Every October Pinnacle Environmental Services, Inc. provides free RCRA/DOT training at the Madren Center on the campus of Clemson University. Participants receive required and certified training regarding the disposal, handling, and transportation of hazardous waste.

If your company produces hazardous waste RCRA/DOT requires specific training for employees. Employees learn the proper way to manage and dispose of hazardous waste. Improper disposal or mismanagement of hazardous waste can result in huge fines. The free training provided by Pinnacle Environmental Services, Inc. is designed primarily for EHS managers, chemical site managers, and plant engineers.

Attendees learn vital information such as:
● Proper labeling for shipping hazardous waste drums
● How long you can keep waste in a warehouse
● DOT label requirements
● What size of a generator is your company/business
● Waste inspections

Attendees receive a free buffet lunch and certificate upon completion of the one-day training event. Pinnacle Environmental Services is a non hazardous and hazardous waste consulting firm specializing in the disposal and transportation of industrial waste. We focus on waste elimination/minimization, sustainability, zero-landfill and converting waste to energy. The 2020 date to be announced soon!

Mike Watts, President
Pinnacle Environmental Services, Inc.

If you’re a business owner, your top priority is to make a profit. You do that by making quality products and then finding and retaining customers. You focus on getting the best price for quality materials as well as production efficiencies to control your costs. That’s all as it should be, but how much consideration do you give to the waste you generate? If any of your waste is considered hazardous under Federal and State regulations, then mishandling or improper disposal can result in massive fines and penalties that can quickly wipe out profits.

If you generate solid waste, you’re required to determine if it is hazardous. A solid waste is defined as a solid, liquid or gaseous material that is discarded by disposal, burning or recycling. Your waste is considered hazardous if it contains items on any of four lists (F, K, P and U) published by the Environmental Protection Agency (EPA) in 40 CFR Part 261. Waste materials that make these lists are known to be harmful to human health and the environment when improperly managed.

Waste materials that are most hazardous make the P-List (acutely hazardous) or the U-List (toxic). There are six hazard codes for wastes that make these lists:

Hazard Code Hazard
I Ignitability Characteristic
C Corrosivity Characteristic
R Reactivity Characteristic
E Toxicity Characteristic
H Acutely Hazardous
T Toxic

Once you’ve determined that you are generating hazardous waste, you need to calculate your Generator Category by measuring the amount of hazardous waste you generate in each calendar month:

  • 220 pounds—Very Small Quantity Generator (VSQG)
  • 220 to 2,200 pounds—Small Quantity Generator (SQG)
  • 2,200 pounds—Large Quantity Generator (LQG)

If your business is an SQG or LQG, you must obtain and use an EPA Identification Number. The annual registration fee you’ll pay is based on the maximum amount generated in any month of the previous year, not a monthly average.

Accumulating hazardous waste at your production facility can be a danger to human health and the environment so it should be kept on-site only for a short time—unless you obtain a permit. SQGs can accumulate no more than 13,228 pounds of hazardous waste on site for up to 180 days without a permit. LQGs can store greater amounts but must meet strict storage requirements and follow stringent requirements for emergency equipment testing and maintenance, with access to communications or alarms. Employees must be thoroughly trained on proper waste handling and emergency procedures.

Most hazardous waste cannot be disposed on land unless it meets treatment standards to reduce the hazardous components to levels set by the EPA. When hazardous waste is removed from the production site, it must be properly contained to ensure safe transport, correctly labeled and accompanied by a hazardous waste manifest. The hazardous waste manifest tracks hazardous waste from its generation to its ultimate disposal and must be maintained on file to document compliance.

In August 2016, the EPA increased the maximum penalties for certain violations of EPA regulations and environmental law. These higher penalties can be retroactively applied to violations that occurred as far back as November 2015. For many offences, fines doubled or even tripled. Disposing of hazardous waste in the wrong way and hoping you won’t get caught is not a viable business plan. The fines from even a single violation could easily bankrupt your company.

If you have doubts about your company’s compliance with current law, it just makes good financial sense to talk to Pinnacle Environmental Services. Not only will you keep your employees, and the environment, safe from hazardous waste materials, but it also makes good fiscal sense.

At Pinnacle Environmental Services, we have the expertise to handle hazardous waste. Our Total Waste Management Program will ensure the proper handling and disposal of all waste materials generated by your company. We can help with on-site training for your management and production staff to keep you in compliance with all regulations. If you’re looking for help and you’re not yet a client, contact us for a Waste Analysis Study. Our experts will meet with you, survey your operations and present a cost-effective, customized waste management plan.

