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Hazardous Waste Management
What is Hazardous Waste?
A waste is something that is no longer useful; it's used up or contaminated. Hazardous wastes are corrosives, ignitables, oxidizers or toxins listed in the State Rules. Here is a partial list of some common wastes that may be hazardous:
- Dry cleaning wastes
- Electroplating waste
- Ink waste
- Paint, thinner and related material
- Photographic waste
- Rags with solvent/ink/paint
- Residues or sludges
- Stripper waste
- Solvents/degreaser
- Used batteries
- Used oil and related wastes
- Wastes containing toxic metals
You are required to figure out if your wastes are hazardous - a process called evaluation. You can use the Material Safety Data sheet supplied with your product, thinking about your process and any contamination that could occur or send a sample to a testing laboratory.
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Does My Business Generate it?
Businesses generate waste, some of it may be hazardous. These businesses could generate hazardous waste:
- Auto Body shops
- Dry cleaners
- Electronics shops
- Electroplaters
- Furniture refinishers
- Government
- Laboratories
- Manufacturers
- Medical/Dental offices
- Metal fabricators/machine shops
- Photography studios
- Printers/graphic artists
- Schools/universities
- Vehicle repair shops
This is just a partial listing. If your business type is not listed, you still need to evaluate your waste.
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Waste Evaluations: Exempt Wastes
Wastes are non-hazardous, exempt or hazardous. First, figure out if your waste is exempt. If it is, your hazardous waste evaluation is complete! Remember, wastes that are exempt may still be regulated by another program.
A list of exempt wastes appears below.
- normal household refuse;
- non - household refuse (paper, cardboard, plastics);
- samples sent to a testing laboratory;
- recycled scrap metal;
- demolition debris;
- hazardous waste that is generated in tanks, pipelines or transport vehicles until it leaves the unit;
- waste discharged to surface waters under a National Pollution Discharge Elimination System (NPDES) permit;
- mining overburden and certain wastes from processing ores;
- fly ash and related wastes from burning fossil fuel;
- waste from emergency spill cleanups approved by the MPCA commissioner; and
- certain wastes containing chromium III.
If your waste wasn't exempt answer the following questions.
- Is it a listed waste?
- Is it a characteristic waste?
- Does it contain more than 50 parts per million (ppm) PCBs?
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Waste Evaluations: Listed Wastes
These wastes are found on specific lists in the Minn. R. pt. 7045.0135. These wastes are defined by the Rules as hazardous wastes. Some common examples appear below.
- 'F' listed wastes are from non-specific processes. Typical ones include solvents or mixtures of solvents, like trichloroethylene, methylene chloride, toluene, methyl ethyl ketone or xylene. The Material Safety Data Sheet (MSDS) can identify the types of solvents that are used in your product. Other 'F' listed wastes include distillation bottoms, wastewaters, or spent baths and solutions.
- 'K' listed wastes are from specific processes such as wood preserving, petroleum refining, metal smelting, or the formulation of certain products.
- 'P' and 'U' listed wastes are discarded, commercial chemical products, off-spec products, containers, and spill residues. 'P' listed wastes are acutely toxic.
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Waste Evaluations: Characteristic Wastes
These wastes have a physical property that makes them hazardous. A complete definition of these can be found in Minn. R. pt. 7045.0131.
- Ignitable wastes are generally liquids with a flashpoint of 140 degrees Fahrenheit or less. Mineral spirits is a good example.
- Oxidizing wastes contribute oxygen to a fire. They may be chemicals whose names begin with per, have ate in the name, or end with oxide.
- Corrosive wastes have a pH of less than or equal to 2 (strong acids) or greater than or equal to 12.5 (strong bases). A common example is a lead acid battery.
- Reactive wastes react violently with air or water, release toxic vapors, like sulfide or cyanide bearing wastes, or are shock sensitive.
- Toxic wastes are certain metals, pesticides or herbicides, and volatiles or semi-volatile organics. When tested in a laboratory, the wastes release these compounds above certain limits.
- Lethal wastes cause death when ingested, inhaled or absorbed.
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Waste Evaluations: PCB Wastes
The final waste to evaluate are PCBs above 50 parts per million. Examples of PCB wastes include capacitors in older appliances, oil from older utility transformers and many old fluorescent lamp ballasts. Unless the ballasts are labeled as NOT containing PCBs, you need to test them or manage them as a hazardous waste.
