WHY SHOULD I CARE ABOUT HAZARDOUS WASTE?
As a business owner, operator or employee, you may be
producing Materials that can harm people and the environment.
This booklet offers helpful tips on how to:
Comply with federal and state hazardous waste regulations.
Avoid penalties by properly managing hazardous wastes.
Save money on disposal costs by reducing hazardous wastes.
Health and Environment
Hazardous wastes spilled or dumped on the ground or disposed of in dumpsters may seep into the groundwater and contaminate drinking water supplies. Hazardous
wastes may run off into the nearest body of water where they may poison or kill
fish and other . Hazardous wastes pose a health risk to you, your employees and
State and county inspectors may visit your business to ensure that
hazardous wastes are being managed properly. State
penalties may range from $100 to $50,000 per violation per day. Reducing hazardous wastes can reduce your production and disposal
costs and reduce Your liability risk.
Your customers will appreciate your efforts to prevent pollution.
Your community will recognize your business as a good neighbor.
WHAT IS A HAZARDOUS WASTE?
A waste is hazardous if:
It has any of the characteristics described below.
It is listed as a hazardous waste in the Code of Federal
Regulations, 40 CFR Part 261.
Ignitable wastes are easily combustible or flammable. If they have a flashpoint of less than 140 F or an alcohol content of 24% or more, they are hazardous wastes.
Examples include some paints, paint solvents, other solvents and degreasers.
Corrosive wastes corrode metals or other materials or burn the skin. These liquids have a pH of 2 or lower or 12.5 or higher. Examples
include rust removers, acid or alkaline fluids and battery acid.
Reactive wastes are unstable and react rapidly or violently with
water or other materials. Examples include bleaches, oxidizers, cyanides and explosives, such
as sodium azide and dynamite.
Wastes are toxic if they contain certain heavy metals, such as
chromium, lead or cadmium, or toxic organic chemicals. Examples include some
parts cleaners, chromium-bearing paints and spray booth filters.
A waste is hazardous if it is listed in the Code of
Federal Regulations, 40 CFR Part 261. For
details on listed wastes and waste code numbers, contact the Florida
Department of Environmental Protection. The Code of Federal Regulations is
available at most libraries or may be purchased from The U.S. Government
Bookstore (phone (904) 353-0569).
ACUTELY HAZARDOUS WASTES
Small amounts of very dangerous wastes, such as arsenic
and cyanide compounds, are regulated in the same way as large amounts of
other wastes. A business that
generates 2.2 pounds (1 kilogram) or more of these wastes per month is
subject to full regulation under the hazardous waste rules.
IDENTIFYING YOUR HAZARDOUS WASTES
It is very important to determine whether a waste is
hazardous or non-hazardous. There
are several ways to identify hazardous wastes.
Obtain and read Material Safety Data Sheets (MSDS).
Talk to product suppliers and manufacturers.
Read product labels.
Compare product and process information to hazardous waste
characteristics and to wastes listed in federal regulations.
If product or process information is not available or is
inconclusive, have a commercial lab sample and test the waste using the TCLP test.
A non-hazardous material or product may become a hazardous
waste due to contaminants added during use. Lab testing may be necessary.
SOURCES OF HAZARDOUS WASTE
Gelcoat and Resin Applications
Gelcoat, which is about 35% styrene, and other resins are a primary source of hazardous wastes in the form of excess gelcoat and resin. Resin wastes can
be minimized with equipment that has greater transfer efficiency. Reducing waste saves money and makes cleanup easier.
Some of the most common solvents used for cleaning equipment, hands
and resins are hazardous. Examples
include acetone, mineral spirits, paint/lacquer thinners and solvent distillation bottoms from solvent recovery units.
Hazardous solid wastes may include un-solidified resins, excess putty
and adhesives that have not hardened solvent distillation bottoms from solvent recovery units, spray booth filters and solvent-contaminated towels, wipes and rags.
Rags contaminated with used oil or solvents may be a hazardous waste. If your shop washes rags, water must be discharged to a publicly owned sanitary sewer,
not a storm sewer, septic tank or cesspool. If
you use a towel service; make sure the company discharges its water to a publicly owned sewer system. Disposable rags or
paper towels used with hazardous substances should be disposed of as hazardous wastes.
They should not be disposed of in a dumpster.
TYPICAL HAZARDOUS WASTES
- A primary component of gelcoat and other polyester resins.
- Flash point: 90 F.
- Corrodes copper.
- Affects the central nervous system, lungs, and skin.
Ethyl Ketone Peroxide (MEKP)
- May be explosive.
- Flash point: 185 F.
- May react strongly with other substances. Refer
- Incompatible with very strong oxidizers, acids, bases.
- Skin and nose irritant. Can cause blindness.
- Affects lungs and central nervous system.
- Flash point: 0 F.
- Incompatible with acids and oxidizers.
- Irritant for
eyes, nose, throat and skin.
- Central nervous system depressant.
- Acetone Substitutes
- Various high flash point
- acetone substitutes are available, such as
propylene carbonate and dibasic ester (DBE).
- However, the spent material may be ignitable due to mixture with ignitable resins and gelcoats.
- If you change your process to use an acetone substitute, waste should be tested prior to
HOW SHOULD I MANAGE HAZARDOUS WASTES?
