July 27, 2018

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Kevin Webber
How to Create an EPA Waste Profile
TriHaz-How-to-Build-EPA-Waste-Profile

An EPA Hazardous Waste Profile is similar to the typical Material Safety Data Sheets (MSDS) that you’re used to working with at any industrial or manufacturing facility. In short, the Hazardous Waste Profile is used to describe the chemical and material characteristics of a given type of solid or hazardous waste.

Why Are EPA Hazardous Waste Profiles Important?

With so many duties already on your plate, you may be wondering: Why are hazardous waste profiles so important, and why are all regulated waste generators required to create them?

These profiles are a critical part of the solid and hazardous waste management process because they provide a verified, codified reference for anybody coming into contact with those waste streams—whether an employee, a representative from your waste disposal provider, or even an unsuspecting member of the community.

Additionally, EPA hazardous waste profiles allow your chosen Treatment, Storage and Disposal Facilities (TSDFs) to accurately determine whether (or how) they can accept and process your waste stream products. The profiles also help you comply with EPA regulations and other Resource Conservation and Recovery Act (RCRA) stipulations, since hazardous waste profiles contain much of the information you’d already be required to report under those legal frameworks.

Depending on your specific facility’s activities, you may be subject to both the RCRA’s waste analysis requirements for waste generators and TSDFs, and the waste generator requirements targeted specifically at large and small quantity generators (LQGs and SQGs).

Since you’re responsible for all regulated waste generated by your facility “from cradle to grave,” EPA waste profiles are a critical tool for managing, tracking and documenting that activity.

But how do you create an EPA waste profile and what information should be included in one?

How to Create an EPA Waste Profile

These are the steps you’ll need to follow when creating an EPA waste profile for each type of regulated or hazardous waste in your facility.

1. Identify the Hazardous Waste

Waste is classified as hazardous or non-hazardous according to a complex set of parameters, material characteristics and evaluative methods.

In most cases, generating facilities are best served by following five key steps to identifying hazardous waste.

These steps are used to determine whether the waste:

  • Is a solid waste
  • Is excluded waste
  • Is an officially Listed hazardous waste
  • Exhibits hazardous characteristics
  • Is made non-hazardous by mixture or derivation rules

2. Determine if the Waste is Excluded

In some cases, solid waste that is included on an EPA List for hazardous waste is re-classified as non-hazardous due to its source, usage or other exclusionary characteristics.

Relevant regulations have carved out a wide variety of exceptions for specific use cases and even specific industries. Unsurprisingly, the criterion for determining whether a given waste stream or material is excluded can be complex and often arbitrary, so it’s always best to consult a knowledgeable TSDF partner who can help you navigate the parameters when assessing your waste streams.

3. Determine the Monthly Quantity of Generated Waste

Relevant law has created three separate categories for waste generators, depending on the quantity of regulated or hazardous waste produced.

Specific classification parameters for Small Quantity Generators (SQGs), Large Quantity Generators (LQGs) and Conditionally Exempt Small Quantity Generators (CESQG) are covered in CFR §261.5, and as part of that framework, you’re required to report on the quantity of waste your facility generates each month. Accordingly, it’s important to work with your partnered TSDF to ensure you’re accurately evaluating and documenting the exact quantity of waste produced by your facility.

4. Ensure All Required Information is Documented

Both the TSDF you partner with and your local or state governments require documentation to fully understand the parameters and characteristics of your waste streams.

An experienced TSDF should already have a waste profile documentation process for you to follow, usually consisting of simple forms to fill out for various types of waste. However, your state or local governments may also have waste profile sheets like Alabama’s, in which case you’ll need to incorporate those documentation procedures into your waste management process.

Such forms typically include information related to:

  • The chemical composition of your hazardous waste
  • The flash point of any chemicals in the waste
  • The physical state of the waste (liquid, solid, etc.)
  • A description of the waste-generating process
  • Relevant EPA waste codes
  • Estimated annual quantities

5. Keep Hard Copies of All Relevant Information

Once you’ve established a compliant regulated waste management process, the bulk of the work required to maintain it centers around documentation and other hard copy information. Accordingly, it’s vital to keep those records on-hand at all times, including all hazardous waste profiles, forms for and required by your TSDF, and any records required by the state or local government.

Additional Considerations for Creating an EPA Waste Profile

If you’re ever uncertain about whether a given product or waste stream contains regulated hazardous materials, work with your TSDF to make the determination. A properly qualified waste management provider should be able to perform or arrange a full lab analysis, which will identify each chemical constituent of the waste to make that determination.

Additionally, your waste profiles may change over time—either because you’re using new substances or simply because legal requirements have changed. For that reason, it’s vital to update your profiles whenever necessary, and you should work with your TSDF to conduct a thorough audit of all waste profiles at least once per year.

Once you’ve partnered with a fully certified and experienced TSDF, you can work with them to ensure you’ve created waste profiles that will protect your workers and community, along with keeping your facility legally compliant when managing hazardous waste.

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