If you generate hazardous waste, you have some basic requirements. The following information is provided as an overview and is not intended to be comprehensive. You can view the Hazardous Waste Rules in their entirety at the MPCA's website.
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Getting Licensed
With very few exceptions, all generators of hazardous waste must get an EPA ID # and a hazardous waste license from Ramsey County. Call 651.266.1199 to request a license packet or AskEH. This is TIME SENSITIVE. You must have your hazardous waste license within 75 days of first generating the waste.
To get your license, figure out your business' generator size. Look at the storage and accumulation limits listed below for help. Add up the hazardous waste you generate in a calendar month; don't count nonhazardous or exempt wastes or used oils and related materials.
Send the license application to the address at the top of the form. After we process it, you will receive an invoice for your license fees. You have thirty days to pay it. After that, we will send you your hazardous waste license.
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Container Management
Storage and accumulation limits for generators
Very Small Quantity Generators (VSQG)
- Generates 100 kg* or less of waste per month (less than 1/2 drum).
- Can accumulate 1,000 kg (or about 4 drums) on-site. If a generator exceeds this limit, waste must be managed according to Small Quantity Generator guidelines.
- Can store less than 1,000 kg indefinitely. Once 1,000 kg is accumulated, waste must be shipped off-site within 180 days.
Small Quantity Generator (SQG)
- Generates between 100 kg* and 1,000 kg of waste per month (about 1/2 to 4 drums).
- Can accumulate 3,000 kg (or about 12 drums) of waste on-site. If a generator exceeds this limit, waste must be managed according to Large Quantity Generator guidelines.
- Waste must be shipped off-site within 180 days after the waste was first placed in the container.
Large Quantity Generator (LQG)
- Generate 1,000 kg or more of waste per month (more than 4 drums)
- No limit on how much waste can be accumulated on-site.
- Waste must be shipped off-site within 90 days after the waste was first placed in the container.
*100 kg (kilograms) is approximately 220 pounds or 22 gallons
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Indoor Storage of Hazardous Waste
- The container must be compatible with the waste, sturdy and leak proof.
- Keep it closed, unless adding or removing the waste.
- Maintain adequate aisle space between containers and other objects.
- Inspect the containers weekly and document it.
- Keep incompatible hazardous wastes separated.
- Do not exceed the time and quantity storage limits.
- Store wastes on an impermeable surface.
Outdoor Storage of Hazardous Waste
The same requirements as indoor, plus:
- Shade ignitable wastes from direct sunlight.
- Protect wastes from unauthorized access and moisture.
- Store free liquids on a curbed, impermeable surface.
While being accumulated, label the containers:
- With the words "HAZARDOUS WASTE"
- Clear description of the waste
- Accumulation start date (the date you first put waste in the container)
Before transporting the waste, mark the container:
- DOT Hazard labels
- DOT Shipping name and ID number
- Company name and address
- EPA ID number
- Manifest document number
- The words "Hazardous Waste - Federal Law Prohibits Improper disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency"
Click here for tips on container management.
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Waste Disposal
Selecting a hazardous waste transporter
Hazardous waste generators are responsible for their wastes from "cradle to grave". Think about these things when you are choosing your transporter.
- Figure out what you need. You should know types and amounts of waste, types of waste containers, how often you will ship, and the location of the destination facility.
- Look at the list the MPCA has compiled of transporters to narrow your selection
- Research your transporter. Hire a transporter with a good reputation and working knowledge of the Hazardous Waste Rules. Select a few companies and ask them detailed, specific questions. Proper permits or registrations, driver training, container markings and labels, waste loading procedures, placarding and manifesting requirements are all areas that responsible companies are familiar with.
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Choosing a Hazardous Waste Facility
Your company is ultimately responsible for its hazardous waste, so give careful consideration to the facility you will use. If at all possible, have someone visit the facility to look at their waste handling procedures. If you can't visit, contact the facility's regulatory agency to an inspector.
Lastly, talk to the facility's representative. Ask them questions about their waste acceptance policies, timelines for shipments, waste handling and management practices, and safety records.
Click here for tips on waste disposal.
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Manifesting Shipments of Hazardous Waste
A manifest is a specialized shipping document. With a few exceptions, it accompanies all shipments of hazardous waste. It provides documentation of shipment and disposal – a “cradle to grave” record of what happened to your waste - from the time it left your site until it reaches its final destination. Tracking your hazardous waste ensures that the waste is managed properly.
