6.3 Hazardous Waste Management

These guidelines provide information about hazardous waste management. They identify the different types of hazardous wastes and how to reduce, store, and dispose of hazardous wastes. These guidelines do not replace regulations from local regulatory agencies; they are general references that supplement these regulations.

6.3.1 Overview

Hazardous waste is generated by nearly all industrial activities. Improperly managed hazardous waste causes expensive and often irreversible environmental problems. Responsible hazardous waste management can help minimize these problems.

A hazardous waste is any hazardous solid, liquid, or contained gaseous material that is (1) no longer suitable for its intended use, (2) not recyclable, (3) going to be thrown away, or (4) stored until enough material has accumulated for treatment or disposal. Waste is considered hazardous if it:

Causes injury, illness, or death.
Damages or pollutes the land, air, or water.

For regulatory purposes in the United States, hazardous wastes are sorted into two categories:

Listed hazardous wastes
Characteristic hazardous wastes

6.3.2 Listed Hazardous Wastes

Listed hazardous wastes are associated with specific process operations. Listed hazardous wastes include, but are not limited to, the following:

Many spent halogenated solvents, such as Freon, perchloroethylene (perc), and mixtures of these solvents used as cleaners and degreasers.
Many other waste cleaners, such as acetone, methyl ethyl ketone (MEK), methyl alcohol, toluene, and xylene.
Wastes derived from products that contain, before use, a total of 10 percent or more (by volume) of individual solvents or solvent mixtures or blends.
Many out-of-date commercial products, such as formaldehyde, lead compounds, mercury compounds, and many pesticides. This category includes more than 200 chemicals.
Certain pesticide wastes.
Any residue or contaminated soil, water, or other debris from the cleanup of a spill into or on any land or water, or any residues that are federally listed hazardous wastes.

6.3.3 Characteristic Hazardous Wastes

Characteristic hazardous wastes exhibit certain properties that make them harmful to human health or the environment. These properties are:

Ignitability. A liquid is considered ignitable if it has a flash point below 140°F (49°C). A solid is considered ignitable if it can spontaneously catch fire and burn so persistently that it presents a hazard.
Corrosivity. Any water-based waste having a pH of 2 or less or of 12.5 or greater is considered corrosive.
Reactivity. Unstable or explosive wastes that react violently when brought into contact with water are considered reactive.
Toxicity. Wastes that release certain amounts of toxic metals, solvents, or other materials when subjected to a specific laboratory procedure are known as toxicity characteristic (TC) wastes.

6.3.4 Excluded Waste

Some solid wastes are excluded from regulation as hazardous wastes even though they may possess characteristics of hazardous waste. The exclusion depends on the type of material and the method of management. Below is a partial listing of the most common wastes that are generally excluded from hazardous waste regulations:

Household hazardous waste
Intact and used lead-acid batteries that are destined for off-site recycling
Waste oil that has not been mixed with a hazardous waste (such as a solvent) and will be properly recycled or used for energy recovery
Residue in empty containers

6.3.5 Types of Hazardous Waste Produced

Any Church operation or affiliated business may generate hazardous waste. The following is a list of hazardous wastes commonly produced by Church operations.

Type of Operation	Type of Hazardous Waste Produced
Construction	Acids and bases (cleaners, etching wastes) Ignitable wastes (waste paint, paint sludge) Solvents (degreasers, thinners)
Carpentry	Acids and bases (cleaning solutions) Ignitable washes (cleaning solutions) Reactive solvents (degreasers, paint solvents)
Equipment repair and maintenance	Acids and bases (cleaning solutions) Heavy metals (antifreeze, oils) Ignitable wastes (paint sludge, thinners) Solvents (degreasers, cleaners)
Laboratories	Acids and bases (cleaning solutions, lab reagents) Heavy metals (lab waste, reagents) Ignitable waste (cleaning solutions) Reactive waste (lab reagents) Solvents (lab reagents, cleaners)
Printing	Acids and bases (plate-etching solutions) Heavy metals (waste inks, sludge, plating waste) Solvents (cleaning solutions, fountain solutions, blanket washes)
Vehicle maintenance and auto body work	Acids and bases (hot tank waste, lead-acid batteries) Heavy metals (hot tank waste, antifreeze) Ignitable wastes (waste paints, paint sludge, thinners) Solvents (degreasers, cleaners)
Custodial	Acids and bases (boiler treatment chemicals, cleaning solutions) Solvents (cleaning solutions)
Farming	Acids and bases (cleaning solutions) Ignitable wastes (cleaning solutions, waste paints, paint sludge, thinners) Solvents (cleaning solutions) Pesticides and herbicides

