements related to Hazardous Materials Business Plans (HMBPs), and we are here to help walk you through them.

As of January 1, 2020, many California businesses only need to submit an HMBP into the California Environmental Reporting System (CERS) every three years, instead of annually. Affected businesses will still need to certify the HMBP annually, though.

Key points to keep in mind:

  • Businesses that have over 10,000 pounds of hazardous materials (or over 500 pounds of Extremely Hazardous Substances) are subject to Tier II of the federal Emergency Planning and Community Right-to-Know Act (EPCRA) and must continue to submit their HMBP every year.
  • Businesses that have more than 1,320 gallons of petroleum or petroleum products in tanks or tanks systems (55 gallons or greater) are subject to the Aboveground Petroleum Storage Act (APSA) and must also submit annually. Note that this includes oil-filled equipment.
  • Businesses that are not subject to EPCRA Tier II reporting or APSA, but that do store hazardous materials above California threshold amounts, must review and certify their HMBP annually (even if there are no changes) but only need to re-submit their HMBP every three years.

Businesses Subject to EPCRA or APSA Requirements
Businesses subject to EPCRA or APSA must continue to submit their HMBP information into CERS annually by the local CUPA submittal date or annually on or before March 1 if there is no locally-established date.

Businesses NOT subject to EPCRA or APSA
California business that are not subject to EPCRA or APSA but that store more than 55 gallons of a liquid, 200 cubic feet of a gas or 500 pounds of a solid must submit an HMBP – but now, under AB1429, these businesses only need to re-submit their HMBP into CERS every three years.

  • However, there are some exceptions and also some more restrictive local requirements.

In other years, if there are no HMBP changes, these businesses only need to certify that their information in CERS remains the same (unless there are more restrictive local requirements, like a local ordinance that requires an annual HMBP submittal). Businesses should check with their local CUPA for clarification.

Businesses must continue to update and resubmit their HMBP within 30 days if there are significant changes, including:

  • A 100% or greater increase for a chemical in the inventory or a reportable quantity of a new chemical.
  • Changes in where or how chemicals are used at the facility that could affect emergency response, changes to business name, ownership or address or other substantive change in operations.

CERS Certification Process
To submit the annual certification (if there are no changes):

  • Log into CERS and select business and facility.
  • Click the “Create All HMBP Submittal Elements” option, confirm and submit

For more information, please request our ASSEMBLY BILL 1429 (AB 1429) BUSINESS PLAN SUBMITTAL UPDATE fact sheet from your account manager or by emailing [email protected].

And please do not hesitate to contact us through either of these channels if we can provide any assistance with your HMBP or any other safety or environmental issues!

– James Kapin, Director of EM Services

As a hazardous waste generator, you know your waste containers need to be labeled, but sometimes it is not clear exactly what needs to be included on those labels. Requirements can vary depending on your state, where in your facility the waste is kept (Satellite Accumulation Area or Central Accumulation Area) and what you are doing with the waste (“accumulating” or “transporting”).

We will review waste labeling requirements below, but first let’s clear up some terminology. When waste is being collected in “satellite accumulation areas” (SAAs) or “central accumulation areas” (CAAs) at a generator site, it is being “accumulated”, not “stored” (assuming the accumulation is consistent with state or federal SAA/CAA regulations). “Storage” is when waste is kept on site in excess of applicable SAA/CAA time limits and requires a permit (like at a TSD facility). So what we are talking about in the generator world are hazardous waste “accumulation” labels, not hazardous waste “storage” labels.

EPA Labeling Requirements
At the federal level, RCRA rules for container labeling (as well as labeling of tanks and containment buildings) were recently revised as part of the “Generator Improvement Rule” (GIR) process. The updated regulations are found in title 40 of the Code of Federal Regulations, Part 262 (40 CFR § 262). Specific GIR provisions are still being adopted by individual states, and some states may have additional requirements, but under RCRA, hazardous waste in containers in CAAs must be labeled with the following:

  • The words “Hazardous Waste”
  • The date accumulation began (the date the waste exceeded SAA quantity limits or was moved into a CAA)
  • An indication of the hazards of the waste

As long as containers are compatible with the materials they contain, containers holding incompatible materials are segregated, leaks and spills are addressed promptly and other large or small quantity generator responsibilities are met, then waste containers in SAAs only need to be labeled with the words “Hazardous Waste” and an indication of the hazards, since RCRA regulations do not establish time limits for waste in SAAs. See 40 CFR § 262.15 for more information.

The GIR updates (if adopted by states) allow generators to maintain a “lower” generator status for a single planned or unplanned waste generation event that would otherwise push them into a higher generator status. Waste generated from these “episodic” events should be labeled with the words “Episodic Hazardous Waste” as well as an indication of hazards and the date the episodic event began.

These requirements apply whether you are a whether you are a large-quantity generator (LQG) or Small Quantity Generator (SQG). See 40 CFR §262.16 or 40 CFR §262.17 for more information on requirements for SQGs and LQGs.

What does “indication of the hazards” mean?
RCRA regulations allow generators to use any of the following methods to indicate the hazards of the waste in the containers:

  • Words indicating the applicable U.S. EPA hazardous waste characteristic(s): ignitable, corrosive, reactive or toxic
  • DOT hazard communication pictograms indicating applicable DOT hazard class/division
  • A hazard statement or pictogram consistent with the OSHA Hazard Communication Standard (29 CFR § 1910.1200)
  • A chemical hazard label consistent with the National Fire Protection Association Standard 704 (NFPA 704 – Standard System for the Identification of the Hazards of Materials for Emergency Response)

Examples of acceptable hazard indicators for a flammable liquid waste can be seen in the image accompanying this piece.

