1. Hazardous Waste Generator Training

2. Overview Laws & Regulations Hazardous Waste Procedures/Inspections
Weekly Inspections
PPE
Empty Container Rule
Hazardous Waste Characteristics
Hazardous Waste Paperwork
Accumulation Rules
Hazardous Waste Storage Areas
Hazardous Waste Labeling
Accumulation Times
Incompatibility of Wastes
Emergency Response

3. Laws & Regulations Federal Regulations
Code of Federal Regulations (CFR)
EPA regulation Title 40 CFR
OSHA regulation 29 CFR
DOT regulation 49 CFR
HWCL (Hazardous Waste Control Law) Regulation
California Code of Regulation Title 22(CCR)
California Health & Safety Code (CH&SC)
DTSC Fact Sheet

4. Waste Regulations
Congress defined waste and gave statutory authority to the Environmental Protection Agency (EPA) to regulate it. RCRA (Resource Conservation and Recovery Act) had cradle-to-grave control that regulated the generation, transportation, treatment, storage and disposal of hazardous waste.

5. Waste Regulations
1984, RCRA amended to include HSWA (hazardous and solid waste amendments), requiring generators to:
certify that they have a waste minimization program in place (Small waste generators need to make a good faith effort to minimize no written program needed. section title )
identify efforts to be taken to reduce the quantity and toxicity of the waste
Requirement of Land Ban/LDR

6. California RCRA allows California to implement its own RCRA program
The program must be at least as stringent
Multi agency and levels of government
Federal EPA (Region 9 – San Francisco)
California EPA (Cal-EPA - Sacramento)
Department of Toxic Substance Control (DTSC)
Local (city or county) Certified Unified Program Agencies (CUPA)

7. CUPAs & Other Agencies CUPA
Responsible for applying statewide standards in its jurisdiction of the following programs
Hazardous Waste Generator Program
Hazardous Management Plans & HM Inventory
Aboveground Petroleum Storage Act (New 2008)
Underground Storage Tank Program
HM Release Response Plans & Inventory Program
Above Ground Storage Tank Program
Onsite HW Treatment Tiered Permitting Program

8. What is the CUPA looking at during Inspections?
Start Date
Inspectors can:
Inspect operations and waste storage areas
Review Waste Inspection Records
Training Records
Review All Paper work associated with Manifests
Ask employees questions
Review Consolidated Emergency Response/Contingency Plan

9. Most Frequent Violations Cited include
Marking and Labeling missing or incorrect
Lack of training or no training
No documentation of inspection of waste storage areas or inspections not conducted properly
Record keeping of associated paperwork (example Manifests, LDR and waste profiles)

10. Conduct weekly Inspection of waste storage areas.
Inspection items include
Containers are not open, damaged or leaking
Correct Labeling (Satellite or Haz Waste Area)
Initial accumulation start date on label
Incompatibles are not stored together
Secondary containment and containment area is clean and dry
Unidocs Inspection Form

11. Personal Protection
Choice based on type of exposure the material represents
Routes of entry
Inhalation
Absorption
Ingestion
Injection

12. Personal Protection Four levels Level A Level B Level C Level D
Highest level of respiratory, dermal and eye protection
Level B
Highest level of respiratory protection, lower level of dermal protection
Level C
Lower level of respiratory and dermal protection
Level D
No respiratory and limited dermal protection

13. Disposal of Empty Containers
Did the container hold acute or extremely hazardous material? If so treat as hazardous waste.
Is the container completely empty?
No liquid can’t drain when tilted in any direction.
No material remains and no encrusted material.
How large is container and is it recyclable?
Managing Empty Containers

14. What exactly is a hazardous waste?
EPA (40 CFR § 261.2) defines a hazardous waste as any material that is “discarded, abandoned, or inherently wastelike… which because of its quantity, concentration, or physical, chemical, or infectious characteristics may…pose a hazard to human health or the environment.”
Inherently Waste Photo

15. Hazardous Characteristics
When does a material first become a waste?
When a material can no longer be used for its original intent.
When “Inherently” waste like conditions are obvious. Expired, discarded, no longer used….
When you deem it to be a waste. It looks good but you no longer need it.

