A Guide for Small Businesses

United States Environmental Protection Agency

1EPASolid Waste andEmergency Response(5305W)

EPA530-K-01-005December 2001www.epa.gov/osw

HazardousWaste

Managing Your

ii

1 INTRODUCTION

2 DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU

2 Defining Hazardous Waste

3 Identifying Your Waste

3 Finding Your Generator Category

7 OVERVIEW OF REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS

8 OBTAINING AN EPA IDENTIFICATION NUMBER

11 MANAGING HAZARDOUS WASTE ON SITE

11 Accumulating Your Waste

13 Treating Your Waste To Meet the Land Disposal Restrictions

13 Preventing Accidents

14 Responding to Emergencies

16 SHIPPING WASTE OFF SITE

16 Selecting a Treatment, Storage, and Disposal Facility

16 Labeling Waste Shipments

17 Preparing Hazardous Waste Manifests

17 Land Disposal Restrictions (LDR) Reporting Requirements

18 Export Notification

18 Closure

21 SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS

22 WHERE TO GET MORE HELP

22 EPA and Other Federal Resource Centers

24 EPA Regional Offices

26 ACRONYMS AND DEFINITIONS

CONTENTS

Does your business generatehazardous waste? Many small

businesses do. If you need helpunderstanding which federal haz-ardous waste management regula-tions apply to your business, thishandbook is for you. It has beenprepared by the U.S. Environmen-tal Protection Agency (EPA) to helpsmall-business owners and opera-tors understand how best to com-ply with federal hazardous wastemanagement regulations.

This handbook provides anoverview of the regulations to giveyou a basic understanding of yourresponsibilities. It should not beused as a substitute for the actualrequirements. All of the federalhazardous waste regulations arelocated in Title 40 of the Code ofFederal Regulations (CFR), Parts260 to 299 (www.epa.gov/epacfr40).

EPA defines three categories ofhazardous waste generators basedupon the quantity of hazardouswaste they generate per month:

(1) Conditionally exempt smallquantity generators (CESQGs),which generate less than 220lbs (100 kg) per month.

(2) Small quantity generators(SQGs), which generatebetween 220 lbs (100 kg) and2,200 lbs (1,000 kg) permonth.

(3) Large quantity generators(LQGs), which generate morethan 2,200 lbs (1,000 kg) permonth.

Each category of generator mustcomply with the hazardous wasterules specific to that category. Thishandbook is intended primarily forbusinesses that generate a smallquantity of hazardous waste (SQGsand CESQGs) to help them learnabout regulations that apply tothem.

This handbook explains only thefederal requirements for hazardouswaste management. Many stateshave their own hazardous wasteregulations based on the federal

hazardous waste regulations. Insome of these states, the require-ments are the same as the federalstandards and definitions. Otherstates, however, have developedmore stringent requirements thanthe federal program. If this is thecase in your state, you must com-ply with the state regulations. Tobecome familiar with your state’srequirements, consult your statehazardous waste agency. For theaddress or phone number for yourstate agency, contact the RCRACall Center at 800 424-9346 orTDD 800 553-7672.

INTRODUCTION

You can look up unfamiliarwords, phrases, or

acronyms in the list of defini-tions found on page 26.

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If you have questions about any part of thisbook, or the federal hazardous waste regula-tions, contact the RCRA Call Center at 703 412-9810 or TDD 703 412-3323 in theWashington, DC, area or at 800 424-9346 orTDD 800 533-7672 from other locations, or<www.epa.gov/epaoswer/hotline>.

The Call Center provides free technical assis-tance. Any information you share will not beused for any other purpose.

FOR MORE INFORMATION

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DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU

Defining Hazardous Waste

Awaste is any solid, liquid, or con-tained gaseous material that is

discarded by being disposed of,burned or incinerated, or recycled.(There are some exceptions for recy-cled materials.) It can be the by-product of a manufacturing processor simply a commercial product thatyou use in your business—such asa cleaning fluid or battery acid—andthat is being disposed of. Evenmaterials that are recyclable or canbe reused in some way (such as

burning solvents for fuel) might beconsidered waste.

Hazardous waste can be one oftwo types:

�� Listed waste. Your waste isconsidered hazardous if itappears on one of four listspublished in the Code ofFederal Regulations (40 CFRPart 261). Currently, morethan 500 wastes are listed.Wastes are listed as haz-ardous because they areknown to be harmful to humanhealth and the environmentwhen not managed properly.

Even when managed properly,some listed wastes are sodangerous that they are calledacutely hazardous wastes.Examples of acutely haz-ardous wastes include wastesgenerated from some pesti-cides and that can be fatal tohumans even in low doses.

�� Characteristic wastes. If yourwaste does not appear onone of the hazardous wastelists, it still might beconsidered hazardous if it

demonstrates one or more ofthe following characteristics:

� It catches fire under certainconditions. This is known asan ignitable waste. Examplesare paints and certaindegreasers and solvents.

� It corrodes metals or has avery high or low pH. This isknown as a corrosive waste.Examples are rust removers,acid or alkaline cleaning flu-ids, and battery acid.

� It is unstable and explodesor produces toxic fumes,gases, and vapors whenmixed with water or underother conditions such asheat or pressure. This isknown as a reactive waste.Examples are certaincyanides or sulfide-bearingwastes.

� It is harmful or fatal wheningested or absorbed, or itleaches toxic chemicals intothe soil or ground water whendisposed of on land. This isknown as a toxic waste.Examples are wastes thatcontain high concentrationsof heavy metals, such as cad-mium, lead, or mercury.

You can determine if your waste istoxic by having it tested using theToxicity Characteristic Leaching

Federal hazardous waste

management regulations

apply to most businesses

that generate hazardous

waste. To determine if

these regulations apply to

your business, you must

first determine if you even

generate hazardous

waste.

Determine if you generate hazardous wastein the first place.

Measure the amount of hazardous waste thatyou produce per month.

Determine your generator category to learn themanagement requirements that apply to you.

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Procedure (TCLP), or by simplyknowing that your waste is haz-ardous or that your processes gen-erate hazardous waste. For moreinformation about the TCLP andother test methods, contact theRCRA Call Center or the MethodsInformation CommunicationExchange (MICE) at 703 676-4690or <www.epa.gov/sw-846>.

Identifying Your Waste

To help you identify some of thewaste streams common to your

business, consult the table onpage 4 to find a list of typical haz-ardous wastes generated by smallbusinesses. Use the insert in themiddle of this handbook for amore detailed listing of the EPAwaste codes associated with thesewaste streams to determine if yourwaste is hazardous. Commercialchemical products that are discard-ed might also become hazardouswaste. For a complete listing ofhazardous waste codes, see 40CFR Part 261.

If your waste is hazardous, you willneed to manage it according toappropriate federal regulations.

Finding Your GeneratorCategory

Once you know that you gener-ate hazardous waste, you

need to measure the amount ofwaste you produce per month. Theamount of hazardous waste yougenerate determines your genera-tor category.

Many hazardous wastes are liquidsand are measured in gallons—notpounds. In order to measure yourliquid wastes, you will need to con-vert from gallons to pounds. To dothis, you must know the density ofthe liquid. A rough guide is that 30gallons (about half of a 55-gallondrum) of waste with a density simi-lar to water weighs about 220pounds (100 kg); 300 gallons of awaste with a density similar towater weighs about 2,200 lbs(1,000 kg).

EPA has established three genera-tor categories, as follows, each ofwhich is regulated differently:

CESQGs:Conditionally Exempt SmallQuantity Generators: You are con-sidered a CESQG if you generateless than 220 lbs (100 kg) permonth of hazardous waste. Youare exempt from hazardous wastemanagement regulations providedthat you comply with the basicrequirements described on page 6.