That’s it for federal hazardous waste accumulation labels, but things are different in California, and there are other requirements when shipping waste off-site. Part 2 of our series will review hazardous waste accumulation labeling requirements for California generators and Part 3 will conclude the series with a discussion of hazardous waste shipping labels for off-site transport and disposal.

If you have any questions about DOT shipping, container labeling or any other hazardous waste issues, ACTenviro is available to help! Contact us at [email protected].

– James Kapin, MPH, CIH, CSP
Director of EM Services

As we learned in Part 1 of this 3-part series, RCRA rules for container labeling (as well as labeling of tanks and containment buildings) were recently revised as part of the “Generator Improvement Rule” (GIR) process and updated regulations can be found in title 40 of the Code of Federal Regulations, Part 262 (40 CFR § 262).

Under RCRA, individual states are also allowed to establish their own regulations that are more stringent than RCRA requirements, including waste container labeling requirements. Some state-specific variations to RCRA container labeling requirements are relatively minor. For example, the State of Washington requires that wording on waste container labels be “clearly visible” from 25 feet away or have lettering size at least ½” in height. In California, the differences in labeling requirements are a little more significant, mainly due to other differences in California hazardous waste regulations.

Similar to the RCRA requirements, California regulations (22 CCR § 66262.34(f)) require the following on each waste container:

  • The words “Hazardous Waste”
  • The accumulation start date (the date the first waste was placed in the container)
  • The hazardous properties of the waste (i.e., flammable, corrosive, reactive, toxic)
  • Composition and physical state of the waste
  • Name and address of the person producing the waste

The accumulation start date for California generators (SQGs and LQGs – see Part 1 for definitions) is the date that waste was first placed in the container. This date must be indicated on all hazardous waste container labels, even SAA labels, because California regulations (22 CCR § 66262(e)) limit accumulation time to a maximum of year, even if the waste is kept in an SAA.

  • As an alternative, some local California regulators allow generators to indicate “Emptied Weekly” or “Emptied Daily” for accumulation start date on SAA containers that are consolidated into larger containers, as long as the consolidation containers are labeled appropriately.

In addition to the accumulation start date, waste containers should also be marked with the date they exceeded SAA quantity limits and/or were moved to CAA to demonstrate compliance with the CAA time limit of 90 or 180 days, depending on generator status.

That’s it for California hazardous waste accumulation area labeling. Part 1 of this 3-part series addressed RCRA requirements for waste accumulation and Part 3 will conclude the series with a discussion of labeling requirements when shipping your waste off site for disposal.

If you have any questions about California regulations, container labeling or any other hazardous waste issues, ACTenviro is available to help! Contact us at [email protected].

– James Kapin, MPH, CIH, CSP
Director of EM Services

The US Chemical Safety and Hazard Investigation Board (CSB) adopted new regulations (40 CFR part 1604) for reporting releases of hazardous materials, effective March 23, 2020. Under the new regulation, businesses must report any spills or releases that result in a death, serious injury, or substantial property damage to CSB within 8 hours. For those who have been following this issue, this is a change from the proposed regulation, which required reporting within 4 hours. Where applicable, multiple owners or operators may provide a consolidated report to CSB, as long as all reporting requirements are met. This initial report can be revised as needed for a 30 day period following the release. See https://www.federalregister.gov/documents/2020/02/21/2020-02418/accidental-release-reporting for more information.

What needs to be reported
The report should contain the following:

  1. The name of, and contact information for, the owner/operator;
  2. The name of, and contact information for, the person making the report;
  3. The location information and facility identifier;
  4. The approximate time of the accidental release;
  5. A brief description of the accidental release;
  6. An indication whether one or more of the following has occurred:
    1. fire;
    2. explosion;
    3. death;
    4. (serious injury; or
    5. property damage.
  7. The name of the material(s) involved in the accidental release, the Chemical Abstract Service (CAS) number(s), or other appropriate identifiers;
  8. If known, the amount of the release;
  9. If known, the number of fatalities;
  10. If known, the number of serious injuries;
  11. Estimated property damage at or outside the stationary source;
  12. Whether the accidental release has resulted in an evacuation order impacting members of the general public and others, and, if known:
    1. (1) the number of persons evacuated;
    2. (2) approximate radius of the evacuation zone;
    3. (3) the type of person subject to the evacuation order (i.e., employees, members of the general public, or both).

If a report has already been made to the National Response Center (NRC) due to 40 CFR 302.6 reporting requirements and additional report does not need to be made to the CSB. Instead the CSB reporting requirement may be satisfied by submitting the NRC identification number to the CSB within 30 minutes of submitting a report to the NRC.

Why are these requirements needed
The CSB was required to create accidental release reporting requirements as part of Clean Air Act A(CAA) amendments in 1990. Initial rulemaking was started, but never completed and instead, CSB has relied on existing EPA release reporting requirements for notification. The current rulemaking originates from a recent lawsuit from environmental groups that led to a court order for the CSB to create a new release reporting regulation by 2020.

Note that the CSB reporting requirements apply to spills or releases that result in a death, serious injury, or substantial property damage and state or local regulators may have lower thresholds for release reporting or require notification for spills that do not need to be reported to the CSB or NRC.