6.3.6 Hazardous Waste Generators

For all Church operations, it is the responsibility of those generating waste to determine if the waste is hazardous. Many people do not think their operations generate hazardous waste because they do not involve an industrial or manufacturing process. However, hazardous waste may be generated when:

A material, such as a solvent, has been used and is spent.
A stored material has exceeded its shelf life, is no longer usable, and must be discarded.

For example, maintenance activities will not generate the types of hazardous waste commonly associated with an industrial process. But they may generate hazardous waste in the form of discarded paints and solvents or other materials and thus would be classified as hazardous waste generators.

In the United States, hazardous waste generators fall into the following three categories depending on the amount of waste generated in one month or the amount of waste stored on the site at any one time.

1. Conditionally Exempt Small-Quantity Generator (CEG)

The following amounts are generated in one calendar month:

1 kg (2.2 lb) or less of acute hazardous waste
100 kg (220 lb) or less of hazardous waste
100 kg (220 lb) or less of spill cleanup debris containing hazardous waste

Or the following amount is accumulated at any time:

Up to 1,000 kg (2,200 lb) of hazardous waste on-site

2. Small-Quantity Generator (SQG)

The following amounts are generated in one calendar month:

More than 100 kg (220 lb) but less than 1,000 kg (2,200 lb) of hazardous waste
More than 100 kg (220 lb) but less than 1,000 kg (2,200 lb) of spill cleanup debris containing hazardous waste

Or the following amount is accumulated at any time:

More than 1,000 kg (2,200 lb) of hazardous waste on-site

3. Large-Quantity Generator (LQG)

The following amounts are generated in one calendar month:

1,000 kg (2,200 lb) or more of hazardous waste
1,000 kg (2,200 lb) or more of spill cleanup debris containing hazardous waste
More than 1 kg (2.2 lb) of acute hazardous waste
More than 100 kg (220 lb) of spill cleanup debris containing acute hazardous wastes

Or the following amount is accumulated at any time:

More than 1 kg (2.2 lb) of acute hazardous waste on-site

6.3.7 Determining the Generator Category

A generator’s category is based on the largest amount of hazardous waste generated during a single month within a year. For example, if an operation produces more than 100 kg (220 lb) of hazardous waste for any calendar month during the year, that operation will not be considered a CEG for that year. The same is true of a generator that stores more than 1,000 kg (2,200 lb) of hazardous waste at any time. (Note: 100 kg [220 lb] is approximately one-half of a 55-gallon drum.)

Since the regulations for each of the hazardous waste generator categories are different, it is important to be aware of changes in the quantity of waste produced for any one calendar month and how those changes may affect your compliance requirements. Most Church operations will be CEGs; however, some operations may be SQGs.

Managers and supervisors should determine the type and maximum amount of hazardous waste generated in one calendar month. When measuring the amount of hazardous waste generated, include the following:

Waste accumulated before recycling, transporting, storing, treating, or disposing
Waste transported off-site for treatment, storage, disposal, or recycling
Waste recycled on-site

After calculating the total amount of hazardous waste produced in one month, refer to the generator status classifications in the previous section.

6.3.8 Obtaining a U.S. EPA Identification Number

If your operation is based in the United States and is an SQG, obtain a U.S. Environmental Protection Agency (EPA) identification number. The 12-character identification numbers used by the EPA and the individual states are part of a national database on hazardous waste activities.

To get a U.S. EPA identification number, do the following:

Call or write to your state’s agency for hazardous waste management or the EPA regional office, and ask for a copy of EPA Form 8700-12, Notification of Regulated Waste Activity. You will be sent a booklet containing the two-page form and instructions for filling it out. (Note: a few states use a form that is different from the federal form. Your state should send you the appropriate form to complete. Ask your state environmental agency if you can apply for an ID number electronically. Some states have electronic application systems.)
Make sure your form is filled out completely and correctly, and then sign it.
Send the form to your state hazardous waste contact. This information will be recorded by the EPA and the state, and you will be assigned a U.S. EPA identification number. This number will be unique to the site identified on your form. Use this number on all hazardous waste shipping papers. The U.S. EPA identification number will stay with the location. If the operation is moved to another location, you must notify the EPA or the state of your new location and submit a new form.

