Knowing if you’re one of the many facilities required to file a Biannual Hazardous Waste Report with the EPA is not necessarily a straight-forward affair. The characteristics that determine if you need to submit a hazardous waste report are filled with tricky conditions, making it somewhat difficult to know exactly how to classify yourself.
To help combat this hazardous waste confusion, ERA has prepared this short guide to walk you through figuring out whether you need to complete a hazardous material report.
Essentially, you need to submit a hazardous waste report if your facility is a Large Quantity Generator (abbreviated to LQG) or if you treated, stored, or disposed of hazardous waste on site.
It may seem simple, but it’s worth breaking down:
Your facility is categorized as a LQG if it meets any of the following criteria:
- Your facility generated, in the course of any single calendar month, 10,000 kilograms (that’s 2,200 pounds) or more of RCRA Non-Acute hazardous waste.
- Your facility generated or accumulated at any time, more than 1kg (2.2 pounds) of RCRA Acute hazardous waste.
- Your facility generated, in any single calendar month, more than 100 kg (220 pounds) of spill cleanup material contaminated with RCRA Acute hazardous waste.
- Your facility accumulated, at any time, more than 100 kg (220 pounds) of spill cleanup material contaminated with RCRA Acute hazardous waste.
There are a few things to pay attention to in those criteria. One of the most complex conditions to keep track of is the time frame associated with your waste generation and your hazardous chemical inventory.
Knowing exactly how much hazardous material was produced in a single calendar month means that you’ll probably want to have a good environmental data management system in place.
Secondly, knowing the difference between a RCRA Acute and Non-Acute hazardous material is vital, since the difference in thresholds is so enormous.
Basically, Acute hazardous wastes are those that pose a threat to human health and the environment, even when they are properly managed. Acute hazardous wastes use the Hazard Code H, and include almost every form of dioxin-bearing waste.
All other wastes are considered Non-Acute materials, although they are still hazardous. They could be ignitable, toxic, corrosive, or reactive.
You can find a user-friendly list from the EPA helping define Acute and Non-Acute hazardous wastes here.
On top of all that, if you import any hazardous waste from another country, you need to count the amount imported as if you had generated it yourself. So importing 10,000 kg of Non-Acute hazardous waste from another country will make you a LQG, even if your facility doesn’t actually generate any hazardous waste of its own.
Finally, always check with your state department of environmental quality, because some states have their own hazardous material reporting criteria. That means you might be required to submit a hazardous waste report, even if you’re not classified as an LQG by the federal EPA.
You can find more resources about how to complete the biannual hazardous materials report from the EPA’s website and by reading the EPA’s official 2011 Hazardous Waste Report guidebook.