If you have any questions about this, or any other environmental or workplace safety requirements, please contact us at [email protected].

– James Kapin, MPH, CIH, CSP
Director of EM Services

Part 1 of this series covered federal (RCRA) requirements for hazardous waste accumulation labels, and Part 2 covered California accumulation label requirements, but what about labeling requirements for off-site shipment for disposal?

In order to transport a hazardous waste container for disposal, the container must meet U.S. Department of Transportation (DOT) requirements for hazardous materials shipments in addition to applicable state/federal hazardous waste labeling requirements, since hazardous waste is, by definition, a hazardous material.

RCRA regulations (40 CFR § 262.32) require the following information on containers prepared for off-site transportation:

  • The words “Hazardous Waste”
  • The statement “Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
  • Generator’s name, address and EPA identification number
  • Manifest Tracking Number
  • EPA Hazardous Waste Codes

DOT regulations (49 CFR § 172.301) also require the following information for non-bulk containers (< 119 gallons):

  • The complete DOT shipping description including UN identification number, “Proper Shipping Name” (PSN), Hazard Class/Division (including subsidiary hazards), Packing Group and “Reportable Quantity” (RQ), if applicable
  • The name and address of the designated recipient
  • DOT hazard label(s) for the material

There are specific size requirements for the UN/NA numbers:

  • The UN/NA number on packages with a maximum capacity of 5 L (1.3 gal.) or 5 kg (11 lbs.) or less “must be marked in a size appropriate for the size for the package”
  • Packages with a maximum capacity of 30 L (8 gal.) or less, or 40 kg (66 lbs.) max. gross weight, or cylinders with a capacity of 60 L (16 gal.) or less must be marked with characters at least 6 mm (0.24 in.) high
  • Larger packages must be marked in characters at least 12 mm (0.47 in.) high

That’s it for hazardous waste shipping labels. We already covered federal and state accumulation container labels in Parts 1 and 2 of this 3-part series. Remember, though, that this is just a brief summary of DOT hazardous materials shipping issues – there are some other DOT issues for bulk shipments (> 119 gallons), some specific requirements for different hazard classes and a variety of exemptions and exceptions.

49 CFR Part 172 has complete information on DOT labeling requirements, but if you have any other questions about off-site shipping, transportation or any other hazardous waste issues, ACTenviro is available to help! Contact us at [email protected].

– James Kapin, MPH, CIH, CSP
Director of EM Services

We all know what happens when we destroy our environment. So, taking care of it is everyone’s responsibility. Naturally, the U.S. government enacted laws to ensure maximum environmental protection and the CERCLA Act, commonly known as “Superfund, is one such example. To put simply, the CERCLA Act regulates the control and management of hazardous and toxic wastes detected within abandoned or “orphaned” facilities that can affect not just the environment but also the health of the public. 

Under CERCLA, approximately $1.6 billion was collected from a special tax on the petroleum and chemical industries that lasted until 1995.  This money, along with revenue from companies that created the problem is used for clean-up and waste management at abandoned or uncontrolled hazardous waste sites.

What is CERCLA?

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) is also known as the Superfund act. CERCLA was passed by the U.S. Congress on December 11, 1980. CERCLA laid out the requirements for closing and abandoning hazardous sites and its related prohibitions and established liability for those who created the waste, referred to as “potentially responsible parties” or PRPs.  After identifying the proper hazardous waste removal plan for a specific, abandoned area, called Superfund sites, the next step is to try to ensure that the PRPs will be held accountable. 

As mentioned in the introductory section of this article, CERCLA also imposed a tax on the chemical and petroleum industry.  The funds from this tax (which was in effect from 1980 to 19995) were placed in a trust fund to be used for cleaning up activities in cases where no person or party can be identified as responsible for the hazardous waste.

CERCLA is under the administration of the Environmental Protection Agency (EPA). The amounts that CERCLA or Superfund accumulates is for a specific use. Obviously, this means that the government is not allowed to spend it on anything else. 

CERCLA is also known as: 

Comprehensive Environmental Response
Compensation Liability Act
Compensation And Liability Act 

What caused CERCLA?

The Comprehensive Environmental Response, Compensation, and Liability Act was ratified in 1980 but the reason behind CERCLA started in the ’70s with several unacceptable, tragic incidents and unlawful practices of mismanaged toxic, hazardous waste disposal. Here are some notable examples:

A grave accident at a chemical treatment facility  happened in 1977 that left six people dead and thirty-five people hospitalized in Bridgeport, New Jersey. The incident started from a spark of a welder’s torch which came in contact with some chemicals in the facility. This resulted in a big fire in the chemical-waste treatment facility. The event raised an alarming concern from the public and got the government’s attention because it covered the city of Bridgeport in huge black smoke.

Another terrible incident concerning hazardous waste happened in the Love Canal neighborhood near Niagara Falls, New York that prompted then-President Jimmy Carter to declare a State of Emergency in 1978. The residents started to develop rashes, pregnant women experienced miscarriages, and babies were born with birth defects. The case was traced from a former chemical facility which dumped their wastes in the canal near the Niagara River. 

Due to these unfortunate incidents, the House and Senate committees met in 1979. They discussed the risk of these hazardous waste dumps and filed bills to create a “superfund” to deal with these kinds of disasters. 

The same year that CERCLA law was passed, another catastrophe happened in a waste storage facility in Elizabeth, New Jersey. A huge fire broke out and sent up into the atmosphere thick black smoke and ash. The public feared chemical contamination since the fire lasted for ten hours and covered a 15-mile area. 

