RCRA HazWaste Management Plan

(Click here for a Fact Sheet on E-Manifests as used by inspectors.)

In 1976, President Gerald Ford signed into law the Resource Conservation and Recovery Act (RCRA), to be overseen by the U.S. EPA. This was a means for controlling pollution to the environment – air, soil and water – often caused by the generation, mismanagement and improper disposal of hazardous waste material by Industry in the U.S. RCRA is a "cradle to grave" system for managing hazardous waste. Driven by 750 hazardous waste codes, RCRA provides specific requirements for the generation, accumulation, storage, packaging, transportation and disposal of hazardous waste. RCRA also imposes strict training regulations for employees concerning exposure to, handling of, and accidents involving hazardous wastes. Hazardous waste is highly regulated in the U.S., from the time it is created through industrial processes until it is neutralized or finds its final place at a treatment, storage and disposal facility (TSDF). The entire cycle or life span of any hazardous waste is documented by tracking system (called "manifests"), all of which is controlled and enforced at federal, state (primarily) and local levels.

Biennial Waste Reporting

In most states, Biennial Waste Reporting is mandated for those facilities designated as "Large Quantity Generators" (LQG). An LQG is defined as a facility that, in any given month of the calendar year, generates 2,200 lbs. (1,000 kg) or more of RCRA Hazardous Waste (Note: this is a minimum of about FOUR 55-gallon drums); or 2.2 lbs. (1 kg) or more of RCRA Acute Hazardous Waste; or 220 lbs. (220 kg) or more of Spill Cleanup Material Contaminated with RCRA Acute Hazardous Waste. In addition to submitting a Biennial Waste Report with the U.S. EPA, facilities are also required to submit the same report to the state in which the facility is located. Generally, the Biennial Waste Report is required by March 1 on even-numbered years for the previous two calendar years.

Annual and Quarterly Hazardous Waste Reporting

Many states require Annual and/or Quarterly Hazardous Waste Reporting, as well as Hazardous Waste Stream Notification by Texas and Illinois. Annual Waste Reporting must be completed by each Small Quantity Generator (SQG) and Large Quantity Generator (LQG) (where applicable) of RCRA Hazardous Waste or industrial solid waste. In most states, the Annual Report is required by January 25 on an annual basis for the previous calendar year, although the deadline is deferred to March 1 if the report is filed electronically. Annual and Quarterly Hazardous Waste Reporting certifies that (during the quarter of record) all Hazardous Waste generated was accurately described by a proper shipping name, classified, packed, marked, labeled and placed in proper condition for transport by highway according to applicable international and national government regulations, including regulations mandated by the State of Record. Most states usually require that Quarterly Reports be submitted no later than sixty (60) days after the end of the Quarter of Record.

RCRA Hazardous Waste Training

The RCRA HazWaste Training Program is a training component encompassing all pertinent issues to hazardous waste generation in the workplace. The training is an outgrowth of the facility’s comprehensive management of its hazardous waste as regulated by RCRA, a free-standing law under the U.S. EPA.

The RCRA HazWaste Ttraining program differs from the OSHA 8-hour HAZWOPER Refresher in that its thrust is specific to the onsite day-to-day management, accident prevention and proper procedure for spill/release cleanup of just those products and chemicals generated in the facility’s hazardous waste disposal program. [OSHA’s HAZWOPER training is focused on emergency response pursuant to far-reaching hazardous waste incidents]. This training program is limited in scope for those facilities designated as either Small Quantity Generators (SQGs) or Very Small Quantity Generators (VSQGs).

RCRA HazWaste Testimonial

We rarely see the regulators because they ”know” we are doing what is required because Vanguard is here.- Spa Mfr./St. Petersburg, FL