If you are a CESQG and you gener-ate no more than 2.2 lbs (1 kg) ofacutely hazardous waste (or 220

lbs (100 kg) of acutely hazardouswaste spill residues) in a calendarmonth, and never store more thanthat amount for any period of time,you may manage the acutely haz-ardous waste according to theCESQG requirements. If you gener-ate or store more than 2.2 lbs(1kg) of acutely hazardous wasteon site, you must manage itaccording to the LQG requirements(see below).

SQGs:Small Quantity Generators: Youare considered an SQG if you gen-erate between 220 and 2,200 lbs(100 and 1,000 kg) per month ofhazardous waste. SQGs must com-ply with EPA requirements for man-aging hazardous waste describedin this document.

LQGs:Large Quantity Generators: Youare considered an LQG if you gen-erate more than 2,200 lbs (1,000kg) per month of hazardous waste.LQGs must comply with moreextensive hazardous waste rulesthan those summarized in thishandbook. See page 21 for anoverview.

One way to help determine if your waste exhibits any of thecharacteristics listed on page 2 is to check the Material

Safety Data Sheet (MSDS) that comes with all products containinghazardous materials (www.msdsonline.com for information). Inaddition, your national trade association or its local chapter mightbe able to help you.

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TYPE OF BUSINESS

Drycleaning and Laundry Plants

Furniture/WoodManufacturing andRefinishing

Construction

Laboratories

VehicleMaintenance

Printing and AlliedIndustries

Equipment Repair

Pesticide End-Users/ApplicationServices

Educational andVocational Shops

Photo Processing

LeatherManufacturing

HOW GENERATED

Commercial drycleaning processes

Wood cleaning and wax removal,refinishing/stripping, staining, paint-ing, finishing, brush cleaning andspray brush cleaning

Paint preparation and painting, car-pentry and floor work, other special-ty contracting activities, heavyconstruction, wrecking and demoli-tion, vehicle and equipment mainte-nance for construction activities

Diagnostic and other laboratorytesting

Degreasing, rust removal, paintpreparation, spray booth, sprayguns, brush cleaning, paint removal,tank cleanout, installing lead-acidbatteries, oil and fluid replacement

Plate preparation, stencil prepara-tion for screen printing, photopro-cessing, printing, cleanup

Degreasing, equipment cleaning,rust removal, paint preparation,painting, paint removal, spray booth,spray guns, and brush cleaning.

Pesticide application and cleanup

Automobile engine and body repair,metalworking, graphic arts-platepreparation, woodworking

Processing and developing nega-tives/prints, stabilization systemcleaning

Hair removal, bating, soaking,tanning, buffing, and dyeing

TYPICAL WASTES

Still residues from solvent distilla-tion, spent filter cartridges, cookedpowder residue, spent solvents,unused perchloroethylene

Ignitable wastes, toxic wastes,solvent wastes, paint wastes

Ignitable wastes, toxic wastes,solvent wastes, paint wastes, usedoil, acids/bases

Spent solvents, unused reagents,reaction products, testing samples,contaminated materials

Acids/bases, solvents, ignitablewastes, toxic wastes, paint wastes,batteries, used oil, unused cleaningchemicals

Acids/bases, heavy metal wastes,solvents, toxic wastes, ink, unusedchemicals

Acids/bases, toxic wastes,ignitable wastes, paint wastes,solvents

Used/unused pesticides, solventwastes, ignitable wastes, contami-nated soil (from spills), contaminat-ed rinsewater, empty containers

Ignitable wastes, solvent wastes,acids/bases, paint wastes

Acid regenerants, cleaners,ignitable wastes, silver

Acids/bases, ignitables wastes,toxic wastes, solvent wastes,unused chemicals

TYPICAL HAZARDOUS WASTE GENERATED BY SMALL BUSINESSES

WASTE CODES

D001, D039, F002, F005, U210

D001, F001-F005

D001, D002, F001-F005

D001, D002, D003, F001-F005, U211

D001, D002, D006, D007, D008,D035, F001-F005, U002, U080, U134,U154, U159, U161, U220, U228,U239

D002, D006, D008, D011, D019,D035, D039, D040, D043, F001-F005,U002, U019, U043, U055, U056,U069, U080, U112, U122, U154,U159, U161, U210, U211, U220,U223, U226, U228, U239, U259,U359

D001, D002, D006, D008, F001-F005

D001, F001-F005, U129, U136, P094,P123

D001, D002, F001-F005

D001, D002, D007, D011

D001, D002, D003, D007, D035,F001-F005, U159, U228, U220

WHAT IS YOUR GENERATOR CATEGORY?

Depending on your type of business, you might be regulatedunder different rules at different times. If, for example, you gen-erate less than 220 lbs (100 kg) of hazardous waste during themonth of June, you would be considered a CESQG for June, andyour June waste would be subject to the hazardous waste man-agement requirements for CESQGs. If, in July, you generatebetween 220 and 2,200 lbs (100 kg to 1,000 kg) of hazardouswaste, your generator status would change, and you would beconsidered an SQG for July. Your July waste would then be subjectto the management requirements for SQGs. If you mix the wastesgenerated during June and July, the entire mixture would be subjectto the more stringent SQG standards.

5

In many cases, small businesses that fallinto different generator categories at

different times choose to satisfy the morestringent requirements to simplifycompliance.

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UNIVERSAL WASTES

The Universal Waste Rule was written to streamline envi-ronmental regulations for wastes generated by large

numbers of businesses in relatively small quantities. It isdesigned to reduce the amount of hazardous waste dis-posed of in municipal solid waste, encourage the recyclingand proper disposal of certain common hazardous wastes,and reduce the regulatory burden for businesses that gen-erate these wastes.

Universal wastes are items commonly thrown into thetrash by households and small businesses. Although han-dlers of universal wastes can meet less stringent stan-dards for storing, transporting, and collecting thesewastes, handlers must still comply with the full hazardouswaste requirements for final recycling, treatment, or dis-posal. By providing a waste management structure thatremoves these wastes from municipal landfills and inciner-ators, this rule ensures stronger safeguards for publichealth and the environment.

Universal wastes include:

�� Batteries, such as nickel-cadmium (Ni-Cd) and smallsealed lead-acid batteries, which are found in manycommon items, including electronic equipment, cellphones, portable computers, and emergency backuplighting.

�� Agricultural pesticides that have been recalled orbanned from use, are obsolete, have become dam-aged, or are no longer needed due to changes incropping patterns or other factors. They often arestored for long periods of time in sheds or barns.

�� Thermostats, which can contain as much as 3 gramsof liquid mercury and are located in almost any build-ing, including commercial, industrial, agricultural, com-munity, and household buildings.

�� Lamps, which typically contain mercury and some-times lead, and are found in businesses and house-holds. Examples include fluorescent, high-intensitydischarge (HID), neon, mercury vapor, high-pressuresodium, and metal halide lamps.

Materials are continually added to the Universal Waste list;check <www.epa.gov/epaoswer/hazwaste/id/univwast.htm>for the latest information.

The Universal Waste Rule also encourages communitiesand businesses to establish collection programs or partici-pate in manufacturer take-back programs required by anumber of states. Many large manufacturers and tradeassociations are already planning national and regional col-lection programs for their universal waste products.

For more information, see 40 CFR Part 273.

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DO Measure:

All quantities of listed and char-acteristic hazardous wastes thatare:

�� Accumulated on the propertyfor any period of time beforedisposal or recycling.(Drycleaners, for example,must count any residueremoved from machines,as well as spent cartridgefilters.)