What comes to mind when you think of hazardous waste generators? You’re probably picturing evil corporations dumping enormous, disintegrating, cylindrical drums filled with oozing green goo thrown haphazardly (pun intended) into a dilapidated, ramshackle part of town while the CEO’s and board members dive into their personal vaults of gold and jewels, Scrooge McDuck style. As fun as it would be to imagine such an obviously nefarious company practice, the reality is a little less “black and white”, and a lot more “gray”. There are actually many regulatory committees and laws in place to monitor the production of hazardous waste as well as the disposal of such materials. In fact, hazardous waste generators are grouped into three different categories depending on how much waste they produce in a given month. The three different categories, as established by the EPA, are Conditionally Exempt Small Quantity Generators (CESQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs). Now take a sip of your coffee, because detailed descriptions of all three of these are down below. So let’s get started!

The first category is Conditionally Exempt Small Quantity Generators (CESQGs). This group generates 100 Kilograms or less per month of hazardous waste, or one Kilogram or less per month of acutely hazardous waste (epa.gov). To those who are unfamiliar with the differentiation between the two waste characterizations, hazardous waste is waste with properties that make it potentially dangerous or harmful to human health or the environment. Acutely hazardous waste, on the other hand, is specific to any kind of hazardous waste with a waste code beginning with the letter “P” or any state-only hazardous waste with a waste code beginning with the letters “P”, “ORP”, or any of the following “F” codes; F020, F021, F022, F023, F026, and F027. CESQGs must identify all hazardous waste generated, may not accumulate more than 1,000 kilograms of hazardous waste at any time, and must ensure that hazardous waste is delivered to a person or facility who is authorized to manage it (epa.gov).

The next category of hazardous waste generators is Small Quantity Generators (SQGs). This group generates more than 100 Kilograms, but less than 1,000 kilograms of hazardous waste per month (epa.gov). I hope you refilled your coffee, because this next part gets a little convoluted. There are several major requirements for SQGs and they include the ability to accumulate hazardous waste on-site for 180 days without a permit (or 270 days if shipping a distance greater than 200 miles), complying with the Hazardous Waste Manifest and pre-transport requirements at 40 CFR part 262, subpart B and 40 CFR262.30 through 265.33, managing hazardous waste in tanks or containers (subject to the requirements found at 40 CFR 265.201 and 40 CFR part 265 subpart I except for 40 CFR 265.176 and 265.178, respectively), complying with the preparedness and prevention requirements at 40 CFR part 256 subpart C, and the land disposal restriction requirements at 40 CFR part 268, and they must also keep the quantity of hazardous waste on-site below the 6,000 Kilogram point at all times (epa.gov). By the way, for those of you playing the home game, CFR is the Code of Federal Regulations that these companies must adhere to in regards to their hazardous waste production. Different than the CESQGs, SQGs have to have one employee available on site to respond to an emergency. As you may have guessed, this employee is responsible for coordinating all emergency response measure, though he or she is not required to have a detailed, written contingency plan (epa.gov).

We’re coming into the proverbial home-stretch now, and the last category for hazardous waste generators is Large Quantity Generators (LQGs). LQGs generate 1,000 Kilograms per month or more of hazardous waste or more than one Kilogram per month of acutely hazardous waste (epa.gov). As with the other two categories, there are several restrictions, but given how much waste those in the group produce, their restrictions are far more limiting. LQG’s are only allowed to accumulate waste on-site for 90 days (though certain exceptions apply), but they don’t have a limit as to the amount of hazardous waste they can accumulate in those 90 days. The hazardous waste they generate must be managed in tanks, containers, drip pads, or containment building subject to the requirements found at 40 CFR part 265, subpart J, I, W, and DD, respectively. LQGs must comply with the hazardous waste manifest and pre-transport requirements at 40 CFR part 262 subpart B and 40 CFR 262.30 through 265.33, and also with the preparedness and prevention requirements at 40 CFR part 265 subpart C, the contingency plan and emergency procedures at 40 CFR par 265 subpart D, and the land disposal restriction requirements at 40 CFR part 268 (epa.gov). LQGs are also required to submit a biennial hazardous waste report.

