OUTLINE OF MAJOR PROGRAM POINTS

Hazardous Waste Management for Generators

The following outline summarizes the main points of information presented in this videotape or DVD program. The outline can be used to review the program before conducting a classroom session as well as in preparing to lead a class discussion about the program.

"Hazardous Waste Management for Generators" assists facilities in complying with the government requirements for the management and disposal of hazardous waste. This comprehensive program focuses on EPA RCRA regulations.

· There are two government agencies that regulate the generation, transportation and disposal of hazardous waste. These two organizations are the Environmental Protection Agency and the Department of Transportation.

· The federal regulations governing hazardous waste are found in Title 40, starting with part 260 (EPA) and in Title 49, starting with part 100 (Dept of Transportation).

· Both small quantity and large quantity generators must apply for an EPA identification number using EPA form 8700-12.

· The training requirements of 49 CFR 172.704 are mandatory for individuals involved in the shipping of hazardous materials and hazardous waste.

· Table 171.101 in Title 49 is used to determine packaging requirements and other requirements in the shipping of hazardous materials and hazardous waste.

· Federal requirements for large quantity generators of hazardous waste are different from the requirements for small quantity generators. Large quantity generators are those who generate more than 1,000 kilograms of hazardous waste or more than 1 kilogram of acutely hazardous waste in a period of one month.

· Manifesting and labeling of waste prior to shipping is required for both large and small quantity generators.

· The Resource Conservation and Recovery Act (pronounced “Rick Ra”) of 1976 as amended, is the nation’s basic law governing the management of hazardous waste. The Environmental Protection Agency administers RCRA and other environmental laws under the Code of Federal Regulation (CFR) Title 40.

· The major objectives of the RCRA laws are to (1) Establish a national hazardous waste policy. (2) Establish liability for generators of hazardous waste. and (3) Proper management of hazardous waste from the “cradle” to the “grave”.

· The various terms related to hazardous wastes are quite precisely defined. For example, a hazardous waste is defined as a solid, liquid or gas or any combination of these, all of which may pose potential harm or damage to humans or the environment.

· For the purposes of the law under RCRA, a solid waste can also include liquids as well as gases. Solid waste and hazardous waste are defined and regulated quite differently.

· Whether or not a waste is considered a hazardous waste and therefore subject to RCRA subtitle C regulations can be determined by using the decision chart provided in the regulations and in this video.

· Some hazardous wastes are defined as hazardous because they are listed by chemical name in 40 CFR 261.10 and have an EPA Hazardous Waste Identification Number. Other wastes are considered hazardous due to the waste being ignitable, corrosive, reactive or toxic. To determine if the waste fits any of these characteristics, the characteristic must be measurable by standard test methods which can be performed by commercial chemical laboratories.

· The RCRA gives standards for classifying waste as ignitable, corrosive, reactive or toxic.

· There are advantages and disadvantages of using the federal listings for identification of hazardous waste. One advantage is that the listings make the hazardous waste identification process easy for industrial handlers. A disadvantage is that there is a lack of flexibility. The listing for a waste stream does not consider the potential variations in waste composition. Thus, the listings can unnecessarily regulate some wastes that do not pose a significant health threat.

· The four hazardous waste lists are known as the “F List”, “K List”, “P List” and the “U List”. Each of these lists is devoted to particular sources of hazardous waste.

· Storage – All waste drums for both regulated and non-regulated waste should be stored, packaged and/or shipped in United Nations certified drums or containers. The three agencies governing the use of drums and containers are the Occupational Safety and Health Administration, the Environmental Protection Agency and the Department of Transportation.

· All containers must be properly labeled and marked.

· Both conditionally exempt small quantity generators and small quantity generators may store up to 55 gallons of hazardous waste in what is known as satellite accumulation areas.

· Once the satellite area accumulates 55 gallons, the waste must be relocated in a centralized hazardous waste accumulation area within 3 days. Large quantity generators are not permitted to have or maintain satellite accumulation areas. Large quantity generators have only 90 days to ship their hazardous waste off-site once it is generated.

· The construction of a hazardous waste accumulation facility must meet certain EPA requirements including, among other things, a sloping floor for containment of drainage, security measures, postings, emergency shower, eye wash and other safety measures.

· Certain types of waste are non-regulated because they are not on the EPA list and do not have the characteristics of hazardous waste as detailed in Title 40. Examples of non-regulated waste include broken glass, oil rags, etc.

· Universal wastes are wastes such as rechargeable batteries, fluorescent lamps, TV and monitor picture tubes, mercury containing thermostats and certain pesticides. Universal wastes can be disposed of more easily than hazardous wastes but individual states may modify the rules, so it is important to with your state for the exact regulations

· Once PCBs are declared hazardous waste, they must be destroyed within one year.

· Biohazardous wastes include a wide variety of wastes generated by medical facilities. This type of waste is normally collected and disposed of by commercial facilities located in large cities. This type of waste is normally reduced in volume and sterilized by special equipment and procedures.

· Training requirements for hazardous waste management, for generators, are outlined in 40 CFR 265.16. Other training requirements, mandated by the Department of transportation, apply to each person who performs functions related to the transportation of hazardous waste.

· The terms “hazmat employee” and “hazmat employer” are defined in 49 CFR 171.8. Each hazmat employee must be initially trained and periodically retrained at least every three years in three areas: general awareness and familiarization, function specific and safety. Detailed records of training must be kept.

· Personnel involved in hazardous waste management must receive OSHA’s HAZWOPER training detailed in 29 CFR 1910.120 parenthesis little (c)