6.3.9 Specific Waste Management Requirements for CEGs

Most U.S.-based Church operations are CEGs. Although the amounts of hazardous waste produced are small and CEGs are not regulated like large producers of hazardous waste, managers and supervisors of CEGs still have a responsibility to manage their waste properly to protect human health and the environment.

Operators of CEGs may treat hazardous waste in an on-site facility or ensure delivery to an off-site treatment, storage, or disposal facility. The off-site management facility must be designated as one of the following:

Hazardous waste management facility
Recycling facility

Hazardous waste should be disposed of only at approved management facilities. (See section 6.3.14, “Approved Treatment, Storage, and Disposal Companies.”)

A CEG is not required to have an EPA identification number, but most transporters and disposal facilities will not accept hazardous waste without an EPA identification number and a proper hazardous waste manifest. Therefore, it is suggested that managers and supervisors get an EPA identification number for their CEG.

6.3.10 Benefits of Proper Waste Management

Proper hazardous waste management reduces environmental risks for all Church operations. It also makes good business sense. Here are some of the benefits of a sound hazardous waste management program:

Reduced economic liability. Improperly disposing of hazardous waste can lead to very costly cleanups. Businesses can be held liable for improper hazardous waste disposal, hazardous waste spills, and hazardous waste releases. The economic burden of such liability can be minimized, if not altogether avoided, by using proper waste management procedures.
Maintenance of property value. A property with known or suspected contamination from hazardous wastes can suffer serious loss of value.
Enhanced public image. Failing to manage hazardous wastes responsibly may lead to negative publicity.
Minimized worker exposure. Best practices require that workplace safety measures be followed. Proper hazardous waste management can reduce worker exposure to chemicals.

6.3.11 In-House Waste Audit

One of the best ways to begin developing a good hazardous waste management program is for managers and supervisors to see that an in-house waste audit is conducted. The purpose of the audit is not only to determine what hazardous wastes are generated but also to explore the options available for storing, treating, and disposing of these wastes. The following are major steps in conducting the in-house audit.

Step 1: Inventory all the wastes currently produced.
Step 2: Decide which wastes are hazardous.
Step 3: Evaluate current waste management methods. Evaluate by asking the following questions:
- Handling. How is waste presently handled? How many employees are trained to handle hazardous waste? Is training adequate? Is there enough background information (for example, an SDS) on the chemicals in the waste to understand the health and environmental risks?
- Storage. Where is the waste stored? For how long? Are several small containers used to hold waste, or is it accumulated in large containers? Are all waste containers properly labeled?
- Disposal. What are all the disposal options? What are the costs of different disposal options?
- Recycling, reducing, and reusing. Can any of the waste be recycled, reduced, or reused? Even simple methods to reduce waste can result in significant savings.
- Emergencies. What provisions have been made for emergency response?

6.3.12 Waste Management Tips and Recommendations

The following are several principles to keep in mind when developing a hazardous waste management program.

Waste Reduction

Reducing hazardous waste or eliminating it altogether is the best way to avoid liability, the expense of hazardous waste management, and the risks to human health and the environment. Consider the following methods of reducing hazardous waste:

Substitute raw materials. Nonhazardous or less-toxic materials can sometimes be substituted for hazardous materials to reduce or eliminate hazardous waste.
Manage your inventory wisely. Use the following suggestions:
- Buy only what you will use.
- Rotate inventory so older material is used first.
- Store material to prevent spills and leaks.
- Set up an inventory tracking system.
- Label all containers with contents and date.
- Don’t accept free samples you won’t use.
Segregate wastes. Hazardous waste mixed with nonhazardous waste results in hazardous waste. Mixing different types of hazardous waste may reduce management options.
Modify your process and equipment. Old or inefficient processes and equipment often account for excess use of toxic substances and may generate unnecessary hazardous waste.
Use good housekeeping practices. Consider the following suggestions:
- Regularly inspect and maintain equipment.
- Replace seals and gaskets.
- Repair leaks immediately.
- Use tight-fitting lids to prevent evaporation.
- Wipe up spills whenever possible, rather than hosing them down.
- Use spigots and pumps instead of pouring.
- Have a spill-prevention program.
- Use drip pans.
- Train employees in proper management.
Reuse and recycle. Using and reusing waste materials on-site reduces the amount of waste generated. Consider:
- Recycling waste materials back into the production process as a raw material.
- Filtering and reusing.
- Sending waste off-site for recycling.

