California Senate Bill 14, or SB 14, is the Hazardous Waste Source Reduction and Management Review Act of 1989. It focuses on pollution prevention by way of hazardous waste source reduction. SB 14 also encourages managing hazardous waste using the following hierarchy of recycling, then treatment, and last of all discharge or disposal where source reduction, the primary method, is not feasible. SB 14 requires qualifying generators to prepare and maintain hazardous waste source reduction plans, evaluate implementation performance, and summary progress reports. Effective source reduction plans might involve cross-functional participation and support across a given company from top management leadership to the daily operations personnel. The following parameters apply:
- Sites are subject to SB14 requirements if they routinelygenerate more than 12,000 kg of hazardous waste, or more than 12 kg of extremely hazardous waste in a given reporting year; RCRA and non-RCRA wastes apply.
- Motor vehicle waste, non-routine waste, universal wastes, medical waste, and some other wastes are not applicable.
SB 14 Plan Consist of Three Parts
- Source Reduction Plan (“Plan”): A review of significant waste streams and waste reduction goals with respect to 2022 totals (checklist alternative for small businesses)
- Hazardous Waste Management Performance Report (“Performance Report”): The waste minimization results with respect to the previous baseline year (EPA Biennial Report alternative for small businesses).
- Summary Progress Report (SPR):A summary of information contained in Plan and Performance report. The DTSC provides the document, DTSC Form 1262.
SB 14 plans are based on designated reporting years (mandated by statute), on a four-year cycle. For the current cycle, the Plan, Performance Report, and SPR are due by September 1, 2023, for the 2022 reporting year. See Table 1 for Plan Cycle.
| Table 1 | ||
| Reporting Year | Completion Date | Baseline Year* |
| 2022 | 09/01/2023 | 2018 |
| 2026 | 09/01/2027 | 2022 |
| 2030 | 09/01/2031 | 2026 |
Qualifying generators first need to identify their reporting year so the correct waste data can be organized and analyzed. Once applicable waste streams and their processes are recognized, potential source reduction measures can be explored. 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; and/or
- administrative steps such as inventory control or incentives that reduce waste generation.
Finally, a forward-looking, numerical goal (i.e., SMART) needs to be set for feasible waste reduction measures and a schedule for implementation should be established (e.g., 10% reduction by 2026). 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 law no longer requires generators to submit documents to the DTSC OPPGT; however, generators must maintain all documents on-site and have them available to DTSC and the Certified Unified Program Agency (CUPA) for review during routine inspections.
Who Needs to File?
Picture source: https://dtsc.ca.gov/sb14/sb14-introduction-and-overview/
This blog highlights some of the main aspects of SB 14 requirements. The deadline is approaching quickly, and your SB 14 may require cross-functional collaboration from engineering, facilities, finance, EHS, and other functions. For assistance or questions, the ACTenviro team if consultants are here to help! Contact us with any inquiries at [email protected], or for existing clients, please reach out to your Account Manager.
References
- Guidance Manual for Complying with the Hazardous Waste Source Reduction Management Review Act of 1989. https://dtsc.ca.gov/wp-content/uploads/sites/31/2017/05/GuidanceManualRevised-2.pdf?emrc=23cb58
- Compliance Checklist for Complying with the Hazardous Waste Source Reduction Management Review Act of 1989. https://dtsc.ca.gov/wp-content/uploads/sites/31/2017/07/ComplianceChecklist10.pdf?emrc=20be8b
- For more information – https://dtsc.ca.gov/sb14/sb14-introduction-and-overview/
