What is a Hazardous Waste?
The Resource Conservation and Recovery Act (RCRA), which was passed in 1976, created the management framework for hazardous and non-hazardous waste. “Solid wastes” are the materials regulated by RCRA and additional regulations apply for hazardous wastes.
Materials that are classified as a hazardous waste must first be considered a solid waste, so the first step in hazardous waste identification is determining if a material meets the criteria. (Note: This can be confusing, because the definition of solid waste does not mean that the waste is always physically solid! It could be liquid, solid, sludge, or a contained gaseous material.) Then, the waste generator should determine whether the waste is specifically excluded from regulation as a solid/hazardous waste. There are wastes that are not considered solid wastes and there are solid wastes that are excluded from the definition of hazardous waste. The exclusions are for a variety of reasons (to provide recycling incentives, not enough information on the material, etc.) and made as a result of an EPA rule or Congressional action. Waste generators will find it helpful to refer to the .
The next step is to determine if the waste is a listed or characteristic waste. If a waste is specifically listed on one of four lists–the F and K Lists (including wastes from common manufacturing and industrial processes and wastes from specific sectors of industry and manufacturing) or the P and U Lists (acute hazardous and hazardous wastes from discarded commercial chemical products)–then it is a hazardous waste. Characteristic wastes are wastes that are considered hazardous due to one of four characteristics: ignitability, corrosivity, reactivity and toxicity.
Proper hazardous waste identification can be one of the most challenging parts of hazardous waste management, and also the most important. TriHaz provides information about listed wastes vs characteristic wastes and exemptions.
What is Universal Waste?
Universal waste is generated in many settings and at many types of facilities. This category of hazardous waste covers materials that are common, such as batteries, mercury-containing equipment, lamps, aerosol cans, and pesticides. The waste is hazardous for at least one constituent, and some may have multiple hazardous constituents such as corrosive liquids (battery acid), toxic metals such as mercury or lead, toxic or hazardous compounds, or ignitable compressed gases. A waste must be a hazardous waste in order to be a universal waste; however, this specific subset of hazardous waste is subject to less stringent management requirements.
Managing Universal Waste
Hazardous waste generators (and handlers) may also choose to manage non-hazardous items as mentioned above (certain types of batteries, lamps (light bulbs), equipment with mercury, and pesticide) as universal waste. Managing an item such as a non-hazardous battery, for example, can reduce the regulatory burden of separating/identifying non-hazardous waste materials from hazardous waste material.
Alabama’s Universal Waste Rule
In Alabama, the Alabama Department of Environmental Management (ADEM) is the agency that enforces hazardous waste regulations, including the universal waste rule and ADEM’s simplified set of standards allow for safe management. The goal is to encourage recycling and reclamation, while avoiding improper disposal for commonly generated wastes. Basically, the universal waste rules allow for simplified packaging/labeling requirements, longer accumulation times, and being able to ship the waste without a hazardous waste manifest. Also, universal waste is not counted against a facility’s hazardous waste generator status.
Tennessee’s Universal Waste Rule
Tennessee’s universal waste management requirements closely mirror federal requirements and are administered by the Tennessee Department of Environment & Conservation (TDEC). In Tennessee, hazardous waste generators may choose to manage non-hazardous items as universal waste.
There are a couple of notable differences between federal and state regulations in Tennessee, specifically, regarding lamp crushers and destination facilities.
- Tennessee permits the use of lamp (bulb) crushers, with strict standards for operators.
- Universal waste destination facilities in Tennessee must pay an annual maintenance hazardous waste fee.
Common hazardous waste problems we solve
Managing Multiple Vendors
When new waste needs surface that your current waste provider doesn’t offer, shuffling multiple vendors and unfamiliar faces in and out of your facility can cause unnecessary disruptions in your medical facility or plant.
Finding Simple Solutions
Since all facilities have unique processes in place, it can make problem-solving more difficult. It’s hard to obtain help with your hazardous waste related problems if you have to call a 1-800 number and speak to a representative you’ve never met and who is unfamiliar with your geographic area.
Long Waste Travel Time
Your facility is responsible for its hazardous waste from the moment it’s generated until disposal. Your facility’s liability increases with every extra mile your waste has to travel.
Get a Quote
We provide custom solution packages for our customers. The best way to learn if we’re the right fit for your waste management needs is to get a quote.
Trusted By Hospitals, Medical Practices and Industries throughout the Southeast