Hazardous Waste Management

Author: Marketing
Date: August 14, 2015

Any trash that contains materials that may pose a risk to human lives and the environment is considered as hazardous waste. The sources of these wastes vary, and they may come in many forms.

In this article, we will give you information on:

  • the proper management of hazardous waste
  • how different waste generators manage hazardous wastes
  • how to transport hazardous wastes
  • how to find solutions regarding hazardous waste management.

We will also touch on the topic of solid waste management, which also relates to the management of hazardous waste.

But first, let’s take a look at how EPA defines and identifies certain substances as hazardous waste.

The Hazardous Waste Identification Process

The EPA has come up with definitions to regulate hazardous waste and processes to recognize hazardous substances. EPA's guidelines have also included criteria for other materials to be controlled under the group of hazardous waste.

The process of identification can be confusing for waste generators due to its complex nature. Hence, EPA has produced a flowchart with a series of questions to make the process less complicated and more comprehensible:

Flowchart for Haz Waste Identification Process from the EPA

First, waste generators need to identify if the waste material is a solid waste.

Once the waste material is acknowledged as solid waste, the second step is to examine if the specified waste is let off from being solid or hazardous waste under regulated definition.

If it is determined that the waste passed the definition of being a solid waste, the third step is for the waste to be investigated by the waste generator is whether the waste is listed or not.

In the fourth step, if the waste is deemed delisted then it is subject to RCRA Subtitle C Regulation.

Managing Common Hazardous Waste Right the Way

Since 1960, the country's solid waste generation has increased. The latest data shows that in 2017, the U.S. produced 267.8 million tons of solid waste compared to 88.1 million in the 60s. The annual increase in solid waste has made its management a top priority for government officials. The authorities are continually finding ways, methods, and strategies to safely and cost-effectively manage these wastes.

The background for the proper management of hazardous waste was prepared under the Resource Conservation and Recovery Act, also known as RCRA. With this act, EPA was able to formulate a program that handles hazardous waste carefully. Such programs have specific actions in each phase relating to the hazardous waste, from its creation, transportation, treatment, storage, and disposal.

Hazardous Waste Generator Summary

Managing hazardous waste is dependent on the category of each generator and the associated regulations.

Below is the summary of requirements each hazardous waste generator is obliged to follow to guarantee that the wastes they produced are handled properly to ultimately safeguard the health of the general population and the environment.

  • Quantity Limits- signifies the quantity of hazardous waste produce. This is also used to categorize the hazardous waste generators and the guidelines they need to follow. The EPA recognizes that no two types of waste generators produce the same quantity of waste, hence they have established 3 waste generator categories based on the amount of waste generated:
  • Very Small Quantity Generators produce less than 100 kilograms of hazardous waste a month, less than 1 kilogram of acutely hazardous waste, and less than 100 kilograms a month of acute spill residue or soil.
  • Small Quantity Generators produce more than 100 kilograms but less than 1,000 kilograms of hazardous waste a month.
  • Large Quantity Generators produce more than 1,000 kilograms a month of hazardous waste, more than 1 kilogram of acutely hazardous waste a month, or more than 100 kilograms a month of acute spill residue or soil.
  • Find out if your facility requires an EPA ID Number. This is a unique identification number for each hazardous waste generator. The EPA ID Number is required for both Small and Large Quantity Generators only. Find further information from the EPA here.
  • On-Site Accumulation Quantity indicates the quantity of hazardous waste a particular waste generator is permitted to stack on-site without needing a document.
  • Very Small Quantity Generators are allowed less than 1,000 kilograms of hazardous waste or less than 1 kilogram of acutely hazardous waste or less than 100 kilograms of acute spill residue or soil.
  • Small Quantity Generators are allowed less than 6,000 kilograms of hazardous waste.
  • Large Quantity Generators have no limit in their allowable amount of on-site accumulated hazardous wastes.
  • Accumulation Time Limits indicate the period each generator is permitted to stack on-site hazardous wastes.
  • Very Small Quantity Generators have no time limit.
  • Small Quantity Generators are allowed less than 180 days or less than 270 days if they are transporting the wastes more than 200 miles.
  • Large Quantity Generators have less than 90 days-limit.
  • Accumulation Requirements indicates the specific technical standards each generator is required to follow.
  • Very Small Quantity Generators have no basic requirements for technical standards.
  • Small Quantity Generators are required the fundamental protocols and technical standards for tank, containers, drip pads, or containment buildings.
  • Large Quantity Generators need total compliance for managing tanks, containers, drip pads, or containment buildings.
  • Personnel Training & Certification ensures that the people running the facilities have the relevant training to handle hazardous wastes properly. The pieces of training are not required for very small quantity generators, while small quantity generators are required for basic training. For large quantity generators, full training is required for its personnel.
  • Contingency Plan and Emergency Procedures ensure that each waste generator has installed procedures to be taken during the unplanned event that may happen in their facilities. This is not required for very small quantity generators, while basic planning is required for small quantity generators. The full contingency plan is required for large quantity generators.
  • Preparedness and Prevention Protocol for when an emergency happens. This is not a requirement for very small quantity generators but a requirement for both small and large quantity generators.
  • Air Emissions ensures that tanks and containers' hazardous air emission is within control. This is required for large quantity generators and not for both very small and small quantity generators.
  • Land Disposal Restrictions implies the standards placed on the lands used by waste generators and the accompanying requirements. This is required for small and large quantity generators only.
  • A manifest is needed when hazardous wastes produced are shipped for tracking purposes. This is also a requirement by the Department of Transportation and EPA. This requirement is for small and large quantity generators only. The EPA outlines their Hazardous Waste Manifest System here.
  • Waste Minimization indicates that the waste generators have taken steps to decrease or eradicate creating hazardous waste. A program in place is required for large quantity generators, while efforts made in good faith is what small quantity generators can accomplish. Very small quantity generators are not required. The EPA outlines the following as waste minimization examples: “equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control”.
  • Pre-Transport Requirements is needed for the accurate packaging and labeling of hazardous waste to be shipped to an RCRA facility. This is required for small and large quantity generators and only required for very small quantity generators if DOT or state asked so.
  • Biennial Report is the report made of off-site shipments of hazardous waste the past calendar year. This is only a requirement for large quantity generators.
  • Exception and Additional Reporting indicates other reports required in the operation of waste facilities. This is only required for small and large quantity generators.
  • Record Keeping indicates the maintenance of records showing waste testing and other needed facility reports. This is required for large quantity generators, while for small quantity generators other reports are required except for the biennial reports. Not a requirement for very small quantity generators.
  • Knowing which facility type ensures that wastes are sent to the correct facility site for proper management. The small and large quantity generators must submit their wastes to an RCRA permitted or interim status facility.
  • Closure ensures that the equipment used by the facility is disposed of and appropriately decontaminated. The very small quantity generators are not required to accomplish this. Simultaneously, small quantity generators are required to take this action for their tanks, drip pads, and containment buildings. And the large quantity generators have a general requirement for the closure of its equipment.

