Waste Optimization

Optimize waste management by developing and enforcing a comprehensive plan.

How to Implement a Recycling and Waste Management Plan

Recycling and waste management plans save money, time, and the environment. For example, plans streamline processes like the deployment and collection of waste containers.

Features include:

• Identification of the types of waste produced, including hazardous waste, if applicable
• Identification of parties responsible for waste handling and recordkeeping
• Discussion of methods for measuring waste
• Effectively track or estimate waste volumes as accurately as possible
• Waste management method for each type – storage, reuse, recycling, recovery, disposal
• Maintenance of records pertaining to volumes, management, and collections

When there is a competent, comprehensive plan, significant benefits accrue. Monitoring waste volumes enhance waste reduction strategies and foster effective recycling and reuse practices. This way, waste gets processed more effectively. Material recovery and reuse save money, while landfill disposal can be costly and less sustainable.

ESG Waste Regulations

Now more than ever, organizations and responsible parties are aware of the impact of waste on our air, surface water, and groundwater. ESG waste regulations serve to protect irreplaceable parts of our environment.

EPA & Resource Conservation and Recovery Act (RCRA) Regulations

The Resource and Conservation Recovery Act (RCRA) of 1976 (42 USC §6901 et seq. (1976)) amended the Solid Waste Disposal Act of 1965. The RCRA is the primary law regarding solid and hazardous waste disposal.

The RCRA established national goals for:

• Reducing waste generation
• Protecting people and the environment from waste disposal hazards
• Environmentally sound waste management
• Conservation of natural resources, including energy

RCRA regulations can be complex. Fortunately, there’s an online source of past EPA interpretations of RCRA regulations. RCRA Online is a database indexing letter, memoranda, and publications.

The 1984 Federal Hazardous and Solid Waste Amendments (HSWA) increased the EPA’s enforcement authority by setting more stringent standards for hazardous waste management. It also made the UST program more comprehensive. The HSWA helps to minimize waste by phasing out hazardous waste landfill disposal.

Hazardous Waste

The EPA’s Hazardous Waste Program (RCRA Subtitle C) sets standards for controlling hazardous waste, addressing everything from waste generation to disposal.

Regulations impact facilities involved in every aspect of hazardous waste generation. This includes transportation, treatment, storage, and disposal. For example, 40 CFR sec. 262.11 helps companies determine whether specific solid wastes it generates are hazardous. Hazardous waste includes battery acid, mercury, lead, and PCBs. Many cleaners, oils, and solvents are also considered hazardous waste.

Hazardous Waste

exhibits any of these characteristics: toxicity, reactivity, corrosively, or ignitability.

Toxic waste

is often harmful or even fatal when ingested or absorbed. It is imperative that toxic chemicals not leach into groundwater.

Reactive waste

is prone to explosion. Or, it may release toxic fumes or vapors in unstable environments.

Corrosive waste

is either acidic or alkaline. They can eat away at specific materials, especially metal.

Ignitable waste

is highly flammable. It may even spontaneously combust in specific environments.

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The kind and quantity of waste generated to determine a generator's class. There are three primary classifications: Large Quantity Generators (LQGs), Small Quantity Generators (SQGs), and Very Small Quantity Generators (VSQGs).

Every month:

• LQGs generate 1) 1,000+ kg of hazardous waste, 2) one kg of acutely hazardous waste, or 3) 100+ kg of acute spill residue or soil.
• SQGs generate between 100 and 1,000 kg of hazardous waste.
• VSQGs generate 1) less than 100 kg of hazardous waste, 2) less than one kg of acutely hazardous waste, or 3) less than 100 kg of acute spill residue or soil.

First-time generators need to be aware of the rules so they don’t run afoul. Consultation with knowledgeable third parties mitigates risk.

Laws and Regulations

Any entity involved with hazardous waste must be familiar with RCRA regulations. The EPA oversees hazardous materials from the moment they are generated to their eventual disposal.

Consult relevant parts of 40 CFR:

• Part 261: Identification and listing of hazardous waste
• Part 262: Standards applicable to generators of hazardous waste
• Part 263: Standards applicable to transporters of hazardous waste
• Parts 264 and 265: Standards for operators of hazardous waste treatment, storage, and disposal facilities.

Access more regulatory information through the centralized docket management system at regulations.gov. The Department of Transportation’s Pipeline and Hazardous Materials Safety Administration regulates hazardous waste transport.

Some states maintain waste regulations that are more stringent than federal regulations. They may also define hazardous waste more broadly. Consider that Colorado designates aerosol cans as hazardous waste, for example. States may also require generators to file annual or biennial hazardous waste reports.

Compliance

Compliance falls to the EPA and its various regulatory partners. Regulators focus on:

• Hazardous waste identification
• Those who generate hazardous waste
• Those who transport hazardous waste
• Those who treat, store, and/or dispose of hazardous waste

An onsite compliance evaluation inspection (CEI) determines a hazardous waste handler’s compliance. This includes consideration of RCRA regulations and permit standards.

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The CEI may consist of, but is not limited to:

• Onsite hazardous waste identification
• Identification of units generating, treating, storing, or disposing of hazardous waste
• Review of relevant reports, documents, and on-site plans

Some states adopt RCRA minimums. In other states, regulations may mirror the RCRA but be more stringent in some areas.

For generators, hazardous waste identification is a crucial first step. Compliance requires correct determinations of what is and is not hazardous waste.

Compliance monitoring also involves a review of:

• EPA identification numbers
• Manifesting
• Pre-transport requirements
• Recordkeeping and reporting

Enforcement

State agencies and programs often take responsibility for hazardous waste enforcement. In other instances, the EPA engages in direct enforcement.

Non-Hazardous Waste

The EPA’s Solid Waste Program (RCRA Subtitle D) prohibits the open dumping of solid waste. It establishes standards for solid waste disposal facilities, including municipal solid waste landfills. The program requires that states develop plans to manage municipal solid waste. The same applies to nonhazardous industrial solid waste.

Examples of industrial non-hazardous waste may include grinding dust, ash, and sludges. Medical non-hazardous waste may include paper and plastic packaging, cardboard, and office products. Hazardous waste disposal typically costs more than disposing of non-hazardous waste. Accordingly, the proper classification of waste reduces disposal expenses.

However, waste classification is not always straightforward. Waste can be hazardous yet not fall under the same RCRA disposal guidelines. It is also possible for waste to be non-hazardous under the RCRA yet hazardous under stricter state statutes. Some waste, like electronics, may have both hazardous and non-hazardous components.

Laws and Regulations

At the federal level, household, and municipal solid waste are regulated by 40 CFR Part 258. States also have regulations. Consider the State of Illinois as an example. State regulations(35 Ill Adm Code) pertain to landfills and compost facilities. They also address storage/treatment facilities, medical waste, and transfer stations.

Compliance & Enforcement

The U.S. Environmental Protection Agency takes responsibility for non-hazardous waste compliance. So do state EPAs.

GRI 306 Standards

The 300 series of the Global Reporting Initiative pertains to environmental issues. “GRI 306: Waste 2020” establishes waste reporting standards. It is effective for all materials published after January 1, 2022. Sustainability reporting standards guide organizations in reporting their environmental impact and more. GRI 306 is used in conjunction with GRI 101 (Foundation), GRI 103 (Management Approach), and the GRI Standards Glossary.

GRI 306 addresses a wide range of waste-related activities, products, and services. It applies to specific waste sources and waste generated across supply chains. GRI 306 helps an enterprise to understand its responsibility for waste generation better. It also encourages management decisions promoting positive, systemic change.

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