By Dan Scungio, MT (ASCP), SLS, CQA (ASQ) bio
In the past, if a laboratory or a facility generated less than 220 pounds (or 100 kilograms) of hazardous (chemical) waste each month, it was designated by the Environmental Protection Agency (EPA) as a Very Small Quantity Generator of waste (or VSQG). In order to remove the hazardous waste from such a site, a contracted waste vendor is typically hired. They pick up the waste material from a designated location, perhaps a hazardous materials shed, and they place it on their truck to be taken to a hazardous material disposal facility. Sometimes those facilities are in other states. These waste removal vendors usually charge their customers for transportation to the site and for the number of barrels of waste filled and removed.
Because of the final implementation this year of the Hazardous Waste Generator Improvements Rule signed by the EPA administrator, some flexibility has been added to the waste process described above. Under the new rule, the EPA will allow a VSQG site to move its own waste to another affiliated Large Quantity Generator site provided the waste is under the control of the same generator during the transport process. That can save facilities money. For example, if a clinic laboratory at a small facility sends its waste to an associated large hospital, all of the waste can be picked up from one location. Waste vendors will only charge one transportation fee instead of two. If multiple small locations move their waste to one facility, more savings could be realized.
The Resource Conservation and Recovery Act (RCRA) regulations were published in 1980 by the EPA. In the past few years, the organization has conducted formal evaluations, and the agency decided to make changes in order to increase clarity, consistency, and flexibility for waste generators and handlers. A proposed revised rule was published in the Federal Register in 2015, and the final rule became effective in May of 2017 at the federal level. Four states that do not have their own hazardous waste program implemented the changes right away, but the remaining U.S. states and territories had until July 1, 2018 to adopt the rule.
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Some other changes to the waste regulations include a reorganization for clarity and ease of use. Clarification is given to acute hazardous waste classifications and instructions for biennial report submissions that are filled out by LQG sites. There are edits to the regulations that help with environmental protection, such as emergency response procedure guidance and updated container labeling requirements.
One regulatory improvement includes flexibility for sites that may generate different amounts of hazardous wastes every month. Under the current rules, a Small Quantity Generator (SQG) site is that which produces between 220 and 2200 pounds (or 100 to 1000 kilograms) of waste each month. If a SQG site generates over 2200 pounds of waste in one month out of the year, that site must change its designation to a Large Quantity Generator (LQG) for the entire year, even if that overage occurs just once during the year. That change in designation costs money, and it involves several other changes for the lab or facility including container labeling, recordkeeping, and the requirement for an emergency plan. Once the new regulations are in effect, the EPA will allow a monthly waste overage, provided it is a temporary increase, without forcing the facility through the waste designation status change.
The regulations for handling hazardous waste are complex, but managing such waste is a vital part of the overall laboratory safety program. A solid understanding and compliance with the regulations provide cost savings, environmental protection, and improved employee safety. Help your staff understand the rules, and study the upcoming changes for your state so that you can remain both compliant with the laws and so that waste management safety continues to prevail.