Managing Certain Waste Types

Different waste types require different management techniques. There are also requirements unique to each waste type and every business sector associated with certain waste types. Each state also has its own waste management regulations. Make sure you are well-versed in all regulations and requirements to ensure compliance.

We’ve outlined generally-accepted management practices for most types of waste:

  • Universal Wastes

These are wastes commonly generated by several types of establishments. The four types of universal wastes are:

  • batteries
  • pesticides
  • equipment that contain mercury
  • lamps

Regulating universal wastes can differ from state to state. Other states have implemented full federal regulations of universal wastes while others are implementing federal universal wastes regulations.

To ensure proper universal waste management practices, check your state website for more information.

  • Pharmaceuticals' hazardous wastes and medical waste are wastes generated from locations that provide healthcare services such as hospitals and pharmacies. These types of facilities may be regulated as hazardous waste generators.
  • Hazardous waste generated at academic laboratories is waste coming from research and laboratory facilities of schools and universities. Specific regulations were created by EPA to manage the by-products coming from these waste generators.

Transport of Hazardous Waste

Hazardous wastes produced by several waste generators need to be transported to a location where it will be treated, stored, or disposed of properly. These treatments, storage, or disposal facilities (TSDF) require state approval. Since these wastes may cause harm and damage to human health and environment, different government agencies have given distinct attention when these hazardous wastes are being transported.

"Midnight dumping" was a practice before by some transporters of hazardous wastes. They either spill these wastes intentionally or abandon them in different random places. This practice has dramatically caused damage to the environment and health of the people. That is why the government enacted laws to regulate the transportation process.

One way to curb the practice of “midnight dumping” is the Hazardous Waste Manifest System. This document is furnished by the waste generators containing necessary information relating to the hazards that will be shipped.

The most common means of transporting hazardous waste is through tank trucks. These tank trucks are made of steel or aluminum alloy. It has a capacity of about 34,000 liters. The wastes can also be placed in 200-liter drums. Included in the government regulations are the specifications and standards of these tank trunks used to transport hazardous wastes.

Another means of transporting hazardous wastes is through the railway, but this type of transport system only covers a very small number. There’s almost no hazardous waste transported using air or inland waterway.

Hazardous Waste Management Solutions

To protect the environment and conserve resources, EPA has developed other means to handle hazardous wastes properly. EPA was able to determine that some hazardous waste can be safely and efficiently recycled, while others can be appropriately treated and be disposed of in landfills and incineration facilities.

There are benefits in recycling hazardous wastes; this includes a reduction in the usage of raw materials and a decrease in the volume of wastes that need treatment and disposal.

Under the state's approval, there are Treatment Storage and Disposal Facilities (TDSFs), which manage huge volumes of hazardous wastes and are utilized as temporary safe storage as these wastes are finally treated and disposed of. These facilities are strictly regulated and monitored by different state agencies.

Solid Waste Management

Solid wastes are any materials that have served its purpose to its original owner and are already being thrown away or discarded. Managing solid wastes is difficult in urban areas and is a challenge that is faced by state authorities.

Solid waste management is the process of controlling the production, storage, collection, transport, treatment, and disposal of different types of waste that is incongruence to the goal of protecting human health and the environment. The key areas to manage solid waste effectively are understanding the types of waste produced, resources available, and the environmental conditions of the location.

There are several steps taken in solid waste management; primary collection, transfer points, secondary collection, landfill, and incineration,

Primary collection is done by authorities to ensure that all wastes are entered into waste management facilities, and almost nothing should end up on the streets. Transfer points are waste deposits and storage places before they are shipped to their disposal location. The final disposal site is considered the second collection place, where it can be landfills or incineration facilities.

A part of managing solid wastes is the different methods in disposing of these wastes. Several ways employed in waste disposal include open dumping, compaction and balling, sanitary landfill, composting, and incineration. Some of these methods are not practiced in urban areas, so it is still best to contact your local waste facility to manage your wastes properly.


Managing hazardous waste entails a complex process of identifying the type of waste produced and complying with government regulations surrounding recycling, transporting, treating, storing, and disposing of these wastes properly. However, these are all done to ensure the health and safety of the people and the environment.


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