As you can see, there are many stipulations and requirements for any company that generates hazardous waste. In fact, the Resource Conservation and Recovery Act allows individual states to impose their own laws and regulations for waste management programs. However the states will only gain approval from the EPA if it is “substantially equivalent to, consistent with, and is no less stringent than the federal program” (enviro.blr.com). They may even impose stricter laws than the federal requirements, but the company must follow whichever is the more rigorous of the two. The most important aspect of these restrictions is the proper monitoring and cataloging of hazardous waste that is deemed detrimental to the environment and the living beings that are a part of it. So it may not be as cut and dry as the fable told at the top of the page, but dividing up the hazardous waste generators into the aforementioned groups (CESQGs, SQGs, and LQGs) is a step in the right direction, and a push for a more sustainable and cleaner future.

Today’s business world is changing at a rate unimagined even a generation ago. Business leaders are adapting to new marketing channels—via the web and social media. New technologies are changing the way materials are transported and the way products are created and sold. The world is your market place—but that greatly increases the competition you face for market share. As a CEO or business manager, it can be overwhelming trying to keep up with these rapid changes that have such profound impacts on your business decisions. That’s why you hire personnel who possess the skills and expertise to address these challenges in ways that will grow your market share.

Another one of those rapidly changing details pertains to Hazardous Waste. It’s not a glamorous topic, but it can have a profoundly negative impact on your company’s growth, market share and reputation if you don’t stay on top of things. Take a look at these five reminders and consider how well your company complies with Federal, State and Local Regulations.

First Reminder—Never Dump Illegally

This may seem obvious, but many companies, large and small, take tremendous risks to save the cost of proper disposal in the hopes they won’t get caught. Illegal dumping on public or private property, dumping waste into waterways or municipal sewer systems or even dumping on your own property without having the proper license can result in crippling fines, restitution and remediation expenses and embarrassing publicity. Depending on the severity, illegal dumping can be punished as a felony that may include incarceration.

Second Reminder—Properly Label and Date Hazardous Waste Containers

In the busy process of your production environment, it’s easy to forget this seemingly trivial task. As a generator of Hazardous Waste, your waste containers must indicate the accumulation dates as well as the date of the first addition to the container. The container must be clearly labeled with the words “Hazardous Waste.” Proper training and assigning responsibility to a specific employee goes a long way towards complying with this requirement. Document your training policies, provide (and document) refresher training at least annually or as new procedures go into effect. Ensure your hazardous waste containers meet applicable safety requirements and are compliant with regulations through a regular inspection program, keeping logs of these inspections that include the inspector’s full name, date and time and any problems noted.

Third Reminder—Keep Hazardous Waste Containers Closed

Hazardous Waste Containers that are open or in poor condition will guarantee a regulatory violation. Under the EPA standards, “closed” means leak proof and vapor tight. The Agency may consider leaving the lids off of your hazardous waste containers as a “treatment” since the volume of hazardous waste may be reduced by evaporation. Post notices in the areas where hazardous waste accumulates and provide regular reminders to your employees, especially if you have high employee turnover rates at your facility.

Fourth Reminder—Maintain a Current Contingency Plan

If you’re a Large Quantity Generator of hazardous waste, you must create a contingency plan that covers all potential emergencies and the proper coordinated response pertaining to hazardous waste. Your plan must contain emergency contact information (name, address and phone number) for key managers and must be posted at an on-site phone. You must update the plan when significant changes occur at your facility and local authorities should receive a copy as well. Annual reviews and updates will help ensure you keep current on regulatory changes as well as your own operational changes. Include contingency plan training as part of all relevant new hire orientations.

Fifth Reminder—Document Disposition of Hazardous Waste

It’s not sufficient to comply with all of the regulatory details concerning the collection of hazardous wastes at your facility. You must also document the proper disposal of all the hazardous waste you collect. Your hazardous waste transporter should be using a manifest system that acknowledges their acceptance of the hazardous waste from your facility. You are responsible for maintaining copies of the final manifest to document your compliance with disposal requirements.After that quick review, how are you feeling about your company’s hazardous waste program? Do you feel confident that your company is in full compliance? Or did these reminders trigger a need to reexamine your program? Remember, these five reminders only cover the basics. There are many other details pertaining to Hazardous Waste Management and Disposal that will be subject to inspection. We hope these five reminders will provide a starting point for a total review of your Hazardous Waste Program.

Do you need help managing your facility’s waste? Contact Pinnacle Environmental Services, Inc. We provide a Total Waste Management Program that is customized for each of our clients. We have the expertise and training that gives you peace of mind, confident we’ll keep you in compliance with all Federal, State and Local Regulations. We’re eager to earn your business!