Increased population and demand for chemical-based products and technological devices come attached to a need for determining hazardous waste disposal methods. Unfortunately, wastewater treatment, toxic chemicals, and elements used in manufactured goods are not always safe to handle, transport, store, dispose of, or recycle. That’s largely why the federal government crafted laws and empowered agencies to protect community members and the environment.
The Resource Conservation and Recovery Act (RCRA) provided the U.S. Environmental Agency (EPA) the regulatory and oversight authority necessary to ensure public safety. But the powers vested by the hazardous waste management act cannot necessarily overcome accidents and human error. By understanding how the RCRA and EPA approach hazardous material safety, it’s abundantly clear that workers need on-demand access to personal protective equipment and disposable clothing.
What is the RCRA Hazardous Waste Act?
It’s essential to understand the RCRA was enacted to further health, safety, and environmental goals. The hazardous waste management act was initially presented as an amendment to the Solid Waste Disposal Act of 1965. The Solid Waste act set national objectives that included the following.
- Protecting everyday people from health risks associated with hazardous waste.
- Protecting the natural environment from waste disposal hazards.
- Conserve energy and natural resources.
- Minimize the volume of hazardous waste through recycling processing.
- Reduce the amount of unnecessary waste produced.
- Put forward guidelines for sound waste management processes.
In 1986, the RCRA emerged as a joint venture between federal and state governments, with the EPA spearheading oversight and rulemaking. The RCRA now stands as the most recognized rule declaring body regarding hazardous waste treatment, storage, recycling, and disposal.
Ranked among its primary health and safety success is the so-called “Cradle to Grave” regulations. The RCRA empowers the EPA to regulate hazardous waste materials from point of origin through its entire use and disposal process. The hazardous waste management act involves oversight during production, transportation, storage, usage, and manner of disposal. At each point of the process, industry professionals, the general public, and the environment would be at heightened risk without RCRA and EPA regulations and oversight.
What is a Hazardous Waste “Generator”?
The RCRA defines a “generator” as the first link in a hazardous waste system that may have points of contact with wide-reaching industries. The hazardous waste management act requires producers to consider whether the materials they create or alter fall under the regulatory guidelines, definitions, and hazardous waste lists.
If the items present a health, safety, or environmental risk at some point in the supply chain, the generator assumes responsibility. Hazardous waste generators are tasked with clearly identifying and documenting the material to ensure it receives proper safety considerations and disposal treatment. The RCRA publishes methods for distinguishing hazardous from non-hazardous items.
Empowered by the hazardous waste management act, the EPA produces regulations, procedures, and lists for generators to identify hazardous materials. The EPA groups generators into the following categories:
- Very Small Quantity Generators: This class of generators is determined by exceedingly low production of hazardous and acutely hazardous waste. The thresholds stand at 100 kilograms or fewer, or one kilogram or less of acutely hazardous material per month. Under hazardous waste management act guidelines, these generators must not accumulate in excess of 1,000 kilograms and may only deliver the material to an authorized facility.
- Small Quantity Generators: This class of generators can produce over 100 kilograms but never more than 1,000 kilograms in a single month. Stringent guidelines indicate generators require a permit when storing hazardous materials for longer than 180 days and never exceed 6,000 kilograms. These businesses must demonstrate safety preparedness and an ability to effectively respond to emergencies.
- Large Quantity Generators: Organizations that generate 1,000 kilograms, or more than one kilogram of acutely hazardous waste in a month fall into this category. Other regulations driven by the hazardous waste management act involve waste accumulations not exceeding 90 days. They must employ hazardous waste disposal methods and demonstrate safety preparedness.
The determined oversight by the EPA under the RCRA puts workplaces under a microscope regarding hazardous waste management. What’s crucial to keep in mind is that regulatory oversight is not just an abstract set of rules. The guidelines instituted by the hazardous waste management act are designed to keep working people and the community out of harm’s way. That’s largely why the emphasis on disposable, personal protective clothing and equipment remains essential.
How Does the EPA Determine What Constitutes Hazardous Waste?
The EPA recognizes that distinguishing the difference between common waste and the hazardous variety can prove challenging. To help waste generators with any confusion, the agency created a regulatory process based on objective criteria. Although identifying hazardous waste tends to be somewhat complicated, the EPA tasks waste producers with applying the following questions.
Is the material considered a solid waste?