These tragedies pushed President Carter to sign the CERCLA Act.

What’s the difference between the RCRA and CERCLA?

Before CERCLA came into fruition, the Resource Conservation and Recovery Act of 1976 (RCRA) was enacted first to create an office in the government that has control over hazardous waste, from its generation to disposal as there was a growing concern by the public regarding “midnight dumping” of hazardous wastes.

RCRA (1976)

  • focuses on specific approaches to both solid and hazardous waste management within facilities that are open and currently in use.
  • RCRA facilities are then known to currently use, manage and dispose of hazardous waste. They are "open for business" with known operators/owners.
  • RCRA regulates hazardous waste transport.

CERCLA (1980)

Focuses on specific approaches to both solid and hazardous waste management within facilities, sites and areas that are abandoned yet identified to contain environmentally hazardous substances.

CERCLA Response Actions

There are two kinds of response actions that the CERCLA law allows: short-term removals and long-term remedial response actions. These responses are administered by the EPA.

The short-term removals are taken when the threat of a toxic waste accident requires an immediate response. On the other hand, long-term remedial response actions are taken when the threat of a toxic waste release is grave but not life-threatening. These actions are only allowed at locations included in the National Priorities List (NPL) by the EPA. 

CERCLA later revised the National Contingency Plan (NCP) which handles the NPL. The NCP created the provisions and procedures for the needed responses to the threat of toxic waste releases, or actual releases. 

Aside from the authority to decide over the kind of response actions to take, the EPA’s responsibility also covers cleaning up sites where the identification of parties responsible is not possible or when the parties just failed to act. The EPA recovers the cost of the cleanup from financially able individuals or companies who are involved when the response action is completed.

The cleanup enforcement program of the EPA aims to provide protection to human health and the environment by imposing regulations on parties responsible for the toxic waste release. The EPA either orders for cleanup or reimbursement for the cleanup that they will conduct to avoid public exposure to toxic waste.

Another important goal of the EPA for their cleanup enforcement program is the reusability of the previously contaminated facility. This is done by encouraging cleanup of the facility in accordance with the Superfund liability concerns. The facility owner liability protections are also implemented. 

When facilities under the Resource Conservation and Recovery Act (RCRA) do not properly manage their toxic waste, the EPA and the states oblige the individuals responsible to do the cleanup under CERCLA. 

CERCLA Amendments

The Superfund Amendments and Reauthorization Act (SARA) was an amendment made to reauthorize CERCLA on October 17, 1986. Several changes and additions to the program were made as follows:

  • The importance is given to permanent solutions and new technologies in handling hazardous waste locations.
  • Obliging Superfund to take actions in considering the environmental laws and regulations by other States.
  • Increase the trust fund to $8.5 billion.
  • Encourage additional citizen participation on how facilities should be cleaned up.
  • Additional focus on the dangers that hazardous waste sites have on human health.
  • Additional involvement of the State in all aspects of the Superfund program.
  • Deliver new enforcement authorities and tools.

Most significantly though Title III of SARA authorized the Emergency Planning and Community Right-to-Know Act (EPCRA).   EPCRA was a direct response to a catastrophic release chemical disaster in Bhopal India, where a release of methyl isocyanate killed or injured thousands of people.

EPCRA requires states and local governments to establish local chemical emergency preparedness programs for their communities and requires businesses to report hazardous materials storage as well as emergency releases.  EPCRA also requires EPA to establish and maintain a publicly available toxic chemical release inventory (TRI) of facility-specific chemical release and waste management information.


CERCLA is one of the key pieces of environmental legislation in the US.  CERCLA created a mechanism to identify abandoned hazardous waste sites and ensure they are cleaned up, in order to protect the public and the environment.  The costs for clean-up are covered from the superfund trust (originally funded by a tax on the petroleum and chemical industries), as well as revenue from potentially responsible parties.  In addition, Title III of SARA requires states to establish emergency preparedness programs and requires businesses to report the hazardous materials they use, as well releases of those hazardous materials.

Disinfectants and cleaning agents were among the products which quickly sold-out when the World Health Organization released the official announcement that we are amidst a global pandemic. However, worryingly, the Centers for Disease Control and Prevention (CDC) have noted an increase in calls to poison centers due to the misuse of these chemicals since the beginning of the pandemic.In this article, we will discuss which disinfectants and cleaning agents have been found to be effective against the Novel Coronavirus, and of course, how to use these properly.

Does Lysol Disinfectant Spray Work Against COVID-19?

In early July, the US Environmental Protection Agency (EPA) released the results of its first tests, which showed that Lysol Disinfectant Spray and Lysol Disinfectant Max Cover Mist met their criteria for use against the virus which causes COVID-19. It has since expanded the list to include over 400 other products and brands.

So, yes,  the quick answer is that Lysol Disinfectant Spray does work against the virus which causes COVID-19.

The findings from a peer-reviewed study published in the American Journal of Infection Control indicate that Lysol and other similar household disinfectant products have a greater than 99.9% efficacy against the Novel Coronavirus, or designated by the International Committee on Taxonomy of Viruses as SARS-CoV-2.

EPA Lysol Certification

The EPA tests different disinfecting and cleaning products that are available in the market. Those which qualify based on the following criteria are then included in List N

  1. Shown to be effective against SARS-CoV-2, the virus which causes COVID-19;
  2. Shown to be effective against viruses that are more difficult to kill than SARS-CoV-2, the virus which causes COVID-19; or
  3. Shown to be effective against another type of human Coronavirus similar to SARS-CoV-2, the virus which causes COVID-19.

