• RCRA Hazardous waste
  • Characteristics of hazardous waste
  • Sources of hazardous waste
  • Disposal of hazardous waste
  • Industrial waste management system
  • Industrial waste disposal methods
  • EPA hazardous waste regulations 40 CFR
  • What is considered EPA RCRA Hazardous waste
  • RCRA Regulations
  • Industrial waste management laws and regulations

How much industrial waste is produced each year?

It's difficult to come up with a concrete figure. Some estimate that more than 7.5 billion tons of industrial waste are produced each year. Others believe that this number is quite a bit lower. Whichever way you slice it, one thing is true: distributors and manufacturers generate a lot of waste - and this waste must be disposed of properly to protect workers, material handlers and the environment. Failure to do so isn't just likely to result in hefty fines and other penalties from regulating agencies, but significant environmental and health consequences to boot.

In this post, we'll cover everything you need to know about industrial waste disposal - from who governs and regulates it to what the current regulations are and more. Read on to learn more.

How Manufacturing Waste is Regulated

Let's start with the governing and regulating bodies for manufacturing and industrial waste. It probably doesn't surprise you to learn that the big player in this realm is the Environmental Protection Agency (EPA).

In 1984, Congress passed the land disposal restrictions (LDR) program as part of the Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA). The primary goal of the LDR and the RSRA is simply to protect human health and the environment from hazardous waste. Essentially, the LDR program helped put guidelines in place to ensure that waste is treated properly prior to its disposal, which helps protect the groundwater and other critical parts of the environmental ecosystem.

We'll get into some of the key prohibitions of the LDR program a bit later on in this post. In the next section, we'll discuss more about hazardous waste versus non-hazardous waste.

Hazardous vs. Non-Hazardous Waste: What You Need to Know

How do you know what's considered hazardous waste and what's not? Generally speaking, toxic or hazardous waste is defined by the following:

  • Materials that are flammable, explosive and/or pyrotechnic.
  • Materials identified as hazardous per the Secretary of Defense or the Department of Defense.
  • Materials defined as such per Section 101 of the Comprehensive Environmental Response, Compensation and Liability Act of 1980.

Some examples of hazardous waste include solvents, spent acids, spent bases, metal finishing waste, wastewater treatment sludge, leachate and more.

In order to determine what's hazardous and what's not, any manufacturer should first and foremost be familiar with the EPA's definition of the matter. But a good rule of thumb to follow to make the determination is just to know whether or not the waste that's being disposed of is dangerous. For instance, general construction debris and commercial trash aren't considered hazardous. But if what's being discarded could be potentially seen as hazardous to the environment, then it likely needs to be discarded more responsibly. It's also worth noting that some waste could become hazardous as a byproduct of the manufacturing process.

The 3 Prohibitions for Hazardous Waste Generators

According to the LDR program, there are three prohibitions that prevent manufacturers that generate hazardous waste from discarding waste that may be damaging to the environment. It's important to note that LDRs don't apply to hazardous waste from households or from "small quantity generators." Waste that's also sent to Clean Water Act pretreatment and treatment systems is also exempt. The LDR program specifically applies to generators of hazardous waste and firms that either store or dispose of hazardous waste (otherwise known as "waste handlers"). The three key prohibitions are disposal, dilution and storage. Read more on them below:

Disposal Prohibition

This is the most basic of LDR treatment standards and essentially just requires treatment standards to be met before any waste can be disposed of. There are many methods of treating hazardous waste, and they can be found in the Code of Federal Regulations (CFR). Upon accessing the CFR, users will be presented with a table featuring four columns, which helps identify hazardous waste codes, describes the waste and identifies how the waste must be treated before it can be disposed of. In order to be disposed of, the hazardous waste must meet or exceed the concentrations identified in the CFR and meet the specific method of treatment.

Characteristic wastes include those that are ignitable, corrosive, reactive and toxic. For example, ignitable wastes are required to be treated via combustion, recovery or organic or polymerization. Corrosive wastes are commonly treated by the deactivation and treatment of underlying hazardous constituents (UHCs) or high-level radioactive waste vitrification. The CFR has more specific information on how to treat hazardous waste for disposal.

Dilution Prohibition

One might think that in order to make hazardous waste non-hazardous, it can simply be diluted by adding the likes of water, soil or non-hazardous materials as a means of phasing out the hazardous components. This is not the case. In fact, dilution alone does not reduce the danger that's present in hazardous waste and is not permitted per the LDR program in order to avoid meeting a treatment standard. Per the disposal prohibition, treatment methods are designed to either destroy, remove or permanently immobilize hazardous waste. More information can be found in the CFR on the dilution prohibition, but the bottom line is that dilution should never be considered a substitute for treatment.

Storage Prohibition

Lastly, the storage prohibition states that manufacturing companies cannot store hazardous waste indefinitely. Many firms may just be content with hanging onto any hazardous waste either for a certain period of time or even indefinitely to avoid properly treating it for disposal. The LDR program does not allow this.

While companies are allowed to temporarily store hazardous waste at their manufacturing sites, it should only be for the purpose of accumulating enough so that treatment and/or disposal becomes more convenient. Storage of hazardous materials could pose a health and safety threat to workers in a particular facility, especially if the facility is not designed to store such waste for elongated periods of time.

The bottom line is that firms are not allowed to just stockpile hazardous waste on-site. They're only allowed to temporarily until enough accumulates to achieve a sufficient volume for proper treatment, recovery and/or disposal. If the storage of the waste exceeds one year, the firm may have to provide proof that such storage is necessary for proper volume accumulation. This prohibition is also found in the CFR.

It's worth noting that there are various record-keeping requirements that manufacturing firms must also keep and submit to prove their compliance with the LDR program. While these requirements can also be found in the CFR, they consist largely of the proper notifications, certifications and waste analysis to validate compliance.

As you can see, industrial waste disposal is highly regulated. It's also a complex process that requires various requirements to be met - and for good reason. Failure to do so could result in significant environmental and health consequences. It's never a bad time to review the standards and guidelines outlined in the LDR program to ensure that your firm is disposing of hazardous waste properly and responsibly.

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