16. Hazardous Characteristics
Determining whether a material is hazardous is the first challenge you face in the hazmat identification process.
Defining HW
Ignitable Corrosive Reactive Toxic

17. California UWR - Wastes
Universal Wastes are:
Hazardous waste batteries
Hazardous waste thermostats
Hazardous waste lamps
Hazardous waste cathode ray tubes (CRT)
Mercury-containing equipment
Consumer electronic devices (CEDs)
Non-empty aerosol cans
UW Label

18. California UWR - Wastes
Universal waste batteries
All hazardous waste batteries except vehicle (cranking) spent lead-acid batteries
Hazardous for:
Corrosivity – Alkaline or acidic
electrolyte
Heavy metals – Lead, zinc, nickel, cadmium, mercury, silver, etc
Reactivity – Lithium (unspent)
Lithium Dangers

19. California UWR - Wastes
Mercury-containing equipment: Thermostats, mercury switches, mercury thermometers, pressure or vacuum gauges, dilators and weighted tubing, mercury rubber flooring, mercury gas flow regulators, dental amalgams, counterweights, dampers and mercury added novelties such as jewelry, ornaments and footwear.

20. California UWR - Wastes
Universal waste lamps
Hazardous due to:
Mercury content (fluorescent tubes, high intensity discharge, sodium lamps)
Reactivity (low pressure sodium)
Leaded glass (some HID lamps)

21. California UWR - Wastes
Non-empty aerosol cans
Empty means that all the contents are used that could be used when the delivery mechanism functions properly
Hazardous due to reactivity (and…)

22. Characteristic Wastes
Hazardous waste definitions are separated into two (2) different categories:
Wastes that Exhibit one of the following.
Ignitability, reactivity, corrosivity, toxicity
2. Wastes that are Listed either RCRA or California.

23. Exhibit Wastes Those that exhibit a “characteristic” hazard like:
Ignitable (D001),- if the waste is a liquid and has a flashpoint less than 140 degrees F.
Corrosive (D002)- If the waste has a pH of 2 or less, or 12.5 or more, or if it corrodes steel at a certain rate.

24. Exhibit Wastes Cont.
Reactive (D003) - if the material reacts with water, forms explosive mixtures with water, generates toxic fumes or vapors when mixed with water, is a cyanide or sulfide bearing waste which generates hazardous fumes or vapors, or is explosive.
Toxic (D004-43)- if the wastes contain more than a certain level of some toxic materials. Includes heavy metals, organics, and pesticides.

25. Listed Wastes
2- The other hazardous waste classification includes those that are specifically “listed” as a hazardous waste.
Listed Waste includes:
Over 400 chemicals and chemical wastes are listed wastes. They have codes that begin with P, U, F, or K
“P” code wastes are acutely hazardous, containers that contain these wastes are also managed as hazardous waste unless triple rinsed.

26. Listed Wastes
P and U codes - Discarded commercial chemical products includes: P codes (acutely hazardous) and U codes (non-acutely hazardous).
They are not considered hazardous until they are discarded in its unused form. They can be stored indefinitely if they are to be used.
Many P-code wastes are pesticides

27. Listed Wastes
F-code wastes are wastes that are listed from non-specific sources.
Includes spent halogenated and non-halogenated solvents in (methylene chloride, CCl4, benzene, toluene, MEK, etc.)
K-code wastes includes wastes from specific industry sources or processes.