It should be noted that the EPA insists that the products included in List N only be used according to their label directions. To date, Lysol has earned EPA certifications for 17 of its products.

How to Use Lysol vs. Coronavirus?

Each Lysol product will have its own formulation type, and minimum recommended contact time in order to be effective against the Novel Coronavirus. Moreover, each product will also be effective only for specific surface types.

The following products are not to be used on the skin, ingested, inhaled, injected, or used to clean food.

Product name Formulation type Minimum contact time in minutes Surface type
1. Lysol Disinfecting Wipes (All Scents) Wipe 2 Hard Nonporous; Rinsing required if surface being disinfected is to come in contact with food
2. Lysol Disinfectant Max Cover Mist Ready-to-use 2 Hard Nonporous
3. Lysol Disinfectant Spray Ready-to-use 2 Hard Nonporous; Rinsing required if the surface being disinfected is to come in contact with food
4. Lysol Brand Foaming Disinfectant Basin Tub & Tile Cleaner II Ready-to-use 10 Hard Nonporous
5. Lysol Brand Toilet Bowl Cleaner with Bleach Ready-to-use 5 Hard Nonporous
6. Lysol Laundry Sanitizer Dilutable 5 Porous; laundry presoak only
7. Lysol Bathroom Cleaner Ready-to-use 5 Hard Nonporous; Rinsing required if the surface being disinfected is to come in contact with food
8. Lysol Neutra Air 2 in 1 Ready-to-use .5 (30 seconds) Hard Nonporous; Rinsing required if the surface being disinfected is to come in contact with food
9. Lysol Brand All Purpose Cleaner Ready-to-use 2 Hard Nonporous
10. Lysol Brand Deodorizing Disinfectant Dilutable 10 Hard Nonporous
11. Lysol Kitchen Pro Antibacterial Cleaner Ready-to-use 2 Hard Nonporous; Rinsing required if the surface being disinfected is to come in contact with food
12. Lysol Brand Cling & Fresh Toilet Bowl Cleaner Ready-to-use .5 (30 seconds) Hard Nonporous
13. Lysol Brand Bleach Mold And Mildew Remover Ready-to-use .5 (30 seconds) Hard Nonporous
14. Lysol Brand Heavy Duty Cleaner Disinfectant Concentrate Dilutable 5 Hard Nonporous; Rinsing required if the surface being disinfected is to come in contact with food
15. Lysol Brand Power Plus Toilet Bowl Cleaner Read-to-use 10 Hard Nonporous
16. Lysol Brand Lime & Rust Toilet Bowl Cleaner Ready-to-use 10 Hard Nonporous
17. Lysol Brand Clean & Fresh Multi-surface Cleaner Dilutable 3 Hard Nonporous; Rinsing required if the surface being disinfected is to come in contact with food

Alternatives Disinfectants Against COVID-19

If brand specific products like Lysol are unavailable, the CDC recommends the use of other common household chemicals like bleach and alcohol. Common household bleach with concentrations of 5% - 6% or 1000ppm sodium hypochlorite can be used on appropriate surfaces, after proper dilution.

Contact time should be at least 1 minute, and ensure proper ventilation during and after use. Avoid inhaling chemical fumes because these are harmful to your health.

To properly dilute bleach, use only room temperature water, using a ratio of 5 tablespoons of bleach per gallon of water. Alcohol-based wipes, sanitizers, or sprays with at least 70% alcohol may also be used to clean surfaces and skin. For hand hygiene, washing with soap and water for at least 20 seconds should be enough for most situations.

Government regulations distinguish between products that claim to disinfect, sanitize, and clean surfaces. 

Disinfecting kills bacteria and viruses on surfaces, but does not necessarily remove their remains. Cleaning removes bacteria, viruses, dirt, and other impurities from surfaces, but does not kill bacteria and viruses. Both should be used in conjunction with each other, generally, first by cleaning and then, disinfecting surfaces.

The Food and Drug Administration (FDA) regulates antibacterial soaps, hand sanitizers, antiseptic washes, and similar products that may be used on the skin.

The EPA regulates surface disinfectant products with more rigorous testing requirements compared to surface sanitizing products. To date, there are no sanitizer-only products that have been shown to work against viruses. There are, however, products that are registered with the EPA as both sanitizers and disinfectants after complying with the testing requirements for both.

The EPA also tests cleaning products if these products make claims on their labeling regarding effectiveness against bacteria or viruses.

Moreover, the CDC reminds the public to always read the instructions on the proper usage of cleaning and disinfectant products, to wear protective gear when using these products, and not to mix these products together.

Lysol themselves have stated in their website that none of their disinfectants are to be ingested or administered to any part of the human body. Their products are meant to be used as directed.

Another popular disinfectant brand that is effective in eliminating the Coronavirus is Clorox. Here are some specific Clorox products that are also as effective as Lysol:

  • Clorox Disinfecting Wipes

    Pre-soaked and EPA-approved, these disinfectant wipes from Clorox need only 4 minutes’ contact time to effectively neutralize the Novel Coronavirus.

  • Clorox Bleach

    A staple in almost any home or business, bleach is the key ingredient to any DIY disinfectant. Always use as prescribed by label instructions.