Instructions for filling out manifests are provided with the manifest. Even if your transporter or facility fills in the information for you, it is your company’s responsibility to make sure that everything is accurate.
Your transporter will leave you with copies of the manifest. Keep one copy onsite for a minimum of three years.
Within 5 days of shipment, you must mail a copy of your manifest: Large Quantity Generator (LQG) and a Small Quantity Generator (SQG) to MPCA and Very Small Quantity Generators (VSQG) to the Hazardous Waste Manifest Program. If your facility is located outside of Minnesota, send one copy to that state’s regulatory agency, if required.
You should receive a copy back from the facility within 35 days of shipment. Make a copy of this and mail it to the appropriate agency. If you don't get a copy back, call the facility about your shipment. Notify the MPCA if you don't have a copy from the facility in 45 days.
Click here for tips on manifesting shipments of waste.
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Emergency Planning and Response
You are required have procedures in place which minimize accidents or spils. Specific emergency planning requirements are based on generator size.
Emergency equipment (all generators)
The following items must be available on-site:
- Communications devices - internal and external.
- Portable fire protection or water supply.
- Spill control equipment.
- Decontamination equipment.
Preventive Measures (all generators)
These are required for all generators:
- Closed containers.
- Adequate aisle space for inspections and easy passage of emergency equipment.
- Wastes stored on an impermeable surface (sealed or diked floor drains).
- Weekly container inspections.
Emergency Response (all generators)
If a spill occurs:
- Evaluate the situation and respond accordingly.
- If feasible, contain and clean up the spill.
- Report the spill immediately if it causes pollution of the air, land or water resources of the state.
- CALL THE STATE DUTY OFFICER (24 HOURS) 651.649.5451
Telephone Posting (SQG)
Post the following information next to a phone that could be used in an emergency:
- Emergency Coordinator's name and phone number.
- Location of the emergency equipment.
- Fire department's phone number.
Local Authority Notice (SQG/LQG)
Notify the local emergency respondersabout:
- Types and amounts of hazardous waste on-site.
- Building layout, including evacuation routes, exits and wastes storage areas.
Emergency Coordinator (SQG/LQG)
Appoint an emergency coordinator (and alternate) who is:
- On-site.
- On call.
- Responsible for oversight.
Contingency Planning (LQG)
Emergency planning and prevention for Large Quantity Generators is more comprehensive than for other generators. Plans must include:
- Emergency response plan.
- Documented arrangements with local authorities.
- Emergency coordinator information.
- Emergency equipment list.
- Evacuation plans.
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Personnel Training
Very Small Quantity Generators - Employees must be familiar enough with waste handling procedures and proper emergency response to maintain compliance.
Small Quantity Generators - Must train their employees in the hazardous waste and emergency response duties that are relevant to their jobs. This training must occur one time and be documented.
Large Quantity Generators - Training requirements for LQG's are much more comprehensive. They include:
- having a designated hazardous waste program coordinator;
- keeping records listing job titles, job descriptions, and job requirements;
- outline or description of the contents of the course;
- training new employees within 6 months of hiring;
- annual refresher training;
- maintaining documentation on all hazardous waste training.
Keeping Records
You business is required to keep records regarding you hazardous waste generation. These records must be kept on-site and be available for inspection.
Required Records - Keep these records for at least 3 years
- Initial license applications and license renewal application;
- Manifests and/or manifest exception reports;
- Analytical and other test data;
- Weekly inspection logs;
- Receipts for used oil and used oil filters;
- Shipping papers or a log showing the recycling of 75% of the lead acid batteries generated in one year;
- Receipts or shipping papers for sorbents, universal wastes, wastes taken to a VSQG collection site;
- Training documents (kept for 3 years from the last day the employee works for you);
- Feedstock or byproduct documentation;
- Land disposal restriction notification forms.
Recommendation Records
- Documentation showing how you determined a potentially hazardous waste to be non-hazardous;
- Correspondence regarding your hazardous wastes;
- Telephone log of calls regarding hazardous waste management;
- Certificates of Destruction or Recycling;
- Spill or clean up records.
Click here for tips on record keeping.
AskEH or call 651.266.1199 with any questions that you might have.
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