What it Really Means to be RCRA Compliant When Handling Hazardous Waste

If your business handles hazardous waste, then you understand compliance is a subject that needs to be at the top of your priority list. The Resource Conservation and Recovery Act (RCRA) contains the United States’ primary regulations on the removal of solid and hazardous waste. It also grants the Environmental Protection Agency (EPA) the ability to monitor and control hazardous waste from the moment that it is created to the time of ultimate disposal.

Overview of RCRA

The RCRA concerns both non-hazardous and hazardous solid waste requirements. The EPA’s definition of “solid waste” includes solids, liquids, and gases. For the law to apply, these substances need to be discarded by businesses that generate hazardous waste, government agencies, and gas stations with submerged tanks. 

RCRA and Hazardous Waste

The disposal of RCRA hazardous waste is addressed under Subtitle C and it is legislated from “cradle-to-grave.” If states do not already have programs implemented to handle hazardous waste disposal, RCRA grants the EPA authority to directly implement rules concerning “generation, transportation, treatment, storage and disposal.

The full text of RCRA regarding hazardous waste is found in Title 40 of the Code of Federal Regulations (CFR) in sections 260 through 273. The general process for hazardous waste RCRA compliance can be accessed here and is summarized below: 

Six-Step Process for Hazardous Waste RCRA Compliance

Identify

First, consult 40 CFR section 262.11 for the process you must follow to determine if the solid waste you have generated is considered hazardous waste. Hazardous waste is defined in 40 CFR section 261.3.

Count

Second, determine the sum weight of all hazardous waste. Based on the weight of the materials, there are three generator categories: Large Quantity Generators (LQGs), Small Quantity Generators (SQGs), and Very Small Quantity Generators (VSQGs). More details on each of these generator categories can be found here

Notify

If you determine that your business is an LQG or SQG, you must notify the EPA or your state agency, if it runs an independent hazardous waste program. Depending on the state, VSQGs may be required to detail their hazardous waste activities, too.

Manage

Based on your waste generation classification, you must comply with different regulations. Some kinds of waste, like universal or pharmaceutical hazardous waste, have specific requirements. More details on managing hazardous waste by generator size can be found here.

Transport

If you are an LQG or SQG moving hazardous waste off of your site, you need a manifest. These are found on the Hazardous Waste Manifest System.

Recycle, Treat, and Dispose

Depending on your generator classification, you may be able to recycle and treat hazardous waste on-site and without a permit. Consult Title 40 CFR to see if your business can do this. If not, you will be subject to 40 CFR sections 264 and 265, which address the treatment and disposal of hazardous waste.
Clean Management Environmental Group, Inc. will walk you through each step and ensure that you are in compliance with RCRA rules and regulations. Fill out our form or call 800-538-8131.


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