�� Packaged and transportedaway from your business.

�� Placed directly in a regulatedtreatment or disposal unit atyour place of business.

�� Generated as still bottomsor sludges and removedfrom product storage tanks.

DO NOT Measure:

Wastes that:

�� Are specifically exemptedfrom counting. Examplesinclude lead-acid batteriesthat will be reclaimed, scrapmetal that will be recycled,used oil managed under theused oil provisions of 40CFR 279, and universalwastes (e.g., batteries, pesti-cides, thermostats, andlamps) managed under 40CFR 273.

�� Might be left in the bottomof containers that have beenthoroughly emptied throughconventional means such aspouring or pumping.

�� Are left as residue in the bot-tom of tanks storing prod-ucts, if the residue is notremoved from the producttank.

�� Are reclaimed continuouslyon site without storing priorto reclamation, such asdrycleaning solvents.

�� Are managed in an “elemen-tary neutralization unit,” a“totally enclosed treatmentunit,” or a “wastewater treat-ment unit,” without beingstored first. (See Definitionsfor an explanation of thesetypes of units.)

�� Are discharged directly topublicly owned treatmentworks (POTWs) without beingstored or accumulated first.This discharge to a POTW

must comply with the CleanWater Act. POTWs are publicutilities, usually owned bythe city, county, or state, thattreat industrial and domesticsewage for disposal.

�� Have already been countedonce during the calendarmonth, and are treated onsite or reclaimed in somemanner, and used again.

�� Are regulated under the uni-versal waste rule or haveother special requirements.The federal regulations con-tain special, limited require-ments for managing certaincommonly generated wastes.These wastes can be man-aged following the less bur-densome requirements listedbelow instead of the usualhazardous waste require-ments. Check with your stateagency to determine if yourstate has similar regulations.

Used oil—40 CFR Part 279

Lead-acid batteries that arereclaimed—40 CFR Part266, Subpart G

Scrap metal that is recy-cled—40 CFR 261.6 (a)(3)

Universal wastes (e.g., cer-tain batteries, recalled andcollected pesticides, andmercury-containing thermo-stats and lamps)—40 CFRPart 273

WHAT DO YOU MEASURE TO DETERMINE YOUR GENERATOR CATEGORY?

First, you must identify all haz-ardous waste that you gener-

ate. Second, you may not storemore than 2,200 lbs (1,000 kg) ofhazardous waste on site at any

time. Finally, you must ensuredelivery of your hazardous wasteto an off-site treatment or disposalfacility that is one of the following,or, if you treat or dispose of yourhazardous waste onsite, your facilityalso most be:

�� A state or fed-erally regulatedhazardouswaste manage-ment treat-ment, storage,or disposalfacility.

�� A facility permitted, licensed,or registered by a state tomanage municipal or industri-al solid waste.

�� A facility that uses, reuses, orlegitimately recycles thewaste (or treats the wasteprior to use, reuse, orrecycling).

�� A universal waste handler ordestination facility subject tothe universal waste require-ments of 40 CFR Part 273.(Universal wastes are wastes

such as certain batteries,recalled and collected pesti-cides, or mercury-containingthermostats or lamps.)

Suggestion:

It’s a good idea to call the appro-priate state agency to verify thatthe treatment, storage, and dispos-al facility (TSDF) you have selectedhas any necessary permits, etc.You also may want to see that thefacility fits into one of the abovecategories. (It’s a good idea todocument such calls for yourrecords.)

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OVERVIEW OF REQUIREMENTS FOR CONDITIONALLYEXEMPT SMALL QUANTITY GENERATORS

If you generate no more

than 220 lbs (100 kg) of

hazardous waste per

month, you are a

Conditionally Exempt

Small Quantity Generator

(CESQG). You must comply

with three basic waste

management requirements

to remain exempt from the

full hazardous waste regu-

lations that apply to gener-

ators of larger quantities

(SQGs and LQGs).

(Note: there are different

quantity limits for acutely

hazardous waste.)

Identify your hazardous waste.

Comply with storage quantity limits.

Ensure proper treatment and disposal of yourwaste.

STATE REQUIREMENTS

Some states have additional requirementsfor CESQGs. For example, some states

require CESQGs to follow some of the SQGrequirements such as obtaining an EPA identifi-cation number, or complying with storage stan-dards. See page 14 for SQG storagerequirements.

CESQG

To obtain an EPA identificationnumber, you should:

�� Call or write your state haz-ardous waste managementagency or the hazardous wastedivision of your EPA Regionaloffice and ask for a copy ofEPA Form 8700-12,“Notification of HazardousWaste Activity” (EPA Regional

offices are listed on pages 24or visit <www.epa.gov/epaoswer/hazwaste/data/form8700/forms.htm>). You will besent a booklet that contains aform with instructions andthose portions of the regula-tions that will help you identifyyour waste. A sample copy of acompleted notification form isshown on pages 9-10. (Note: Afew states use a form that isdifferent from the one shown.Your state agency will send you the appropriate form tocomplete.)

�� Fill in the form as shown in theexample. To complete Item IXof the form, you will need toidentify your hazardous wasteby its EPA Hazardous WasteCode. A list of common haz-ardous wastes and their wastecodes can be found on theinsert in this handbook; for acomplete list of waste codes,you should consult 40 CFR Part261, or contact your state orregional EPA office or the RCRACall Center. The form youreceive from your state mightcontain an additional sheetthat provides more space forwaste codes. Complete one

copy of the form for each busi-ness site where you generateor handle hazardous waste.Each site will receive its ownEPA identification number.Make sure you sign the certifi-cation in Item X.

�� Send the completed form toyour state hazardous wastecontact. This address is listedin the information booklet thatyou will receive with the form.

EPA records the information on theform and assigns an EPA identifica-tion number to the site identified onyour form. The EPA number stayswith the property when ownershipchanges. If you move your business,you must notify EPA or the state ofyour new location and submit a newform. If another business previouslyhandled hazardous waste at thislocation and obtained an EPAIdentification Number, you will beassigned the same number afteryou have notified EPA that you havemoved to this location. Otherwise,EPA will assign you a new identifica-tion number.

OBTAINING AN EPA IDENTIFICATION NUMBER

If your business generates

between 220 lbs (100 kg)

and 2,200 lbs (1,000 kg)

of hazardous waste per

month, you are an SQG,

and you must obtain and

use an EPA identification

number. EPA and states

use these 12-character

numbers to monitor and

track hazardous waste

activities. You will need to

use your identification

number when you send

waste off site to be

managed.

Call your state agency to determine if youneed an EPA identification number.

If you do, obtain a copy of EPA Form 8700-12.

Fill in the form completely.

Send the form to your STATE hazardous wastecontact.

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SQG

9

SAMPLE “NOTIFICATION OF REGULATED WASTE ACTIVITY” FORM

SQG

10

SAMPLE “NOTIFICATION OF REGULATED WASTE ACTIVITY” FORM (CONTINUED)

SQG

Accumulating Your Waste

Accumulating hazardous wasteon site can pose a threat to

human health and the environment,so you may keep it only for a shorttime without a permit. Before ship-ping the waste for disposal or recy-cling, you are responsible for itssafe management, which includessafe storage, safe treatment, pre-venting accidents, and respondingto emergencies in accordance withfederal regulations.