28. Manifest Resources
Links below are good resources to understand Hazardous Waste Manifets.
EPA Waste Codes
CA Waste Codes
CA Restricted
Waste Codes
Example Manifest

29. Hazardous Waste Disposal Paperwork
Uniform Hazardous Waste Manifest
Waste Profiles (Reviewed annually-referenced on Manifest)
Bill of lading
Land Ban/Land Disposal Restrictions
Sample
Waste Profile

30. Bill of Lading
Used as the proper shipping papers for Universal Wastes.
Uniform Hazardous Waste Manifest is NOT necessary for universal waste shipments.
Keep records of all shipments and receipts of universal waste for at least 3 years.

31. Land Ban/Land Disposal Restrictions
Land Ban requires wastes sent for disposal have an LDR (Land Disposal Restrictions) form.
The LDR states the waste has been treated or qualifies to be disposed to land disposal.

32. Manifest
The “Uniform Hazardous Waste Manifest” is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage, or disposal facility (TSDF).

33. Generator Classifications
Small Quantity Generator – 220 to 2,200 lbs of hazardous waste and less than 2.2 lbs of acute hazardous waste per month.
Acquire an EPA I.D. number.
Follow EPA storage facility requirements.
Follow DOT packaging requirements.
Prepare manifests to accompany shipments.
Include certification with each shipment on the proper treatment method.
Allowed to store waste longer than 90 days.
Accumulation
Fact Sheet

34. Satellite Accumulation Areas
Waste can be accumulated in satellite areas with minimal regulatory burden.
Must be at or near the process generating the waste.
55 gallon accumulation limit.
Excess of 55 gallons must be removed within 72 hours.
Containers must be Labeled, “Hazardous Waste”, Date accumulation started, Composition and physical state with words that identify the contents and hazardous properties (Ex. Flammability, reactivity, corrosivity, ignitability )

35. Hazardous Waste Accumulation Rules
HW Label
Label All Containers
Put Waste labels on all waste bottles i.e. waste toluene.
Identify the material. Disposal of unknown waste is very expensive.
Complete all information on the label and date. Including EPA Id#.

36. Hazardous Waste Accumulation Rules
1) Store chemical waste in the designated area.
Not on the floor or in the fume hood
2) Keep containers closed.
Never leave funnels in the drums, bottles, or lids unscrewed.

37. Hazardous Waste Accumulation Rules
Stoppers or corks are unacceptable.
Containers must be compatible with the waste.
Must be properly labeled.
Must have completed Waste Label
Do not overfill
leave 2 inches headspace in all bottles and containers

38. Hazardous Waste Accumulation Rules
Print clearly!
Do not use formulas, symbols or abbreviations.
Commingled Waste must equal 100%, including water and trace chemicals.
Dilution is not the Solution. Waste placed into neat (virgin) material makes the whole container waste!
Place only compatible materials together.

39. Hazardous Waste Accumulation Rules
Secondary Containment
Secondary containment is required for hazardous waste containers.
110% of the individual container.
If multiple waste containers are stored inside same secondary containment it must be 110% of largest container or 10% of all the containers, whichever is greater.
If outdoors must be protected from rainfall or sized to handle 24 hours of rainfall.

40. Hazardous Waste Accumulation Rules
Incompatible Wastes must not be stored together.
Example; Oxidizers and Flammables/Acids and Bases.
Incompatible wastes should be separated by secondary containment, wall (distance), dike or other means.

41. Emergency Planning Contingency Plans
Hazardous Materials Business Plans (HMBP)
Awareness Level First Responders
Emergency Response/Contingency Plan
Hazardous materials inventory
Business emergency plans (Shut down)
Evacuation Procedures
Title
Awareness Level
HMBP
Emergency Response
Guidebook
DOT Placards

42. Questions?
Disclaimer – Keenan & Associates is an insurance brokerage and consulting firm. It is not a law firm. We do not give legal advice and neither this training presentation, the answers providing during the question and answer period, nor the documents accompanying this presentation constitutes or should be construed as legal advice. You are advised to follow up with your own legal counsel to discuss how this information affects you.