When it comes to matters of environmental pollution, the words “toxic” and “hazardous” are used interchangeably. The word “toxic” simply means “poisonous”, and by implication, poisons are harmful to life and health and anything that is harmful is said to be hazardous.
In most developed countries, businesses and institutions are required by federal and state laws to determine if the waste materials they generate are toxic waste.
Accurate waste determinations are the first step in ensuring safe management of toxic wastes. Failure to properly identify a toxic waste may result in damage to human and environmental health, while accurate waste determinations have the potential to reduce management and disposal costs.
Based on regulatory requirements, records of all waste determinations conducted on solid wastes must be maintained, regardless of whether the outcome of the determination is positive or negative.
Read Also : Waste Management Terms and their Meanings
The records associated with the waste determinations must be maintained and available during compliance inspections.
However, there are solid waste streams that do not require a waste determination and they include wastes not having the potential to be a toxic waste. Examples include food waste and office-generated paper wastes.
Waste Determination Process
There are five principal steps in the waste determination process:
Identify the waste streams: Make a list of all facility waste streams and include how the waste is generated.
Determine whether the waste stream is a solid waste: Check to see if each waste meets the definition of “solid waste”.
Determine if the solid waste is excluded from regulation.
Determine whether the solid waste is a hazardous waste.
Document the information in steps 1-4: Compile the information used to make the waste determination, including a statement on whether the waste is a hazardous waste.
If it is hazardous waste, list the applicable waste codes and what the generation rate of this waste is per month. Knowing your waste generation rates will help in determining the correct generator status and applicable regulations for your facility.
Written documentation is a required step in the hazardous waste determination process. These documents must be kept as part of your recordkeeping requirements.
In the United States, small quantity generators (SQGs), large quantity generators (LQGs), storage and disposal (TSD) facilities are required to document and retain their hazardous waste determinations.
The Department of Natural Resources (DNR) and U.S. Environmental Protection Agency (EPA) strongly recommend that very small quantity generators (VSQGs) also retain these documents.
However, if no documentation is available during a facility inspection, both the DNR and the EPA can require a generator to perform a waste determination to support the facility findings that a waste of concern is not a hazardous waste.