Is Managing Hazardous Waste Really the Nightmare People Say It Is?


The secret to effectively managing hazardous waste is to implement a comprehensive and integrated management program to minimize the amount generated and stored at any given time and share responsibility for managing.  As a result, regulatory requirements are minimized, and you are left with time to devote elsewhere, like having lunch.

A comprehensive management program for hazardous waste addresses four key aspects: proper characterization, clearly communicated disposal and storage procedures, regular monitoring to maintain generator status, and devotion to proper tracking and reporting.  The best programs have standard operating procedures (SOP) for all of these aspects which define roles and responsibilities throughout the organization and act as a catalyst for ownership in the process. 


Don’t it always seem to go, that you don’t know what you’ve got till it’s gone?

Characterizing your waste streams is the first important step towards effectively managing waste.  EPA and PADEP regulations have requirements for characterizing hazardous wastes.  Here’s a hint, characterize all waste streams so you know what you’ve got before it’s gone.


Such a determination or characterization should be made using all three of the following criteria:

  • Knowledge of the process and/or materials used to generate the waste;
  • Review of the Material Safety Data Sheet (MSDS) for hazardous constituents;
  • Analytical sampling of the waste stream using USEPA approved methods including the Toxic Characteristic Leachate Procedure (TCLP).
Once routinely generated wastes have been characterized, the results must be documented and kept on file until three years after the last disposal of such a waste or until the waste stream changes due to changes in process or raw materials or other changes that warrant a new characterization.


Routinely generated wastes that may be hazardous include:

  • Parts cleaning solvents (check ignitability and TCLP metals)
  • Other spent/used solvents (check ignitability and TCLP metals)
  • Paint waste (oil-based) (check ignitability and TCLP metals)
  • Fluorescent Bulbs (check TCLP for mercury and lead)
Non-routine or contractor wastes should be characterized every time.  Because of the variability in these waste streams, characterization should be as specific as possible, often demonstrating that wastes may be non-hazardous and more cost-effectively disposed of.


Haz Waste Management Comes in Different Sizes to Meet Your Specific Needs.

Conditionally Exempt Small Quantity Generators (CESQG) are those generating hazardous wastes in amounts no more than 100 kg/month (approximately 220 pounds or half of a 55-gallon drum) or generating less than 1 kg/month of acutely hazardous waste and accumulating no more than 1,000 kg of hazardous waste or 1 kg of acutely hazardous waste. 

Small Quantity Generators (SQG) are those generating hazardous wastes in amounts greater than 100 and less than 1,000 kg/month or generating less than 1 kg/month of acutely hazardous waste (and storing no more than 6,000 kg of waste at any one time).

Large Quantity Generators (LQG) are those generating hazardous wastes in an amount of 1,000 kg/month or greater or generating more than 1 kg/month of acutely hazardous waste.


Examples of Management Requirements

CESQG and SQG status facilities can accumulate up to a total of 55 gallons of hazardous waste in a container that is located near the point of generation.

A LQG must clearly mark each container with the date on which the drum becomes full (accumulation begins).  Full containers must be stored in a certified containment building operated in accordance with 40 CFR Part 265, Subpart DD requirements.

SQG and LQG accumulation areas must be inspected weekly and documentation must be maintained.  Items to inspect include: container condition, marking, accumulation area condition, and emergency response equipment.

Limits on accumulation time and quantity for hazardous waste vary depending on generator status:

  • CESQG: there is no accumulation time limit on CESQG provided that the total amount of accumulated wastes does not exceed 1000 kg.
  • SQG: may accumulate up to 6,000 kilogram (or 1,500 gallons) of hazardous waste for up to 180 days. 
  • LQG status: may accumulate hazardous waste on site for up to 90 days provided the hazardous waste storage facility is maintained in accordance by properly trained personnel with a clearly written preparedness and prevention plan and emergency response measures are defined in a clearly written contingency plan.


    SQG and LQG generators are required to prepare special shipping papers known as manifests to track every container from “cradle to grave”.   These shipping papers are required to be kept on file and monitored to ensure that documentation of final disposition is maintained. 

    Biennial Reports are to be prepared and submitted to EPA and PADEP to document and verify generator status and program implementation.  Here is one area where some level of sophistication may be warranted for information tracking.  There are many software packages available on the market to automate some of this information management.  Often times, it can be integrated into existing shipping information systems maintained at facilities.

    Many plants don’t generate more than 100 kg (220 lbs) of hazardous waste in a month and therefore operate as a CESQG.  If remediation projects or other special clean ups on site require disposal of greater than 220 pounds of  hazardous waste, they will need to evaluate the need to implement hazardous waste collection and disposal measures in compliance with either SQG or LQG requirements. 

    When changes in hazardous waste operations require a change in generator status formal notification to USEPA is required by submitting a revised “Notification of Hazardous Waste Activity” form (EPA Form 8700) to the state contact for hazardous waste management.
    Avogadro Environmental Corporation | 1350 Sulivan Trail Suite A, Easton, PA 18040 | 610-599-8776