SQGs can accumulate no morethan 13,228 lbs (6,000 kg) of haz-ardous waste on site for up to 180days without a permit. You canaccumulate this amount of wastefor up to 270 days if you musttransport it more than 200 milesaway for recovery, treatment, or

disposal. Limited extensions maybe granted by the state director orthe regional EPA administrator. Ifyou exceed these limits, you areconsidered a TSDF and mustobtain an operating permit. Wastesgenerated in small amountsthroughout your facility may bestored in satellite accumulationareas located at or near the pointof generation of the waste. Thetotal amount of waste that may beaccumulated at a satellite area islimited to 55 gallons. Once thisquantity has been exceeded, youhave 3 days to transfer the wasteto your designated 180-day (or270-day) storage area.

(Note: Different quantity limits applyto acutely hazardous wastes.)

SQGs must accumulate waste intanks or containers, such as 55-gallon drums. Your storage tanksand containers must be managedaccording to EPA requirementssummarized below:

For containers, you must:

�� Label each container with thewords “HAZARDOUS WASTE”and the date that the wastewas generated.

�� Use a container made of, orlined with, a material that iscompatible with the haz-ardous waste to be stored.(This will prevent the wastefrom reacting with or corrodingthe container.)

�� Keep all containers holdinghazardous waste closed dur-ing storage, except whenadding or removing waste. Donot open, handle, or store(e.g., stack) containers in away that might rupture them,cause them to leak, or other-wise fail.

�� Inspect areas where contain-ers are stored at least weekly.Look for leaks and for deterio-ration caused by corrosion orother factors.

�� Maintain the containers ingood condition. If a containerleaks, put the hazardous wastein another container, or containit in some other way that com-plies with EPA regulations.

�� Do not mix incompatiblewastes or materials unlessprecautions are taken toprevent certain hazards.

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MANAGING HAZARDOUS WASTE ON SITE

Accumulate wastes according to limits estab-lished by EPA for SQGs.

Follow the storage and handling proceduresrequired by EPA for SQGs.

Follow EPA requirements for equipment testingand maintenance, access to communications or

alarms, aisle space, and emergency arrangementswith local authorities.

Most small businesses

accumulate some haz-

ardous waste on site for a

short period of time and

then ship it off site to a

treatment, storage, or dis-

posal facility (TSDF).

It is a good practice never to mix wastes. Mixingwastes can create an unsafe work environment and

lead to complex and expensive cleanups and disposal.

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SQG

12

�� Do not mix wastes. Do notmix nonhazardous waste withhazardous waste. Once youmix anything with listed haz-ardous waste, the wholebatch becomes hazardous.Mixing waste can also makerecycling very difficult, if notimpossible. A typical exampleof mixing wastes would beputting nonhazardous clean-ing agents in a container ofused hazardous solvents.

�� Change materials, process-es, or both. Businesses cansave money and increaseefficiency by replacing amaterial or a process withanother that produces lesswaste. For example, youcould use plastic blastmedia for paint stripping ofmetal parts rather than con-ventional solvent stripping.

�� Recycle and reuse manufac-turing materials. Many com-panies routinely put usefulcomponents back into pro-ductive use rather than dis-posing of them. Items suchas oil, solvents, acids, andmetals are commonly recy-cled and used again. In addi-tion, some companies have

taken waste minimizationactions such as using fewersolvents to do the same job,using solvents that are lesstoxic, or switching to a deter-gent solution.

�� Safely store hazardous prod-ucts and containers. Youcan avoid creating more haz-ardous waste by preventingspills or leaks. Store haz-ardous product and wastecontainers in secure areas,and inspect them frequentlyfor leaks. When leaks orspills occur, materials usedto clean them also becomehazardous waste.

�� Make a good faith effort.SQGs do not have to docu-ment their waste minimiza-tion activities or create awaste minimization plan. Youdo, however, need to certifyon your manifests that youhave made a good faitheffort to minimize waste gen-eration when you send yourwaste off site.

WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT

The easiest and most cost-effective way of managing any waste is not to generate it in the first place. Youcan decrease the amount of hazardous waste your business produces by developing a few “good house-

keeping” habits. Good housekeeping procedures generally save businesses money, and they prevent acci-dents and waste. To help reduce the amount of waste you generate, try the following practices at yourbusiness.

SQG

13

For tanks, you must:

�� Label each tank with thewords “HAZARDOUS WASTE”and the date that the wastewas generated.

�� Store only waste that will notcause the tank or the innerliner of the tank to rupture,leak, corrode, or fail.

�� Equip tanks that have anautomatic waste feed with awaste feed cutoff system, or abypass system for use in theevent of a leak or overflow.

�� Inspect discharge control andmonitoring equipment and thelevel of waste in uncoveredtanks at least once eachoperating day. Inspect thetanks and surrounding areasfor leaks or other problems(such as corrosion) at leastweekly.

�� Use the National FireProtection Association’s(NFPA’s) buffer zone require-ments for covered tanks con-taining ignitable or reactivewastes. These requirementsspecify distances consideredto be safe buffer zones forvarious ignitable or reactivewastes. You can reach theNFPA at 617 770-3000.

�� Do not mix incompatiblewastes or materials unlessprecautions are taken to pre-vent certain hazards.

�� Do not place ignitable or reac-tive wastes in tanks unlesscertain precautions are taken.

�� Provide at least 2 feet (60centimeters) of freeboard(space at the top of eachtank) in uncovered tanks,unless the tank is equipped

with a containment structure,a drainage control system, ora standby tank with adequatecapacity.

Treating Your Waste to Meet the Land DisposalRestrictions (LDRs)

Most hazardous wastes maynot be land disposed unless

they meet “treatment standards.”The Land Disposal Restrictions(LDR) program requires that thewaste is treated to reduce the haz-ardous constituents to levels setby EPA, or that the waste is treat-ed using a specific technology. It isyour responsibility to ensure thatyour waste is treated to meet LDRtreatment standards before it island disposed. (See page 17 for adescription of required LDRnotices.) Most SQGs probably willhave their designated TSDF do thistreatment. If you choose to treatyour waste yourself to meet LDRtreatment standards, there areadditional requirements includingwaste analysis plans, notifications,and certifications. To learn aboutthese requirements, contact theRCRA Call Center, your stateagency, or EPA regional office, andconsult 40 CFR Part 268.

Preventing Accidents

Whenever you store hazardouswaste on site, you must mini-

mize the potential risks from fires,explosions, or other accidents.

SQG

14

All SQGs that store hazardouswaste on site must be equippedwith:

�� An internal communications oralarm system capable of pro-viding immediate emergencyinstruction (voice or signal) toall personnel.

�� A device, such as a telephone(immediately available at thescene of operations) or ahand-held, two-way radio,capable of summoning emer-gency assistance from localpolice and fire departments oremergency response teams.

�� Portable fire extinguishers,fire-control devices (includingspecial extinguishing equip-ment, such as those usingfoam, inert gas, or dry chemi-cals), spill-control materials,and decontaminationsupplies.

�� Water at adequate volumeand pressure to supply water-hose streams, foam-producingequipment, automatic sprin-klers, or water spray systems.

You must test and maintain allequipment to ensure proper opera-tion. Allow sufficient aisle space topermit the unobstructed movementof personnel, fire protection equip-ment, spill-control equipment, anddecontamination equipment to anyarea of facility operation. Attemptto secure arrangements with firedepartments, police, emergencyresponse teams, equipment suppli-

ers, and local hospitals, as appro-priate, to provide services in theevent of an emergency. Ensurethat personnel handling hazardouswaste have immediate access toan alarm or emergency communi-cations device.

You are not required to have a for-mal personnel training program, butyou must ensure that employeeshandling hazardous waste are famil-iar with proper handling and emer-gency procedures. In addition, youmust have an emergency coordina-tor on the premises or on-call at alltimes, and have basic facility safetyinformation readily accessible.