  • Clorox Clean Up Cleaner & Bleach Spray

    With fumes as strong as the chemical that makes up this powerful disinfectant, it effectively works in as short as 5 minutes.

  • Clorox Multi-Surface Cleaner & Bleach Spray

    The strong formulation in this particular product is strong enough to kill the Coronavirus in 1 minute. When not used properly, it may potentially cause damage to fabrics. Always use as prescribed by label instructions.


How do I dispose of empty Lysol spray cans?
Lysol spray cans are aerosol cans. Once these are used up and emptied, these must be disposed of properly as these can contain harmful chemicals. The EPA identifies all aerosol cans as hazardous waste and classified them as “universal wastes”.

Facilities such as hospitals, schools, restaurants, and other large establishments that require the regular use or products packaged in aerosol cans may have a different set of specifications and rules for aerosol can disposal. Refer to your local and state regulations for more information.

For household aerosol cans however, it is best to take them to your nearest recycling center. Because aerosol cans are made of high-value metals, these are recommended for recycling.

However, you must ensure that the spray can must be completely empty. The recycling may not accept it for recycling if it still has some contents in it. You must also not puncture the aerosol can as this may possibly explode. The plastic caps on aerosol cans must be removed, as well, before you take in for recycling.

Verify with your local hazardous waste treatment facility for further instructions before sending in aerosol cans and other metal waste products.
Is Lysol harmful to children?
In general, when ingested or inhaled in copious amounts, the toxic chemicals found in Lysol and other disinfectant products are harmful and dangerous to children. If you are using disinfectants to wipe down specific areas in your home or facility that is frequented for children, it’s best to do with no children within the vicinity.

Parents and caregivers are advised to leave the room unoccupied for 30 minutes to a few hours (depending on the degree of cleaning) before children can come into the room.


Whether in the face of a pandemic or not, it is always good practice to clean, disinfect, and sanitize surfaces we regularly come in contact with. Brand-specific products with EPA or FDA certifications provide the guarantee that if used properly, they are effective against viruses like the one which causes COVID-19.

If not available, common household chemicals like bleach or alcohol may be used. In either case, these products must be used only as directed in order to ensure effectiveness, and safety.

Not all waste are made equal. That is, some are easy to dispose of, while some require special handling and are covered by stricter laws and specific regulations. In this article, we will put our focus on hazardous waste and how to dispose of them properly.

What are hazardous wastes?

As a rule of thumb, hazardous wastes are those which are one, or a combination of the following:

  • Corrosive
  • Ignitable/flammable
  • Reactive/explosive
  • Toxic/poisonous

Due to their nature, they can put both people, properties, and the environment at risk. This is why they are treated differently from other wastes produced by households and some businesses, otherwise referred to as waste generators.

Corrosive wastes are either acidic or alkaline and this property allows them to dissolve materials they come in contact with. Human skin is especially vulnerable, while some corrosive wastes are even quick to damage certain metals. A substance is corrosive if it has a pH value of less than or equal to 2, or more than or equal to 12.5.

Ignitable wastes are characterized by their being able to easily be set on fire and sustain the combustion. In liquids, this is if it has a flash point of below 60 Celsius (140 Fahrenheit), while there are also solids and gases that ignite given specific circumstances – open flames, sparks, or even ambient temperature.

Reactive wastes are unstable under normal conditions, and may explode if it comes in contact with water, certain chemicals, or when it reaches a specific temperature. These can also emit toxic gases.

Toxic wastes are harmful and poisonous when inhaled, swallowed, or absorbed via the skin or mucous membranes. These can contaminate the air, soil, or groundwater, negatively affecting the air we breathe, as well as the food and water we eat and drink.

How are hazardous wastes disposed?

Regulations dictate that waste generators are expected to segregate hazardous waste from non-hazardous wastes. Hazardous wastes are then retrieved by specially designated hazardous waste collectors and brought to authorized facilities. Hazardous waste transportation is covered both by EPA regulations and US Department of Transportation regulations.

During transportation, hazardous wastes need to be deposited in portable containers, the most common of which is the 55-gallon drum. Small amounts can be contained in test tubes, buckets, or sealable and specially marked garbage bags. Some chemicals can be transported using their original plastic or glass containers, while larger volumes of hazardous waste are contained and transported through tanker trucks and railroad cars.

Once brought to the appropriate facilities, many hazardous wastes can be safely recycled. Those that cannot, are treated or made less hazardous. When treatment is effective, the resulting wastes can then be disposed of with other non-hazardous wastes in landfills, or incinerated.

However, there are some hazardous wastes that cannot be treated fully or effectively. Instead, these are sealed in specialized containers and buried. Other methods are available.  Although the risk of leaks and spills remain, these are mitigated with proper monitoring and other safety protocols.

In order to facilitate the proper recycling, storage, or disposal of hazardous wastes, the US Environmental Protection Agency (EPA) develops and continues to update relevant regulations. These regulations are what governs and certifies Treatment Storage and Disposal Facilities (TSDFs).

Treatment Storage and Disposal Facilities

TSDFs provide one, or combination of the following services:

  • Treatment
  • Storage
  • Disposal

Treatment is the process of changing the character or composition of hazardous wastes. This is through the use of various means, including incineration or oxidation. Some treatment processes allow further recycling where waste can be recovered and reused. Other treatment processes have the goal of significantly reducing the weight and volume of hazardous waste as in the case of incineration, which reduces tons of waste into several hundred pounds of ash.