First, determine how much hazardous waste you generate
each month. The rules you must follow
depend on how much you generate, how much you store, and how long you store
Less than 220 pounds (100 kilograms or about half a drum): you
are a ?Conditionally Exempt Small Quantity Generator.?
220 ? 2,200 pounds (100 ? 1,000 kilograms or about half a
drum to 5 drums): you are a ?Small Quantity Generator.?
More than 2,200 pounds (1,000 kilograms or more than about 5
drums): you are a ?Large Quantity Generator.?
Maintain containers in good condition. Prevent leaks, ruptures and accumulation of rainwater on tops of
If a container leaks, transfer waste to a new container.
Keep containers closed and use self-closing funnels when
Wastes must be compatible with the container. For example, use HDPE plastic containers for corrosive wastes.
Never place incompatible wastes, such as wastes that react
with each other (acids and bases), in the same container.
Maintain adequate aisle space between container rows to allow
inspection for leaks and damage.
Store ignitable and reactive wastes at least 50 feet from
Store containers of incompatible wastes in separate areas.
Be aware of allowable time limits for storage.
Label every container with the type of waste and whether it is
hazardous or non-hazardous.
Include federal waste code numbers.
Include the accumulation start date (the date when waste was
first placed in the drum).
Include you business?s name and address.
Use the following words on labels for hazardous wastes:
FEDERAL LAW PROHIBITS IMPROPER DISPOSAL
If found, please contact the nearest police or public
safety authority of the U.S. EPA
Transport and Disposal
Inspections and Record Keeping
Inspect containers at least once a week and keep a written log
of container inspections.
Keep training and inspection records for 3 years.
Keep manifests and shipping receipts for 3 years.
Keep records of lab tests for 3 years.
Keep land disposal restriction forms for 5 years.
Train all employees to identify, reduce and properly handle
Train new employees before they handle hazardous wastes.
HOW CAN I REDUCE HAZARDOUS WASTES?
Reducing hazardous wastes in your shop makes good
business sense. Benefits
Saving money on waste management costs.
Reducing concerns about penalties and liability.
Creating a safer, healthier workplace.
How Do I Begin?
Make a commitment to reducing wastes in every area of your
Evaluate your shop?s wastes and identify areas where changes
can be made.
Encourage the participation of all employees through
education, training and incentives.
Reduce solvent waste by replacing solvent only when necessary.
Replace organic solvents with emulsifiers.
Replace acetone and other solvents with non-hazardous
solvents, such as propylene carbonate, or less hazardous solvents, such as
dibasic ester (DBE).
Recycle solvent wastes on-site in a distillation unit and
Reduce solvent rinse usage by using squeegees to remove excess
Use a two-stage cleaning process (dirty solvent followed by
clean rinse) to reduce solvent usage.
Reduce resin waste by using flow cutters, airless sprayers and
Consider using non-spray resin application methods.
Reduce over spray by changing spray orientation.
Replace high-pressure air systems with airless or air-assisted
equipment to reduce fogging, over spray and Bounce back.
Prevent contamination of resin buckets.
Minimize inventory and use a ?first-in, first-out? system
to prevent the need for disposal of old, unused materials.
Store raw materials and wastes in closed containers in a
covered area protected from rain and sunlight.
Use drip trays under solvent storage drums.
Prevent leaks and spills. Keep floors clean.
Use the least hazardous type of floor cleaner available.
For dirty rags, use an approved laundry service that
discharges its water to a publicly owned sewer system.
Do not discharge wastes to the ground surface. Plug floor drains.
WHO NEEDS TO KNOW IF MY BUSINESS GENERATES HAZARDOUS WASTES?
Notify Your DEP
Notify Local Authorities
Designate an Emergency Coordinator
Develop a Contingency Plan
Guidance on contingency plans is available from DEP. Large quantity generators must have a written plan that includes:
Emergency response arrangements with police, fire, hospitals
and emergency response contractors.
Emergency coordinators? addresses and phone numbers.
On-site emergency equipment descriptions and locations.
Evacuation plan and routes, including a site diagram.
Post the following information near every telephone:
- Fire department phone number
- Emergency coordinator?s name and phone number
- Locations of fire alarms and extinguishers
- Locations of spill control materials
This checklist will help you to prevent the most common
hazardous waste violations. For more detailed information on hazardous waste
management requirements, contact DEP.
Identify types and quantities of hazardous wastes.
Determine how much hazardous waste is generated.
Notify Florida DEP and obtain an EPA identification number
Use proper containers to collect and store wastes.
Label all containers as hazardous or non-hazardous wastes.
Include accumulation start dates on labels.
Keep containers of hazardous waste closed.
Maintain aisle space between containers for inspection.
Inspect containers weekly for rust, leaks or damage.
Train employees to properly handle hazardous wastes.
Designate an emergency coordinator.
Notify police, hospitals and fire department.
Post-emergency information near each phone.
Develop a contingency plan for emergencies.
Use manifests for all waste transported for disposal.
Keep all records for at least 3 years.
WHERE CAN I GET MORE INFORMATION?
The EPA has published a series of industry-specific
guidelines and handbooks on preventing pollution and complying with
hazardous waste regulations.
Phone: (800) 424-9346
Your Trade Associations
Many trade associations have published guides to help
you find solutions to your hazardous waste management problems.