Responding to Emergencies

Although EPA does not requireSQGs to have a written contin-

gency plan, you must be preparedfor an emergency at your facility.You should also be prepared toanswer a set of “what if” ques-tions. For example: “What if thereis a fire in the area where haz-

ardous waste is stored?” or “Whatif I spill hazardous waste, or one ofmy hazardous waste containersleaks?” In case of a fire, explo-sion, or toxic release, having sucha plan provides an organized andcoordinated course of action.SQGs are required to establishbasic safety guidelines andresponse procedures to follow inthe event of an emergency.

Worksheets 1 and 2 (on page 15)can help you set up these proce-dures. The information onWorksheet 1 must be posted nearyour phone. You must ensure thatemployees are familiar with theseprocedures.

IF YOU THINK YOU HAVE AN EMERGENCY,IMMEDIATELY CALL 911 AND THE NATIONALRESPONSE CENTER AT 800 424-8802.

In the event of a fire, explosion,or other release of hazardous

waste that could threatenhuman health outside the facili-ty, or if you think that a spill hasreached surface water, call theNational Response Center toreport the emergency. TheResponse Center will evaluate

the situation and help you makeappropriate emergency deci-sions. In many cases, you willfind that the problem you facedwas not a true emergency, but itis better to call if you are notsure. Serious penalties exist forfailing to report emergencies.

SQG

15

Worksheet 1 Fill in and post this information next to your telephone.

Worksheet 2 Fill in and post this information next to your telephone. Make sure all employees read and are familiarwith its contents.

✂

In the event of a spill:

Contain the flow of hazardous wasteto the extent possible, and as soonas is possible, clean up the haz-ardous waste and any contaminatedmaterials or soil.

In the event of a fire:

Call the fire department and, if safe,attempt to extinguish the fire usinga fire extinguisher.

In the event of a fire, explosion, orother release that could threatenhuman health outside the facility, orif you know that the spill hasreached surface water:

Call the National Response Centerat its 24-hour number (800 424-8802). Provide the following infor-mation:

Emergency Coordinator

Name: ________________________________________

________________________________________________

Telephone: ____________________________________

________________________________________________

________________________________________________

Fire Extinguisher

Location(s): ____________________________________

________________________________________________

________________________________________________

________________________________________________

Spill-Control Materials

Location(s): ____________________________________

________________________________________________

________________________________________________

Fire Alarm (if present)

Location(s): ____________________________________

________________________________________________

________________________________________________

________________________________________________

Fire Department

Telephone: ____________________________________

EMERGENCY RESPONSE INFORMATION

EMERGENCY RESPONSE PROCEDURES

Our company name:

__________________________________________________________________

__________________________________________________________________

Our address:

__________________________________________________________________

__________________________________________________________________

Our U.S. EPA identification number:

__________________________________________________________________

Date of accident __________________________________________________

Time of accident __________________________________________________

Type of accident (e.g., spill or fire) __________________________________

Quantity of hazardous waste involved ________________________________

Extent of injuries, if any ____________________________________________

Estimated quantity and disposition of recovered materials, if any

__________________________________________________________________ ✂

SQG

Package, label, and mark your shipment, andplacard the vehicle in which your waste isshipped as specified in DOT regulations.

Prepare a hazardous waste manifest to accom-pany your shipment.

Include a notice and certification with the firstwaste shipment.

Ensure the proper management of any hazardouswaste you ship (even when it is no longer in yourpossession).

16

SQG

Selecting a Treatment,Storage, and DisposalFacility (TSDF)

SQGs may send their waste onlyto a regulated Treatment,

Storage, and Disposal Facility(TSDF) or recycler. Most regulatedTSDFs and recyclers will have apermit from the state or EPA.Some, however, may operate underother regulations that do notrequire a permit. Check with theappropriate state authorities to besure the facility you select has any

necessary permits. All TSDFs andrecyclers must have EPA identifica-tion numbers.

Labeling Waste Shipments

SQGs must properly package,label, and mark all hazardous

waste shipments, and placard thevehicles in which these wastes areshipped following Department ofTransportation (DOT) regulations.Most small businesses use a com-mercial transporter to ship haz-ardous waste. These transporterscan advise you on specific require-ments for placarding, labeling,marking, and packaging; however,you remain responsible for compli-ance. For additional information,consult the DOT regulations (49CFR Parts 172 and 173) or callthe DOT hazardous materials infor-mation line at 202 366-4488 or800 467-4922.

Federal regulations allow you totransport your own hazardouswaste to a designated TSDF provid-ed that you comply with DOT rules.Some states, however, do notallow this practice. Call DOT andyour state hazardous waste man-agement agency regarding applica-ble regulations.

SHIPPING WASTE OFF SITE

When shipping waste off

site, SQGs must follow

certain procedures that

are designed to ensure

safe transport and proper

management of the waste.

17

SQG

Preparing Hazardous WasteManifests

The Hazardous Waste ManifestSystem is a set of forms,

reports, and procedures designedto seamlessly track hazardouswaste from the time it leaves thegenerator until it reaches the off-site waste management facilitythat will store, treat, or dispose ofthe hazardous waste. The systemallows the waste generator toverify that its waste has been prop-erly delivered and that no wastehas been lost or unaccounted forin the process.

The key component of this systemis the Uniform Hazardous WasteManifest, which is a multipart formprepared by most generators thattransport hazardous waste for off-site treatment, recycling, storage,or disposal. The manifest isrequired by both the DOT and EPA.When completed, it contains infor-

mation on the type and quantity ofthe waste being transported,instructions for handling thewaste, and signatures of all par-ties involved in the off-site treat-ments, recycling, storage, ordisposal process. Each party alsomust retain a copy of the mani-fest. This process ensures criticalaccountability in the transportationand disposal process. Once thewaste reaches its destination, thereceiving facility returns a signedcopy of the manifest to the genera-tor, confirming that the waste hasbeen received.

At press time, the UniformHazardous Waste Manifest systemis in the process of being updatedand modernized. Please check theInternet at www.epa.gov/epaoswer/hazwaste/gener/manifest/index.htm.

EPA expects to standardize thecontent and appearance of the cur-

rent manifest form so that thesame form may be used by wastehandlers nationwide. Other antici-pated changes include improvedtracking procedures and an optionto complete, send, and store themainfest information electronically.

Land Disposal Restrictions(LDR) ReportingRequirements

Regardless of where the wasteis being sent, the initial ship-

ment of waste subject to LDRsmust be sent to a receiving TSDFor recycler along with an LDRnotice. You must send an addition-al LDR notice if your waste orreceiving facility changes. Thisnotice must provide informationabout your waste, such as the EPAhazardous waste code and theLDR treatment standard. The pur-pose of this notice is to let theTSDF know that the waste must

18

SQG

meet treatment standards before itis land disposed. There is norequired form for this notice, butyour TSDF may provide a form foryou to use. A certification mayalso be required in specific situa-tions. Contact the RCRA CallCenter, your state agency, or EPAregional office and consult 40 CFRPart 268 for help with LDR notifica-tion and certification requirements.

Export Notification

If you choose to export your haz-ardous waste, you must notify

EPA 60 days before the intendeddate of shipment to obtain writtenconsent. EPA’s “Acknowledge-mentof Consent” document mustaccompany the shipment at alltimes. For more information onhow to obtain the consent toexport hazardous waste, contactthe RCRA Call Center at 800 424-9346.

Closure

When you close your facility,you must ensure that all haz-

ardous waste has been removedfrom your hazardous waste tanks,discharge-control equipment, anddischarge confinement structures.In addition, any contamination youmight have caused must becleaned up and managed under allapplicable hazardous wasteregulations.

