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Air Indoor Resources - Hazardous Waste Management

Environmental Protection Agency (EPA) and Hazardous Waste

For most federal law making, the proposed rules are announced in the Federal Register, a daily publication of the federal government. The regulated community and industries may voice their opinions during a public comment period before rules become final. Environmental rules become effective once codified into the “Code of Federal Regulations (CFRs), Title 40: Protection of Environment,” which consists of 18 volumes containing thousands of pages of environmental regulations.

Congress enacted the first federal waste law under the 1965 Solid Waste Disposal Act. In 1970, the Resource Recovery Act was the precursor to the modern-day hazardous waste rules. At that time, it was apparent that more rulemaking was necessary to encourage proper disposal for household, municipal, commercial, and industrial refuse.

The U.S. Environmental Protection Agency’s (EPA) Office of Solid Waste (OSW) now regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA), Subtitle C, Hazardous Waste Management Program. The RCRA hazardous waste rules were written in 1976 to respond to the problems caused by improper hazardous waste management and amended in 1980 to mandate tracking “cradle to the grave” and remediation of abandoned contaminated sites. The rules were amended again in 1984 to add land disposal restrictions, and in 1986 to address storage tank issues.

Please see RCRA Laws and Regulations for a chronology of RCRA and portals to all RCRA rules.

Today, RCRA’s goal is to protect human health and the environment from the hazards posed by improper waste management and disposal while conserving energy and natural resources to ensure environmentally sound management. Improper disposal is the discharge, dumping, spilling, leaking, or placing of hazardous waste onto land or into water, allowing it to enter the environment or be emitted into the air.

Pollution Prevention (P2) is a vital part of RCRA through the elimination or reduction of waste generation from the source through process changes, substitution of less toxic alternatives, reuse, and recycling, as well as more efficient work practices. Simply revising work practices can help you avoid costly fines and liabilities, minimize risk, save energy, and substantially reduce pollutants going into our environment.

The EPA is the primary authority to control hazardous waste generation, storage, transportation, and disposal (TSD). The RCRA regulations are designed to track the waste from “cradle to the grave,” or from the point of generation to its ultimate disposal site. The regulations call for copious waste tracking, registered transports, permitted disposal facilities, and regulatory oversight and inspections.

The following steps outline a systematic approach to understanding the RCRA hazardous waste rules:

  1. Common School Wastes;
  2. Waste Evaluation and Generator Size Determination;
  3. Application for EPA Identification Number;
  4. Appropriate Container with Label;
  5. Proper Storage and Accumulation Time;
  6. Transport of Hazardous Waste;
  7. Disposal Manifests and Shipment of Hazardous Waste;
  8. Emergency Response, Personnel Training, and Recordkeeping; and
  9. Inspections, Enforcement, and Supplemental Environmental Projects.

Before a facility manager can begin to comply with the above-mentioned steps, a records review and physical walk-through of the facility is required to determine the kinds of waste that are generated on-site. The facility manager should prepare a waste inventory through purchasing records, interviews with production and maintenance personnel, and inspection of the working areas that should include storage areas and dumpsters.

Contact Information

Wendy Murphy
325 West Gaines Street
Suite, 1054
Tallahassee, FL 32399
Phone: (850) 245-9295