Examples of solid waste materials typically involve items such as garbage or sludge generated from a wastewater treatment facility, among others. Material that has been discarded from industries such as agriculture, mining, and manufacturing, often meets the criteria for solid waste as well. The regulatory definition of solid waste remains quite broad. If the material involves the following, it may meet the solid waste standard.
- The material was abandoned, discarded, burned, or improperly recycled.
- Poses some level of risk to people, wildlife, or the environment.
- Items such as expended military munitions are routinely considered solid waste, among other wide-reaching examples.
- Is the material excluded from the solid or hazardous waste definition?
The lengthy list of materials that enjoy an exemption may run contrary to commonsense. For example, spent sulfuric acid, domestic sewage, and radioactive waste rank among the seemingly dangerous items on the EPA’s solid waste exemption list. Excluding them does not necessarily mean they do not pose a significant health risk to workers. The EPA publishes an extensive list of solid materials that are exempt under the Code of Federal Regulations (CFR) at 40 CFR section 261.4(a).
Is the material considered hazardous waste?
It’s entirely possible for a material to fall under a solid waste exemption and remain highly dangerous to humans and the environment. For example, materials that possess a hazardous and radioactive element may be considered mixed waste. Such materials are usually regulated through the RCRA, as well as the Atomic Energy Act. The EPA identifies what is hazardous by determining whether the material possesses attributes that involve the following.
The regulatory agency also publishes definitive lists of materials considered hazardous to help generators better identify qualifying waste. The so-called “F, K, P, and U lists” can be found within the subsections of 40 CFR section 261.
Has the material been previously delisted?
The RCRA offers a petition process that involves reconsidering and declassifying a material deemed hazardous. Rather than apply broad strokes regulations to industries and organizations that produce certain types of waste, a generator can appeal. Petitioners generally must demonstrate their waste does not present hazards generally included in its class. In terms of workplace safety, employees should operate under the assumption the typically hazardous materials remain dangerous to their health unless proven otherwise.
What are Proper Hazardous Waste Management Steps?
Best practices regarding hazardous waste disposal methods revolve around placement in the supply chain and anticipated health and environmental risks at each juncture. In many ways, the EPA’s signature Cradle to Grave thought leadership provides guidance for supervisors and boots-on-the-ground workers regarding safety. Along with hazardous waste generators, Cradle to Grave rules includes the following.
- Hazardous Waste Transportation: The transportation sector often moves hazardous materials to destinations where they are recycled, treated, and disposed of based on hazardous waste management act regulations. The U.S. Department of Transportation also regulates hazardous waste in conjunction with the EPA. The Federal Motor Carrier Safety Administration (FMCSA) publishes requirements regarding transport, communication, and packaging, among others.
- Treatment, Storage, and Disposal Facilities:These facilities comprise the cradle to grave infrastructure necessary to manage hazardous materials safely. Federal and state agencies set standards for safe handling and storage. It’s critical to note that the frontlines workers who ensure proper waste management remain at heightened risk. Businesses involved in hazardous waste management are tasked with maintaining a complete inventory of PPE that includes disposable protective clothing.
- Hazardous Waste Recycling: Recycling poses perhaps the greatest health and safety threat to workers. Materials are often housed in temporary storage units that can spill on working people. Leaking hazards can also impact employees who unknowingly inhale airborne particles or vapors. In some cases, hazardous chemicals and other agents can ignite and cause a fire.
Although the RCRA empowers the EPA and other organizations to provide oversight and enforce safety regulations, workplace incidents remain problematic. Accidents and resulting injuries are often caused by human error, and no government body can change reality. That’s why it’s essential hazardous materials workers, and those on the periphery need access to certified PPE and disposable protective clothing.
What PPE is Needed When Interacting with Hazardous Waste?
Determining the best PPE and disposable clothing options is largely driven by the type of hazardous material in play. Common sense dictates that workers dealing with liquid waste and chemical agents must have splash-resistant disposable clothing at all times. What’s also important to keep in mind is that waste generators in the cradle-to-grave supply chain match the correct PPE to the danger and maintain a reliable inventory.
If your organization handles hazardous waste materials, International Enviroguard produces a complete inventory of disposable protective clothing and accessories that can protect workers throughout the cradle to grave process of hazardous waste management. From toxic chemicals to flames, bodily fluids, sewage, residual radioactive particles, noxious particulates, and more, International Enviroguard is here to keep workers safe from exposure to hazardous waste and materials.