Storage is generally understood to be the temporary holding of hazardous wastes until they are treated or disposed of. This is done through containment in specialized tanks, containment buildings, drip pads, surface impoundments, or waste piles.

Disposal is the process of permanently and safely containing hazardous wastes. This is achieved mainly through the use of sanitary landfills, which under existing regulations, must include mechanisms that are designed to protect surface and groundwater contamination.

Tanks are stationary containers constructed of steel, plastic, fiberglass, or concrete. Containment buildings are completely sealed, self-supporting structures (walled, roofed, and floored). Drip pads are engineered structures with a curbed, free-draining base designed to allow the drippage and collection of chemicals, contaminated rain and surface water towards a separate holding tank.

Surface impoundments can either be man-made excavations, diked areas, or natural topographic depressions which accumulate liquid hazardous waste. They are required to have a double liner system, leachate collection and removal systems, and leak detection systems.

Landfills are similar to surface impoundments but are designed for non-liquid hazardous wastes. These are also required to have a double liner system; double leachate collection and removal systems; leak detection systems; run on, run off, and wind dispersal prevention controls; and a final cover.

Waste piles operate in the same way as surface impoundments and landfills, but are for temporary storage or treatment only. They also require the same construction design requirements and safety assurance systems.

There are also land treatment units which employ naturally occurring soil microbes and sunlight to degrade, transform, or render ineffective hazardous components. Constant monitoring ensures that hazardous component levels do not exceed a certain threshold based on background levels.

Hazardous Waste Disposal Regulations

The Resource Conservation and Recovery Act (RCRA) of 1976 is the law which set the general framework for the proper handling of hazardous wastes. Inclusion and exclusion criteria, as well as specific regulations continue to change at the federal and state levels.

The following links should provide up to date information regarding the general framework and how each are to be handled:

Is the material categorized as a solid waste?
Is the material categorized as a hazardous waste?
Is the material delisted as a hazardous waste?
Is the hazardous waste in question recyclable?

Moreover, subject to its mandate, the EPA has created different categories, standards, inclusion and exclusion criteria, and exemptions for different classes of wastes:

Is the material categorized as Academic Laboratory Wastes?
Is the material categorized under Cathode Ray Tubes (CRTs)?
Is the material categorized as Household Hazardous Wastes?
Is the material categorized as Mixed Radiological Wastes?
Is the material categorized as Pharmaceutical Hazardous Wastes?
Is the material categorized as Solvent-Contaminated Wipes?
Is the material categorized as Universal Waste?
Is the material categorized as Used Oil?

Further, state regulatory requirements may or may not be more stringent compared to the federal regulatory requirements. The following provides links to state specific information on hazardous material disposal:

List of US State Environmental Agencies

COVID-19 Hazardous Waste Management

In the time of a global pandemic, stringent compliance of hazardous material disposal is more important than ever. One simple misstep in disposing of hazardous wastes during these uncertain times may possibly lead to being infected with COVID-19.

For this reason, both the CDC and the OSHA have released specific guidelines in regards to the management and disposal of any hazardous wastes produced as a result of COVID-19.

All Regulated Medical Waste (RMW) facilities are equipped and able to properly handle any RMW wastes related to COVID-19. Further, all other hazardous waste including pharmaceutical waste and household hazardous waste known to come in contact with any COVID-19 patient are to be routed to disposal facilities with the proper permits.

If you have any concerns in regards to COVID-19 hazardous waste disposal, you can seek proper advice from your local state agencies.

Common Hazardous Waste Disposal Misconceptions

In order to avoid inconveniencing waste generators, waste transporters, and TSDFs, the EPA clarify the following regarding hazardous material disposal:

  • Propane tanks should be returned to the place of purchase, especially those larger than 20 lbs. Smaller tanks may be recycled at authorized facilities for a fee.
  • Used paint is not accepted at recycling centers, these should be brought to Household Hazardous Waste Events which are held at regular schedules in your area.
  • Used/defective electronic equipment, including light bulbs, are also not accepted at many recycling centers. Inquiries should be made beforehand.
  • Local government units at the county level should be contacted for specific information regarding pertinent local hazardous waste programs for both businesses and households. Schedules, volume/weight limits, restrictions, and fees are subject to change.


Hazardous waste management regulations continue to evolve, and rightfully so. This is because industries, businesses, and households continue to consume a wide array of products which also produce a wide variety of wastes.

It is therefore sensible to keep up to date with relevant regulations issued by federal, state, and local authorities. Certified TSDFs are also able to provide helpful information for waste generators who only produce a relatively small volume of waste within a given period of time.

Disposing of hazardous wastes in violation of regulations will incur stiff sanctions and costly penalties. These can easily be avoided by doing our part with regards to proper hazardous waste disposal which at the same time, ensures that the health of individuals, properties, and the environment are kept safe.

Fluorescent tubes are more energy-efficient and cost-effective compared to incandescent bulbs and are used in many homes and businesses. They generally last anywhere between 15,000 to 20,000 hours.

Fluorescent lights must be disposed of or recycled properly because they contain mercury. Unlike chemicals that are visible or that emit a strong odor, when mercury is spilled, it forms vapors that are invisible, almost undetectable (except with the use of specialized equipment) and completely odorless. Exposure to mercury, even in small amounts, can cause serious health problems.

