Hazardous Waste: What You Need to Know

Hazardous materials remain hazardous even after they’re used. And other materials can become hazardous with use. Today we’ll review safety information about hazardous wastes that will help you protect your employees from harmful exposure.
Hazardous Waste Defined

According to the OSHA Required Training for Supervisors monthly newsletter, the Resource Conservation and Recovery Act (RCRA) defines a hazardous waste as any substance that has one or more of the following characteristics:

  • Ignitable—Can catch fire easily

  • Corrosive—Can burn eyes or skin or corrode containers

  • Reactive—Can catch fire, explode, or give off hazardous fumes if it comes in contact with air, water, or certain other substances

  • Toxic—Can poison humans and other animals

Hazardous Waste Regulations
Hazardous wastes are primarily regulated by RCRA regulations (40 CFR Parts 260-279), which are administered by the Environmental Protection Agency (EPA).

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OSHA’s Hazardous Waste Operations and Emergency Response Standard, known as HAZWOPER (29 CFR 1910.120), may also apply and generally covers operations involving hazardous waste at treatment, storage, and disposal facilities regulated by RCRA, as well as cleanup operations or emergency response involving hazardous wastes at any location.
In addition, Department of Transportation (DOT) regulations must be followed whenever wastes are shipped from your plant (49 CFR Parts 171-180).
Control Strategies
RCRA’s generator regulations and DOT’s shipping rules focus on these strategies:

  • Packaging. Wastes transported from your plant for disposal must be properly prepared for shipment in accordance with DOT packaging regulations.

  • Labeling, marking, and placarding. Every hazardous waste container must have a label that identifies the chemical inside as well as the generator’s name and EPA-issued ID number. Waste shipments must also be marked and placarded according to DOT rules.

  • Tracking manifests. Every shipment of hazardous waste that leaves your plant must be accompanied by a manifest prepared and signed by your organization. The manifest must have your EPA ID number; the organization’s name, address, and phone number; the name and ID number of the transporter and receiving facility; and a description of the hazardous waste, including quantity, type, and number of containers. The manifest must stay with the shipment until the waste is properly disposed of.

  • Accumulation limits. RCRA regulations generally allow generators to keep hazardous wastes on site for up to 90 days without a special EPA permit as long as the wastes are in approved containers and properly managed.

The OSHA HAZWOPER regulations come into play when there is a release of hazardous wastes and emergency response is required.

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Container Maintenance and Storage
To prevent accidental leaks and spills, safe storage of hazardous wastes during the accumulation period is essential. That means:

  • Waste containers need to be inspected regularly (at least weekly), and any damaged or leaking containers need to be reported immediately.

  • Waste tanks need to be inspected daily for leaks, corrosion, and accurate controls.

  • Leaking or corroded containers must be immediately removed from service and the contents transferred to sound containers.

  • Containers with missing or incomplete labels must be reported immediately.

  • Material safety data sheets (MSDSs) need to be consulted to determine incompatible substances, and incompatible substances should always be stored separately.

  • Wastes should never be mixed without full assurance of safety.

  • Hazardous waste storage areas must be well ventilated and have an impervious floor so that leaking chemicals can’t seep into the ground.

In tomorrow’s Advisor we’ll look at some safe work practices that can help minimize the danger to your employees posed by hazardous wastes.