19

It is important to choose your transporter and yourTSDF carefully because you remain responsible for

the proper management of your hazardous wasteeven after it has left your site.

For help in choosing a transporter or TSDF, checkwith the following sources:

�� References from business colleagues who haveused a specific hazardous waste transporter orTSDF.

�� Trade associations for your industry that mightkeep a file on companies that handle hazardouswaste.

�� The Better Business Bureau or Chamber ofCommerce in the TSDF’s area, which might havea record of any complaints registered against atransporter or a facility.

�� Your state hazardous waste managementagency or EPA regional office, which can tell youwhether the transporter or TSDF has an EPAidentification number and a permit, if required.Facility information, including types and quanti-ties of waste managed and violationsassessed, can be accessed via the EnvirofactsInternet site at <www.epa.gov/enviro>.

SELECTING A TRANSPORTER OR TSDF/RECYCLER

SQG

EPA’s used oil management stan-dards are a set of “good house-keeping” requirements thatencourage used oil handlers torecycle used oil instead of dispos-ing of it. Used oil can be collected,refined and recycled, and usedagain—for the same job or a com-pletely different task.

Used oil is defined as “any oil thathas been refined from crude oil orany synthetic oil that has beenused and, as a result of such use,is contaminated by physical orchemical impurities.” To meetEPA’s definition of used oil, a sub-stance must meet each of the fol-lowing criteria:

�� Origin. Used oil must havebeen refined from crude oil ormade from synthetic materi-als. Animal and vegetable oilsare excluded from EPA’s defi-nition of used oil.

�� Use. Oils used as lubricants,hydraulic fluids, head transferfluids, buoyants, and for othersimilar purposes are consid-ered used oil. Unused oilsuch as bottom clean-outwaste from virgin fuel oil stor-age tanks or virgin fuel oilrecovered from a spill do notmeet EPA’s definition of usedoil because these oils havenever been used. EPA’s defini-tion also excludes productsused as cleaning agents orsolely for their solvent proper-ties, as well as certain petro-leum-derived products suchas antifreeze and kerosene.

�� Contaminants. To meet EPA’sdefinition, used oil mustbecome contaminated as aresult of being used. Thisincludes residues and contami-nants generated from handling,storing, and processing used

oil. Physical contaminants caninclude dirt, metal scrapings, orsawdust. Chemical contami-nants could include solvents,halogens, or saltwater.

The following types of businesseshandle used oil:

�� Generators are businessesthat handle used oil throughcommercial or industrial oper-ations or from the mainte-nance of vehicles andequipment. Examples includecar repair shops, service sta-tions, government motorpools, grocery stores, metal-working industries, and boatmarinas. Farmers who pro-duce less than an average of25 gallons of used oil permonth are excluded from gen-erator status. Individuals whogenerate used oil through themaintenance of their personalvehicles and equipment are

MANAGING USED OIL

20

SQG

not subject to regulationunder the used oil manage-ment standards.

�� Collection centers and aggre-gation points are facilitiesthat accept small amounts ofused oil and store it untilenough is collected to ship itelsewhere for recycling.

�� Transporters are companiesthat pick up used oil from allsources and deliver it to re-refiners, processors, or burners.Transfer facilities are any struc-ture or area where used oil isheld for longer than 24 hoursbut not longer than 35 days.

�� Re-refiners and processorsare facilities that blend orremove impurities from usedoil so the oil can be burnedfor energy recovery or reused.

�� Burners burn used oil forenergy recovery in boilers,industrial furnaces, or in haz-ardous waste incinerators.

�� Marketers are handlers thateither a) direct shipments ofused oil to be burned as fuel inregulated devices or b) claimthat certain EPA specificationsare met for used oil to beburned for energy recovery indevices that are not regulated.

Although different used oil han-dlers have specific requirements,the following requirements arecommon to all types of handlers:

Storage

�� Label all containers and tanksas Used Oil.

�� Keep containers and tanks ingood condition. Do not allowtanks to rust, leak, or deterio-rate. Fix structural defectsimmediately.

�� Never store used oil in any-thing other than tanks andstorage containers. Used oilalso can be stored in unitsthat are permitted to storeregulated hazardous waste.

Oil Leaks or Spills

�� Take steps to prevent leaksand spills. Keep machinery,equipment, containers, andtanks in good working condi-tion, and be careful when trans-ferring used oil. Keep sorbentmaterials available at the site.

�� If a leak or spill occurs, stopthe oil from flowing at thesource. If a leak can’t bestopped, put the oil in anotherholding container or tank.

�� Contain spilled oil using sor-bent berms or spreading sor-bent over the oil andsurrounding area.

�� Clean up the used oil andrecycle it as you would havebefore it was spilled. If recy-cling is not possible, youmust first make sure the usedoil is not a hazardous wasteand dispose of it appropriate-ly. All used cleanup materials,including rags and sorbentbooms, that contain used oilmust also be handled accord-ing to the used oil manage-ment standards.

�� Remove, repair, or replace thedefective tank or containerimmediately.

Used oil requirements are detailedin 40 CFR Part 279. For moreinformation, contact the EmergencyResponse Division’s InformationHotline at 202 260-2342.

21

SUMMARY OF REQUIREMENTS FOR LARGE QUANTITYGENERATORSIf you are a Large Quantity Generator (LQG) (generating more than 2,200 lbs (1,000

kg) per month), you must comply with the full set of hazardous waste regulations. This

table summarizes the federal LQG requirements. This is only a summary and does not

include all of the LQG requirements. For more details, contact the RCRA Call Center at

800 424-9346, or TDD 800 553-7672, or see 40 CFR Part 262. Be sure to check with

your state as well because certain states have additional or more stringent require-

ments than the federal government.

LQG Requirements

Hazardous Waste Determination(40 CFR Part 262.10)Generator Category Determination(40 CFR Part 262.10 (b) and 261.5 (b)and (c))

EPA Identification Numbers(40 CFR 262.12)

Prepare Hazardous Waste for ShipmentOff Site (40 CFR Parts 262.30 - 262.33)

The Manifest(40 CFR Parts 262.20 - 262.23, 262.42)

Managing Hazardous Waste On Site(40 CFR Part 262.34)

Recordkeeping and Biennial Report(40 CFR Parts 262.40 - 262.41)

Comply with Land Disposal Restrictions(40 CFR 268)

Export/Import Requirements(40 CFR Subparts E and F)

Air Emissions (40 CFR Part 265,Subpart CC)

Closure (40 CFR Parts 265.111 and265.114)

Summary

Identify all hazardous wastes you generate. Measure the amount of hazardous waste yougenerate per month to determine your generator category (e.g., LQG).

Obtain a copy of EPA Form 8700-12, fill out the form, and send it to the contact listed withthe form. An EPA identification number will be returned to you for your location.

Package, label, mark, and placard wastes following Department of Transportation require-ments. Ship waste using hazardous waste transporter.

Ship waste to hazardous waste treatment, storage, disposal, or recycling facility. Ship haz-ardous waste off site using the manifest system (EPA Form 8700-22) or state equivalent.

Accumulate waste for no more than 90 days without a permit. Accumulate waste in contain-ers, tanks, drip pads, or containment buildings. Comply with specified technical standards foreach unit type.

Retain specified records for 3 years. Submit biennial report by March 1 of even numberedyears covering generator activities for the previous year.

Ensure that wastes meet treatment standards prior to land disposal. Send notifications andcertifications to TSDF as required. Maintain waste analysis plan if treating on site.

Follow requirements for exports and imports, including notification of intent to export andacknowledgement of consent from receiving country.

