Upon completion of this unit, students should be able to:

1. Identify the primary laws that govern hazardous waste operations and discuss how they are applied in workplace situations.

2. Identify hazardous wastes using the EPA-defined characteristics of ignitibility, corrosivity, reactivity, and toxicity.

3. Identify hazardous wastes using the EPA F, K, P, and U lists.

4. Define universal wastes and describe the requirements for handling them.

5. Define the various categories of hazardous waste generators and explain the regulatory requirements that apply to each.

6. Describe the precautions for the safe handling of hazardous waste.

7. Identify and explain strategies for waste minimization.

8. Identify the considerations for selecting hazardous waste transporters and treatment storage and disposal facilities (TSDF).

9. Discuss the process and options available for the remediation of contaminated hazardous waste sites.

Reading Assignment

Forward: pp. iv-vii

Chapter 1:

Hazardous Waste

EPA Listed Wastes, 40 CFR 261.31-33: http://www.epa.gov/epa waste/hazard/wastetypes/listed.htm

Unit Lesson

BOS 3125, Hazardous Materials Management

5

 (NARA, 2011a)

Here we are, ready to start a course titled “Hazardous Materials Management,” but the first course unit and first chapter in the book are titled “Hazardous Waste.” What’s that about? Isn’t hazardous waste at the end of the lifecycle and more appropriate for the end of the course? Besides, safety practitioners aren’t responsible for hazardous waste; that’s an environmental thing, right?

In order to manage hazardous materials in the workplace effectively, we need to start with the end in mind; that is, what happens to the material when we are done with it. The Resource Conservation and Recovery Act (RCRA) of 1976 introduced us to the cradle to grave” concept of hazardous materials management by focusing efforts on the final disposal of hazardous substances (Haight, 2012). The improper disposal of industrial waste over many decades had created enormous health and environmental issues, as well as a nearly insurmountable cleanup problem.

The Environmental Protection Agency (EPA) has created regulations for the cleanup of contaminated waste sites, but more importantly, has forced industries to think about the materials they use, how they are stored and handled, and how they are to be discarded when no longer needed. The escalating cost of the disposal of hazardous wastes in accordance with EPA rules has caused many industries to change to materials that are less hazardous or change processes so that hazardous materials are no longer needed. Recycling and reuse of hazardous materials has become more cost-effective than disposal. One of the goals of RCRA is to prevent

future problems caused by irresponsible waste management (Haight, 2012). This goal is being achieved by managing the full lifecycle of hazardous materials.

Safety practitioners are most often concerned with OSHA regulations and the effects of hazardous materials on the workers, and they might feel that compliance with EPA regulations belongs to someone else. Some organizations do have a separate environmental compliance office, and other organizations choose to combine the “safety” and “environmental” functions. Regardless of how the responsibilities are divided, the safety practitioner must be familiar with EPA rules and regulations, since they are central to the decisions made regarding hazardous materials in the workplace. Over the years, the OSHA/EPA connection has become even closer, with OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) and the Hazard Communication Standard. It is interesting to note that RCRA predates both of these OSHA standards.

The core of RCRA is the identification of hazardous wastes. The first determination is whether or not a material is a solid waste. Anything that is discarded is considered a solid waste, but not all solid wastes are hazardous. A solid waste is designated as hazardous if it is listed in one of the four RCRA

Environmental technicians secure the lid of a hazardous material container. (Barstow, 2008)

hazardous waste code lists (F, K, P, and U). If the material is not listed, it can still be classified as hazardous

if it exhibits one or more of the criteria of ignitibility, corrosivity, reactivity, and toxicity. There are really very few industrial wastes that will not fall into one of the above categories. (Graphic below is on page 6 of the textbook.)

Producers of hazardous waste are called “generators.” Hazardous waste generators must determine what category applies to them: Small quantity generator, large quantity generator, or conditionally exempt small quantity generator. The determination requires a comprehensive inventory of all hazardous materials in use and an understanding of the waste streams produced. The inventory is often the same one used by safety practitioners to comply with OSHA standards; again we see the connection.

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