Disposal And Recycling Of Fluorescent Lamps & Tubes

The California Department of Resources Recycling and Recovery (CalRecycle) provides the following guidelines for fluorescent tube disposal:

  • Do not break fluorescent tubes
  • Package spent fluorescent tubes in their original box or another protective container
  • Store them away from rain and water so that if in case they break, waterway contamination is avoided
  • Bring the properly packaged fluorescent tubes to a household hazardous waste collection or event
  • Businesses should contact accredited waste handlers or a local recycling facility

These guidelines apply to fluorescent tubes, including low mercury tubes, compact fluorescents, including low mercury lamps as well as:

  • Metal halide lamps, such as floodlights for large indoor and outdoor areas and gymnasiums.
  • Sodium lamps, such as those sometimes used as security lighting and outdoor floodlights.
  • Mercury vapor lamps, such as those sometimes used for street lighting.

In case of accidental breakage:

  • Open windows and doors to ventilate the area and disperse any toxic vapor. Promptly switch off forced-air heating or cooling systems, and do not switch them on for at least 4 hours.
  • Instead, evacuate all people and pets to avoid exposure and the spreading of the contamination when mercury sticks to clothing, shoes, arms, legs, and other body parts. This lowers the risk of transferring toxic materials to other locations. Use disposable latex gloves and a damp disposable paper towel or cardboard to gather and dispose of the glass fragments and trace mercury. Use wide packaging tape or duct tape to pick up smaller glass fragments and powder.
  • Place the disposable latex gloves, damp paper towel, cardboard, packaging or duct tape, and other contaminated materials into a sealable bag or glass jar. Store them outside, away from rain and water until they can be disposed of properly.
  • Do NOT use a standard vacuum cleaner to clean up broken fluorescent tubes. Only specialized vacuum cleaning machines which are specifically designed to handle hazardous waste should be used.

    If a larger number of lamps break such as when they are in a case or pallet awaiting disposal, quickly evacuate and ventilate the area, being careful to keep forced-air heating or cooling systems off until 4 hours after clean-up is completed. Contact the local authorities or accredited waste handlers for proper clean-up and fluorescent tubes disposal.

    The broken fluorescent tubes can be recycled along with those that remain intact.

  • Remember, do NOT use standard vacuum cleaners. There are specially designed vacuum cleaning machines which are rated for handling hazardous wastes.

Where Can You Recycle Fluorescent Tubes?

The U.S. EPA recommends using the Earth911 database to locate the nearest recycling solution to you. You only need to enter your ZIP code and a list of recycling or household hazardous waste collection centers will be provided.Alternatively, you may call 1-800-CLEAN-UP to access the same information.

Disposal of Fluorescent Tubes Regulations

The EPA notes that some states and local jurisdictions may have stricter regulations regarding the disposal of fluorescent tubes and other hazardous wastes, including mandated recycling. Your local waste collection agency should be able to tell you about the particulars of such disposal of fluorescent tubes regulations in your state or locality.

To date, the following jurisdictions have laws that regulate mercury-containing products. These include prohibitions on the discarding of mercury-containing fluorescent tubes into landfills and mandate their recycling:

  • California – Title 22, division 4.5, chapter 11, section 66261.50
  • Maine – Title 38, Chapter 16-B, section 1672
  • Massachusetts – Mercury Management Act, M.G.L. Chapter 21H, Sections 6A-6N
  • Minnesota – Minn. Stat. 115A.932
  • New Hampshire – Section 149-M:4
  • Vermont – Hazardous Waste Management Regulations, Subchapter 9, section 7-907
  • Washington – Mercury Lights Law, Chapter 70.275 RCW and Mercury Lights Rule, Chapter 173-910 WAC.

Mercury and Toxicity

According to the U.S. Environmental Protection Agency (U.S. EPA), fluorescent tubes contain minute amounts of mercury, an average of about four milligrams per glass tubing. This amount can be released into the environment when the glass tubes break and are dangerous because mercury is a known neurotoxin.

In vapor form, it is easily absorbed by the human body through the various mucus membranes and the lungs. It is also a pollutant in bodies of water, which are ingested by fish that are part of the human diet. 

The clinical significance of exposure to smaller amounts of mercury is controversial, but these can accumulate, and the results can be severely damaging. 

After entering the human body through the respiratory or digestive systems, mercury then breaches the blood-brain barrier and targets the brain. It causes a wide array of health issues but is most pronounced in causing cerebral palsy and other neurocognitive damage in unborn children.

Large-scale releases of mercury have also been the cause public health disasters, including in Iraq and in Japan.

In Iraq, mercury poisoning killed hundreds (possibly thousands) of Iraqis in 1971 through consumption of grain treated with a deadly methylmercury fungicide that was never supposed to make its way into human consumption. Other serious symptoms included vision loss, numbness of the skin and may also cause congenital diseases in unborn babies.

In Japan, mercury-containing wastewaters from the Chisso Corporation contaminated Minamata bay from 1932 to 1968.  The mercury accumulated in shellfish and fish which, when eaten by the local population, resulted in mercury poisoning.  This came to be known as “Minamata Disease”.


While light-emitting diode (LED) lighting is becoming more and more cost-effective and energy-effective, fluorescent tubes are still used in many homes, offices and businesses.  

Once they are spent, they should be disposed of or recycled according to the relevant laws and regulations of the locality. Care should be taken that they do not break, and proper clean-up measures should be taken if they do.

Contact the nearest accredited fluorescent tube recycling facility or local government agency for up to date guidance on procedures, rules, and regulations since these can change from time to time. Remember, fluorescent tubes contain toxic mercury, and care should be taken that we do not risk our and the environment’s health.


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