Disposal

Do not dispose of hazardous or industrial waste in the following:

Septic systems, dry wells, boreholes, or on the land
Storm drains, streams, rivers, or other bodies of water
Sewer systems or municipal landfills without prior permission

Dispose of hazardous waste only at permitted hazardous waste facilities.

Container Storage

Do not store hazardous waste containers on a gravel surface. If possible, store hazardous waste on an impermeable surface with secondary containment. The storage area should be covered to protect waste from storm water. In the U.S., if wastes are exposed to stormwater, an EPA stormwater discharge permit may be required.
When storing empty containers outside, keep them closed and on their sides with their stoppers in place. This prevents rainwater from filling the containers.
Label all containers with their contents, whether they contain waste or product or are empty.

Hazardous Waste Management Firms

Not all hazardous waste management firms are qualified to manage your wastes. Use only approved management facilities. (See section 6.3.14, “Approved Treatment, Storage, and Disposal Companies.”)

6.3.13 Waste Management Options for Specific Kinds of Waste

Below are management options currently in use for specific kinds of waste. The list does not include all available options. The location of your operation and the amount of waste you generate may affect what options are most appropriate. In all cases, consider waste reduction first to minimize the amount of waste that needs to be managed. Many of the methods in the following chart may require the services of a waste management firm.

Waste Type	Common Management Method	Comments
Printing ink waste	Recycle; use unused ink; take to a landfill (if solidified and not hazardous); dispose at a hazardous waste management facility.	Often hazardous due to solvent or metal content.
Solvents	Recycle (on-site or off-site); dispose at a hazardous waste management facility.	Very often hazardous. Usually recycled.
Paint waste	Use; recycle (if possible); donate to those who could use; solidify and take to a landfill if latex; empty and dry if oil based (enamel); dispose at hazardous management facility.	Latex paint is usually not hazardous. Oil-based paint is often hazardous.
Used oil	Recycle off-site; burn on-site for heat in approved furnace.	Not regulated as hazardous if recycled. Hazardous if contaminated with another hazardous waste.
Used oil filters	Recycle; take to a municipal waste landfill if drained or crushed.	Used oil filters are exempt from being a hazardous waste when properly drained or crushed. (Terne-plated filters are not exempt.)
Antifreeze	Recycle on-site or off-site.	Can be hazardous. Some sewer agencies allow small amounts to be discharged.
Fluorescent tubes		Verify local requirements for disposal and recycling.
Empty toner cartridges	Empty toner cartridges can be disposed of as normal waste.
Aerosol cans	Empty the aerosol cans before disposal so the pressure in the container is equivalent to atmospheric pressure.
Empty chemical containers	Remove all nonhazardous materials from containers. Use acceptable practices to remove materials from containers (for example, pouring, pumping, or aspirating). Crush or cut open all containers greater than five gallons before disposal.	1. Containers that once held water-based hazardous materials must be rinsed three times to be considered empty. Residues in rinse liquid should be used if possible. If not, they should be disposed of as hazardous waste. 2. Do not rinse empty solvent containers.
Batteries	Return used automotive batteries to gas stations or battery dealerships for recycling. Collect all other batteries for recycling according to local regulations.	Automotive batteries each contain about 18 pounds of lead and about a gallon of corrosive sulfuric acid. Several states have banned lead-acid batteries from their landfills.

6.3.14 Approved Treatment, Storage, and Disposal Companies

In the United States, The Church of Jesus Christ of Latter-day Saints has signed contracts with the companies linked below to provide hazardous waste disposal. These companies have been selected as the most qualified and cost competitive, and they are available for work in all 50 states. The contracts were negotiated by the Church Purchasing Division to ensure the consultants’ companies have adequate insurance and to protect the Church legally.

Safety, Health, and Environmental Consultants and Contractors