If applicable, use various monitoring and control mechanisms to:• Control volatile organic compound (VOC) emissions from hazardous waste management

activities.• Reduce organic emissions from process vents associated with certain recycling activities

and equipment that is in contact with hazardous waste that has significant organic content.• Control VOCs from hazardous waste tanks, surface impoundments, and containers using

fixed roofs, floating roofs, or closed-vent systems routed to control devices.

Decontaminate and remove all contaminated equipment, structures, and soil, and minimizethe need for further maintenance of your site. Meet unit-specific closure standards for tanks,containment buildings, and drip pads.

LQG

22

WHERE TO GET MORE HELPFor further assistance in

understanding the haz-

ardous waste regulations

applicable to you, contact

your state hazardous waste

agency. Other assistance

resources include the EPA

Resource Centers (includ-

ing the RCRA Call Center),

or your EPA regional office

(page 24).

Also, see other related sections ofthe Code of Federal Regulations:

� Handling PCBs (40 CFR Part761)

� Toxic Release Inventory (TRI)Reporting (40 CFR Part 372)

� Domestic Sewage WasteDisposal Reporting (40 CFRPart 403)

� Shipping Hazardous Materials(49 CFR Parts 171-180)

EPA and Other FederalResource Centers

RCRA Call CenterU.S. Environmental ProtectionAgency1200 Pennsylvania Ave, NW.Washington, DC 20460Phone: 800 424-9346, or TDD800 553-7672. In Washington,DC: 703 412-9810, or TDD 703 412-3323Web: www.epa.gov/epaoswer/hotline

Answers questions on mattersrelated to solid waste, hazardouswaste, and underground storagetanks. Also can be used to findand order EPA publications.

RCRA in Focus

RCRA in Focus is a series ofshort informational booklets

that describes the RCRA regula-tions as they apply to specificindustry sectors. The documentsexplain what RCRA is, who isregulated, and what hazardouswaste is; provide a sample lifecycle of a RCRA waste in eachindustry; include a quick refer-ence chart of all applicableRCRA regulations and a seriesof waste minimization sugges-tions for various specific indus-trial processes; and provideinformation on other relevantenvironmental laws and a pageof contacts and resources.

Individual issues of RCRA inFocus have been written for thefollowing industries:

• Dry Cleaning (EPA530-K-99-005)

• Leather Manufacturing(EPA530-K-00-002)

• Motor Freight & RailroadTransportation (EPA530-K-00-003)

• Photo Processing (EPA530-K-99-002)

• Printing (EPA530-K-97-007)

• Vehicle Maintenance(EPA530-K-99-004)

Other issues of RCRA in Focuswill cover:

• Wood Preserving/WoodProducts

• Construction, Demolition &Renovation

• Metals Manufacturing

• Furniture Manufacturing

• PharmaceuticalManufacturing

• Laboratories

Copies of RCRA in Focus can beobtained by contacting the RCRACall Center at 800 424-9346 orTDD 800 553-7672 and request-ing the document numbers list-ed above. You can also view thedocuments online at<www.epa.gov/epaoswer/hazwaste/id/infocus/index.htm>.

23

Small Business OmbudsmanClearinghouse/HotlineU.S. Environmental ProtectionAgencySmall Business Ombudsman(1230C)1200 Pennsylvania Ave, NW.Washington, DC 20460Phone: 800 368-5888 or 202 260-1211Fax: 202 401-2302Web: www.epa.gov/sbo

Helps private citizens, small busi-nesses, and smaller communitieswith questions on all programaspects within EPA.

Department of Transportation(DOT) HotlineOffice of Hazardous MaterialsStandards (DOT)Research and Special ProgramsAdministration400 7th Street, SW.Washington, DC 20590-0001Phone: 202 366-4488 or 800 467-4922Fax: 202 366-3753Web: http://hazmat.dot.gov

Answers questions on mattersrelated to DOT’s hazardous materi-als transportation regulations.

RCRA Docket Information Center(RIC)U.S. Environmental ProtectionAgencyRCRA Docket Information Center(5305W)1200 Pennsylvania Ave, NW.Washington, DC 20460Phone: 703 603-9230Fax: 703 603-9234E-mail: RCRA-Docket@epamail.epa.govWeb: www.epa.gov/epahome/dockets.htm

Provides public access to all regu-latory materials on solid waste anddistributes technical and nontech-nical information on solid waste.

Pollution Protection InformationClearinghouse (PPIC)U.S. Environmental ProtectionAgency1200 Pennsylvania Ave, NW.Washington, DC 20460Phone: 202 260-4659Fax: 202 260-0178E-mail: PPIC@epamail.epa.govWeb: www.epa.gov/opptintr/library/libppic.htm

Provides a library and an electronicbulletin board (accessible by anyPC equipped with a modem) dedi-cated to information on pollutionprevention.

Information Resource CenterU.S. Environmental ProtectionAgencyHeadquarters Library1200 Pennsylvania Ave, NW.IRC (3404)Washington, DC 20460Phone: 202 260-5922Fax: 202 260-5153E-mail: public-access@epamail.epa.govWeb: www.epa.gov/natlibra/hairc

Maintains environmental referencematerials for EPA staff and thegeneral public, including books,journals, abstracts, newsletters,and audio-visual materials generat-ed by government agencies andthe private sector.

Methods InformationCommunication Exchange (MICE)U.S. Environmental ProtectionAgencyOSW Methods Team1200 Pennsylvania Ave, NW.(5307W)Washington, DC 20460Phone: 703 676-4690 or 703 308-8855Fax: 703 318-4682 or 703 308-0511E-mail: mice@cpmx.saic.comWeb: www.epa.gov/sw-846

24

EPA Regional Offices

EPA Region 1CT, MA, ME, NH, RI, VT1 Congress StreetSuite 1100Boston, MA 02114-2023617 918-1111 or800 372-7431 in Region 1Library: 888 372-5427 or 617 918-1990

EPA Region 2 NJ, NY, PR, VI290 Broadway26th FloorNew York, NY 10007-1866212 637-3000Library: 212 637-3185

EPA Region 3 DC, DE, MD, PA, VA, WV1650 Arch StreetPhiladelphia, PA 19103-2029215 814-5000 or800 438-2474 in Region 3Library: 215 814-5254

EPA Region 4AL, FL, GA, KY, MS, NC, SC, TNAtlanta Federal Center61 Forsyth Street, SWAtlanta, GA 30303-3104404 562-9900800 241-1754 in Region 4Library: 404 562-8190

EPA Region 5IL, IN, MI, MN, OH, WI77 West Jackson BoulevardChicago, IL 60604312 353-2000 or800 621-8431 in Region 5

EPA Region 6 AR, LA, NM, OK, TX1445 Ross AvenueSuite 1200Dallas, TX 75202-2733214 665-2200 or800 887-6063 in Region 6Library: 214 665-6424

EPA Region 7IA, KS, MO, NE901 North 5th StreetKansas City, KS 66101913 551-7000 or800 223-0425 in Region 7Library: 913 551-7241

EPA Region 8 CO, MT, ND, SD, WY, UTOne Denver Place999 18th StreetSuite 500Denver, CO 80202-2466303 312-6312 or800 227-8917 in Region 8

EPA Region 9 AS, AZ, CA, GU, HI, MH, MP, NV75 Hawthorne StreetSan Francisco, CA 94105415 744-1305Library: 415 744-1510

EPA Region 10 AK, ID, OR, WA1200 Sixth AvenueSeattle, WA 98101206 553-1200 or800 424-4372 in Region 10Library: 206 553-1289

25

Worksheet 3 These questions are geared toward the federal requirements for SQGs but may be helpful for otherhazardous waste generators. Use them to help prepare for a visit from a federal, state, or local agency.

