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Does Your Business Produce Hazardous Waste?
Most businesses and households use products that contain hazardous materials. For example, a business that uses any of the following materials probably creates hazardous wastes:
- dyes, paints, thinners, solvents or cleaning fluids
- materials that burn or itch on contact with skin
- materials that dissolve metal, wood, paper or clothing
- pesticides
- products with a warning label such as “flammable,” “caustic,” “danger,” “hazardous” or “poison.”
Hazardous wastes require special handling. They can’t be put in the dumpster, poured down the drain or evaporated into the air. They can’t be taken to the transfer station. Every business must comply with regulations, no matter how little hazardous waste it generates. The amount of waste the business produces or stores determines which regulations apply. Businesses that produce large amounts of hazardous waste must comply with more requirements than small quantity generators (SQGs). SQGs may be eligible to bring their waste to household hazardous waste facilities in Seattle and King County. Businesses that produce larger quantities of hazardous waste need to manage their hazardous waste using other resources
The requirements for managing hazardous waste are spelled out in the Washington dangerous waste regulations (Chapter 173-303 WAC). These regulations address how hazardous waste must be stored, handled, transported and disposed.
Every business must comply with regulations, no matter how little hazardous waste it generates. The amount of waste the business produces or stores determines which regulations apply. Businesses that produce large amounts of hazardous waste must comply with more requirements than businesses that produce small amounts.
Waste quantities
A business is a small quantity generator, or SQG, if it never generates more than 220 pounds (about 27 gallons) of hazardous wastes and/or not more than 2.2 pounds (about one quart) of certain extremely hazardous wastes per calendar month and never accumulates more than 2,200 pounds (about five 55-gallon drums) of hazardous waste, or 2.2 pounds of certain extremely hazardous wastes, on-site at any time. The extremely hazardous wastes are mostly chemicals on the Discarded Chemical Products List in Chapter 173-303 WAC.
A small quantity generator business must take certain steps to manage its hazardous wastes. A business is a regulated generator if it exceeds the limits for a small quantity generator. Regulated generators fall into two categories - medium and large quantity generators. Regulated generators should call the Washington State Department of Ecology at 425-649-7000 for more information or visit www.ecy.wa.gov/programs/hwtr/demodebris/pages2/genstatus.html.
What is "hazardous waste"?
The owner of a business must first decide if something is a waste, and if so, whether it is hazardous. A material is a “waste” if:
- The generator doesn’t want it - and no one else can use it.
- It's old or outdated.
- It can no longer be used in the process.
- It spilled.
In Washington, a waste is “hazardous” if it's listed in the state's dangerous waste regulations, Chapter 173-303 WAC, or meets characteristics or criteria described in the regulations. Hazardous wastes require special handling. They cannot be put in the dumpster, poured down the drain or evaporated into the air.
Waste designation
"Waste designation" is the process of deciding if a certain waste is hazardous and selecting the applicable dangerous waste codes. Designation often involves identifying the hazardous chemicals or other constituents in the waste. It helps ensure that the waste is properly labeled and handled.
The specific procedures for designating waste are found in the dangerous waste regulations, WACs 173-303-070 through 173-303-100. Dangerous waste numbers are listed in WACs 173-303-090, 173-303-104, and 173-303-9903 - 9904. The dangerous waste numbers are codes that correspond to the hazardous properties in the waste. For example, D008 means the waste contains lead; WT02 means the waste is toxic; D002 means the waste is corrosive.
Before the products become waste, information about the hazardous chemicals they contain is listed on the Materials Safety Data Sheets (MSDS). Contact suppliers or the product manufacturer for MSDS copies or find more at Ecology’s Clues to Designation Knowledge.
A "waste profile" is a written description of the chemical ingredients in a waste and a listing of the dangerous waste numbers assigned to the waste. Firms that transport, broker, reclaim or dispose of hazardous waste need a waste profile so that they can manage the waste safely and legally. Most private companies and solid waste landfills require a profile or other identification before accepting a waste.
Waste testing
Testing is typically done to determine whether a particular substance is present in the waste, how much of it there is and whether other criteria are salient. Testing is sometimes necessary before designating the waste. For example, used oil is often field-tested to detect the presence of chlorinated solvents. Many wastes, such as untreated photo fixer, are typically designated without testing. Most waste handlers will profile a waste and can arrange to have it tested, if necessary. Doing a little research ahead of time may save money on testing. Here are some tips:
- Explain how the waste was created.
- Provide the chemical ingredients from container labels, material safety data sheets (available from the supplier or manufacturer), or by contacting the manufacturer.
- List anything that was mixed with the material, like water or solvents.
- List any contaminants that were picked up in the process, like oil or metal shavings.
- Don't run tests for substances that couldn't possibly be there or for known substances.
- Don't run tests on outdated (past expiration date) chemicals. These are known from the label and material safety data sheets.
- Do run tests for hazardous substances that could be present, but are uncertain.
It’s important to remember that after the waste profile is completed, the business (generator) signs it, not the waste handler. Because the business is ultimately responsible for the proper disposal of the waste it produces, an accurate profile is important.
Example
A shop mixes concentrated cleaner with water and uses the solution to clean oily, corroded auto parts. The shop's waste management firm suggests testing the solution for solvents and heavy metals. In the preceding year the shop had eliminated all solvents from its cleaning process. The shop shows the material safety data sheets to the waste management firm and explains its "no solvent" policy. The firm agrees that solvent testing is unnecessary. Because parts are corroded before cleaning, it is a good idea to test for heavy metals.
