The Truth About Hazardous Waste

  • What is Hazardous Material?
    • Hazardous materials can be many things, and they are regulated by multiple agencies. Haz materials can be chemical, biological, radiological, and/or physical and have the potential to be harmful to humans, animals, and the environment either by themselves or through reactions caused by other factors.
  • Who Regulates Hazardous Material?
    • Standards and regulations are most commonly set by the Environmental Protection Agency (EPA), Department of Transportation (DOT), and Occupational Safety and Health Administration (OSHA).
    • For More Information, Reference:
      • EPA 40 CFR 355 contains a list of over 350 hazardous and extremely hazardous substances.
      • DOT 49 CFR 100-199 and 49 CFR 171-180.
      • OSHA 29 Code of Federal Regulations (CFR) 1910.1200.
  • Cradle-to-Grave Responsibility
    • There are hundreds of materials that are classified as hazardous, and manufacturers must be aware that they are responsible, as a generator, for their waste materials from cradle to grave – from generation to ultimate disposal.
    • As recently as the ‘70s, only 10% of hazardous waste material was being managed correctly, which led to the Resource Conservation and Recovery Act of 1976 (RCRA). Since then, nothing – not time or date limit – will now relinquish the generator of a hazardous material from their responsibility.  Even hiring someone to transport and dispose of your material does not alleviate the liability or transfer responsibility.
    • Since companies are fully accountable for their hazardous material until reaching its final destination, it is imperative to have reliable partners you can trust to transport according to EPA regulations, DOT standards, etc.
  • How Transportation Affects the Generator Status
    • With the EPA, manufacturers are given a generator status based on the amount of hazardous waste they generate. Reducing environmental risk means moving from a Large Quantity Generator (LQG) Status to a Small Quantity Generator (SQG) to a Conditionally-Exempt Small Quantity Generator (CESQG) Status.  Moving down this hierarchy makes a company look better with the EPA and reduces the scrutiny manufacturers face as a result of having a higher generator status.  Ohio releases reports with updated status on a biennial basis and calls them Shipment Reports.
    • However, hazardous material can be transported as a product for reuse instead, reducing EPA/Environmental Risk using partners that have obtained prior, written approval from the State’s EPA. If the material is treated as a product, not waste, it no longer reflects on the generator report.  According to the EPA, “If a business generates no more than 220 pounds (100 kilograms) of hazardous waste per month, they are a CESQG.”