Yes No

❑ ❑ Do you have documentation on the amount and kinds of hazardous waste that you generate and on howyou determined that they are hazardous?

❑ ❑ Do you have a U.S. EPA identification number?

❑ ❑ Do you ship wastes off site?

❑ ❑ If so, do you know the name of the transporter and the designated TSDF that you use?

❑ ❑ Do you have copies of completed manifests used to ship your hazardous wastes over the past 3 years?

❑ ❑ Are they filled out correctly?

❑ ❑ Have they been signed by the designated TSDF and transporter?

❑ ❑ If you have not received your signed copy of the manifest from the TSDF, have you filed an exceptionreport?

❑ ❑ Is your hazardous waste stored in proper containers or tanks?

❑ ❑ Are the containers or tanks properly dated and/or marked?

❑ ❑ Have you complied with the handling requirements described in this handbook?

❑ ❑ Have you designated an emergency coordinator?

❑ ❑ Have you posted emergency telephone numbers and the location of emergency equipment?

❑ ❑ Are your employees thoroughly familiar with proper waste handling and emergency procedures?

❑ ❑ Do you understand when you need to contact the National Response Center?

❑ ❑ Do you store your waste for no more than 180 days, or 270 days if you ship your waste more than 200miles?

26

Byproduct

A material that is not one of theprimary products of a productionprocess. Examples of byproductsare process residues such as slagsor distillation column bottoms.

CESQG—ConditionallyExempt Small QuantityGenerator

A business that generates lessthan 220 lbs (100 kg) per monthof hazardous waste.

CFR—Code of FederalRegulations

The CFR is a codification of thegeneral and permanent rules pub-lished in the Federal Register bythe Executive departments andagencies of the federal govern-ment. The CFR is divided into 50“titles,” which represent broadareas subject to federal regulation.Each title is divided into chapters,which usually bear the name of theissuing agency.

Commercial ChemicalProduct

A chemical substance that is man-ufactured or formulated for com-mercial or manufacturing use.

Container

Any portable device in which amaterial is stored, transported,treated, disposed of, or otherwisehandled.

DOT—Department ofTransportation

Federal agency that oversees allnational transportation systemsand regulates the transport ofhazardous materials.

Elementary NeutralizationUnit

A tank, tank system, container,transport vehicle, or vessel (includ-ing ships) that is designed to con-tain and neutralize corrosivewaste.

Implementing Agency

EPA regional office or state agencyresponsible for enforcing the haz-ardous waste regulations.

Incompatible Waste

A hazardous waste that can causecorrosion or decay of containmentmaterials, or is unsuitable for co-mingling with another waste ormaterial because a dangerousreaction might occur. See 40 CFRPart 265, Appendix V for moreexamples.

LDR—Land DisposalRestrictions

The LDR program ensures thattoxic constituents present in haz-ardous waste are properly treatedbefore hazardous waste is dis-posed of in the land (such as in alandfill).

ACRONYMS AND DEFINITIONS

27

LQG—Large QuantityGenerator

A business that generates morethan 2,200 lbs (1,000 kg) permonth of hazardous waste.

MICE—Methods InformationCommunication Exchange

The MICE service providesanswers to questions about testmethods used to determinewhether a waste is hazardous. Italso takes comments on technicalissues regarding EPA’s methodsmanual known as Test Methods forEvaluating Solid Waste:Physical/Chemical Methods (SW-846).

MSDS—Material Safety DataSheets

Chemical manufacturers andimporters prepare detailed techni-cal bulletins called Material SafetyData Sheets about the hazards ofeach chemical they produce orimport. Your suppliers must sendyou an MSDS at the time of thefirst shipment of a chemical andany time the MSDS is updatedwith new and significant informa-tion about the hazards. MSDSsinclude information about compo-nents and contaminants, includingexposure limits, physical data, fireand explosion hazard, toxicity, andhealth hazard data. It also discuss-es emergency and first aid proce-dures and information aboutstorage and disposal, and spill orleak procedures.

NFPA—National FireProtection Association

NFPA’s mission is to reduce theworldwide burden of fire and otherhazards on the quality of life byproviding and advocating scientifi-cally based codes and standards,research, training, and education.NFPA has specific rules for storinghazardous wastes.

PBT—Persistent,Bioaccumulative, and Toxic

Persistent chemicals are thosethat don’t readily break down inthe environment and can be trans-ferred among air, water, soils, andsediments. Bioaccumulative chemi-cals are those that concentrate inanimal and plant tissues as aresult of uptake from the surround-ing environment or as a result ofone organism consuming another.Toxic chemicals, in this context,are those that are hazardous tohuman health and the environ-ment. EPA has been tasked withfocusing on reducing the toxicity ofwastes in addition to the quantityof waste, and its WasteMinimization National Plan focuseson reducing PBT wastes.

POTW—Publicly OwnedTreatment Works

A municipal wastewater treatmentplant that receives wastewaterthrough the public sewer fromhouseholds, office buildings, facto-ries and industrial facilities, andother places where people live andwork.

Reclaimed Material

Material that is regenerated orprocessed to recover a usableproduct. Examples are the recov-ery of lead values from spent bat-teries and the regeneration ofspent solvents.

Recovered Material

A material or byproduct that hasbeen recovered or diverted fromsolid waste. Does not includematerials or byproducts generatedfrom, and commonly used within,an original manufacturing process.

Recycled Material

A material that is used, reused, orreclaimed.

Reused Material

A material that is employed as aningredient in an industrial processto make a product, or is used asan effective substitute for a com-mercial product.

Spent Material

Any material that has been usedand, as a result of contamination,can no longer serve the purposefor which it was produced withoutfirst processing it.

SQG—Small QuantityGenerator

A business that generatesbetween 220 and 2,200 lbs (100and 1,000 kg) per month of haz-ardous waste.

28

Sludge

Any solid, semi-solid, or liquidwaste generated from a municipal,commercial, or industrial waste-water treatment plant, water supplytreatment plant, or air pollutioncontrol facility, exclusive of thetreated effluent from a wastewatertreatment plant.

Still Bottom

Residue or byproduct of a distilla-tion process such as solventrecycling.

Tank

A stationary device designed to contain an accumulation of haz-ardous waste and that is con-structed primarily of nonearthenmaterials (e.g., wood, concrete,steel, plastic).

Totally Enclosed TreatmentFacility

A facility for the treatment of hazardous waste that is directly connected to an industrial produc-tion process and that is construct-ed and operated to prevent therelease of hazardous waste intothe environment during treatment.An example is a pipe in whichwaste acid is neutralized.

TCLP—ToxicityCharacteristic LeachingProcedure

A testing procedure used to deter-mine whether a waste is haz-ardous. The procedure identifieswaste that might leach hazardousconstituents into ground water ifimproperly managed.

TSDF—Treatment, Storage,and Disposal Facility

Refers to a facility that treats,stores, or disposes of hazardouswaste; TSDFs have specificrequirements under RCRA.

VOCs—Volatile OrganicCompounds

VOCs are highly evaporative organ-ic gases that can be produced dur-ing the manufacture or use ofchemicals such as paints, sol-vents, and cleaners. Various pollu-tion control devices can preventthe release of VOCs both outdoorsand indoors.

Wastewater Treatment Unit

A tank or tank system that is sub-ject to regulation under eitherSection 402 or 307(b) of theClean Water Act, and that treats orstores an influent wastewater thatis hazardous waste, or that treatsor stores a wastewater treatmentsludge that is hazardous.

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