“Cradle-to-Grave”: Regulating Hazardous Waste From Generation to Disposal and Every Step In-Between

Published On: August 9, 2022

The Resource Conservation and Recovery Act of 1976 (RCRA) is the overarching federal management regime for the disposal of hazardous waste. This act dictates the different classifications of waste, such as hazardous, municipal, and industrial (non-hazardous), as well as the management requirements associated with each classification. It can be daunting to navigate which classification you fall under and your management requirements.

The first step is to identify if the waste you are producing is hazardous. Hazardous wastes are those than can be harmful or detrimental to human health and pollute land or water resources. Hazardous wastes are either specifically listed in RCRA or display certain characteristics. The listed wastes have specific codes that coincide with specific waste properties. You may be able to identify these properties and the code that applies to your waste based on the materials and processes that generated the waste. If your waste is not listed, it can be tested to see if it displays the defining characteristics: ignitability, corrosivity, reactivity, and toxicity.  of a waste sample collected at the time of generation can determine if it displays any of the defining characteristics or help you determine which code your waste is listed under. It is important to properly classify your waste to ensure correct methods are used to dispose of it safely and efficiently.

If you find that your waste is indeed hazardous, the next step is to determine what quantity generation category you fall under. There are three RCRA waste generator classifications: Very Small Quantity Generator, Small Quantity Generator, and Large Quantity Generator. Each classification must abide by different tracking, training, and disposal regulations.

Very Small Quantity Generators produce no more than 220 pounds of hazardous waste per calendar month. They must dispose of their waste at a state-approved or RCRA-permitted facility and can store up to 2,200 pounds of waste on-site.

Small Quantity generators produce between 220 and 2,200 pounds of hazardous waste per month. Waste manifest records are required to track the type and quantity of hazardous waste shipped from the site. Waste can only be disposed at RCRA-permitted facilities. This classification requires generators to have basic emergency procedures and personnel training regarding the hazardous waste. They can store up to 13,228 pounds of waste on-site at one time and must obtain an EPA identification number. This identification number is site-specific and permanent.

Finally, Large Quantity Generators produce more than 2,200 pounds of waste. They are allowed to accumulate any amount of waste for up to 90 days on-site before disposal and can only dispose of the waste at a RCRA-permitted facility. Waste manifests for all shipments are required and the site must have an EPA identification number. These generators must have a formal contingency plan which is an action plan if any incident regarding the hazardous waste were to occur. They are also required to have full emergency procedures and personnel training on site. Finally, this generator will have to complete biennial reports which summarizes the amount of waste produced as well as where it was shipped.

After classifying your hazardous waste and determining your quantity generator category, the next step is to make sure that you fulfill and abide by all the regulations that apply to you and turn in all your reports on time. If any changes occur in your business or production that could affect your waste generation, refer back to step one to ensure that your hazardous waste is classified correctly and managed safely from cradle to grave.









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