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As technology and development have advanced, so has pollution. Over the years, environmental advocates have come to develop a deeper understanding of what affects our environment and what we can do to control and limit the damage done to it. RCRA EPA regulations are an example of the legal and cultural response to eliminate pollution from industrial waste that left communities, waterways, and ecosystems severely degraded and posed significant risks to public health.
What is RCRA? When was RCRA enacted — and what consequences did it have then and continue to have now?
Most people in business should be familiar with the basic RCRA definition, as it is a Congressionally-mandated hazardous waste management program. The Resource Conservation and Recovery Act was enacted by Congress in 1976. As part of RCRA, EPA was delegated the responsibility to develop regulations, which were developed as a response to increasing environmental damage caused by improper disposal of industrial waste streams especially in densely populated cities. EPA also designated certain hazardous wastes as universal waste, which is a category of “hazardous waste” commonly generated across industry verticals. Equipment containing mercury is one example of universal waste. Under RCRA, chemicals on the RCRA Hazardous Waste List must be controlled and disposed of properly. The RCRA list includes toxic, acutely toxic, and hazardous materials, and is separated into F, K, P, and U wastes, all of which originate and must be controlled separately. Non-hazardous waste must also be properly managed. (For additional details, see the Code of Federal Regulations, Tile 40: 40 CFR Subchapter I – SOLID WASTES.)
Industries that produce regulated waste streams are required to manage them from cradle-to-grave to prevent environmental contamination.
RCRA has been successful not only in improving environmental health but also related human health risks. RCRA was developed to address the environmental damage that occurs when hazardous and non-hazardous waste is disposed of improperly, as well as the human health concerns that then arise. Prior to RCRA, it was more common for hazardous waste to be disposed of on site with no measures taken to prevent contaminants from migrating offsite to an area that could then impact entire communities.
Everyone in business should be familiar with the basic RCRA EPA definition, since it’s a waste management program mandated by Congress — and all companies should be aware of the RCRA Hazardous Waste List. (See more in the section on RCRA Hazardous Waste below.)
Per the EPA website: RCRA Online is an electronic database that indexes thousands of letters, memoranda, publications, and questions and answers issued by EPA’s Office of Resource Conservation and Recovery (ORCR). These documents represent past EPA Headquarters interpretations of RCRA EPA regulations governing the management of solid, hazardous, and medical waste. RCRA Online allows users to locate documents by browsing topics or performing full text or advanced searches. RCRA Online also allows users to view the actual text of the documents identified in a search.
For compliance reporting, RCRA Online helps companies to manage RCRA activities beginning with tools including RCRA EPA ID lookup and EPA Generator ID lookup. As a compliance filing starting point, for example, companies can locate applicable site information and ID numbers in EPA ID lookup, and then use those IDs for their remaining compliance information.
Note, however, that RCRA Online does not accommodate certain RCRA compliance reporting that must be completed on a local or state basis. Many state and local jurisdictions maintain their own controls and reporting requirements, as well as their own online reporting systems. Which system you use is determined by where your business is located.
What is the RCRA EPA ID? The EPA ID number is an identifying number for a business that’s used to ensure compliance; these numbers vary by state. You can look at the EPA ID number example if you want to use the EPA ID lookup. For example, you can perform a California EPA ID number lookup, a Massachusetts EPA ID number lookup, or an Illinois EPA ID number lookup. A company will need to know their EPA ID to file the correct forms and ensure that they have met all elements of compliance.
A RCRA EPA ID number is issued either by the local municipality (for the California ID it would be the DTSC) or the EPA. Companies require an EPA ID number to track hazardous waste from when the waste is actually generated to when it’s disposed of. This occurs for any business that generates 100 kg of hazardous waste over the course of a month or 1 kg of acutely hazardous waste over the month. So, a very small generator of hazardous waste will still need to follow these processes, but they will not need an ID.
RCRA training requirements apply to any company dealing with hazardous waste. But which personnel are subject to RCRA training, and is such training continuous?
By law, any EHS professional or other employee who performs hazardous waste tasks is required to complete appropriate RCRA training. This includes all persons who maintain inventory logs, schedule waste shipments, and manage containers that might contain residue from a chemical classified as a hazardous waste. Required training, which pertains to the duties of an employee, can be conducted in-person or online. Typically, RCRA training is more rigorous for someone who manages or handles hazardous materials daily, and less intensive for anyone who has only “passing contact” with hazardous materials within the scope of their job.
RCRA training must include emergency response drills as well as DOT and/or HAZWOPER training. Refresher training is required annually. Training records must also be maintained, and instructors must themselves be trained or certified in RCRA training criteria per federal requirements. State requirements apply to RCRA training in many cases, as well.
EPA offers several resources for RCRA training, as do a number of independent training firms, which conduct seminars and presentations on a year-round basis. EPA RCRA Training Modules provide overviews of specific RCRA regulatory topics, for example, plus corrective action, exclusions, financial assurance, and permits. Two modules in particular provide a statutory overview of RCRA and an overview of other laws that interface with RCRA.
What exactly is RCRA hazardous waste? What are hazardous waste examples — how can you determine when something is hazardous? What is non RCRA hazardous waste and are there still requirements for disposal?
As defined by the EPA, RCRA hazardous waste is any solid waste that’s generated by a commercial or industrial facility that demonstrates one or more of the following characteristics
The following chart also shows how RCRA hazardous waste is defined.
Essentially, RCRA hazardous waste characteristics refer to waste that has the potential to pollute the environment or cause damage to the people in it. RCRA hazardous waste should be disposed of in an approved hazardous waste container. Hazardous waste includes items such as pesticides, batteries, certain kinds of light bulbs, paints, and solvents. These and other similar products could potentially cause harm if introduced to the environment. But some people, and companies, might not realize that things like batteries and fluorescent light bulbs cannot be disposed of in regular trash.
Non-hazardous waste includes items like food, drinks, and paper, which are things you can throw out in a regular trash bin. Such items are not known to pose any substantial threat to people, although they can still potentially cause harm to the environment. Because of that, non-hazardous waste must still be safely disposed of — such as plastic bottles not being disposed of in a way that they could produce litter.
To deal with hazardous waste, an employee must meet RCRA hazardous waste training requirements. As noted in the previous section on RCRA training, any employees who dispose of RCRA hazardous waste or manage the disposal process (or both) must meet applicable training requirements. This training ensures that all employees are aware of RCRA disposal requirements and that the organization is RCRA compliant.
In the RCRA metals equation — specifically TCLP RCRA metals — TCLP refers to the Toxic Characteristic Leaching Procedure. TCLP is a chemical analysis process that determines whether hazardous elements are left in waste, and is an important test both for metals and volatiles. RCRA metals are those that are considered to be hazardous, and include different classifications. Among them are RCRA 11 metals, RCRA 13 metals, and a RCRA 8 metals list. RCRA metals limits depend on the type of metal.
RCRA 8 heavy metals include (but aren’t limited to) Arsenic, Cadmium, Lead, and Silver. These materials can be toxic if introduced to the environment or to a person. Each material has individual limits. Arsenic, for instance, is limited to 5.0 ppm (mg/L), whereas Barium is limited to 100.0 ppm (mg/L). RCRA 11 and RCRA 13 metals include the RCRA 8 metals but expand the definition; RCRA 13 metals, known as priority pollutants, also include antimony and thallium.
All these metals must be dealt with carefully to ensure that toxicity isn’t reached in the environment, which could affect humans as well as wildlife. The RCRA metals list should be used as an example resource of metals that must be controlled and safely managed.
The EPA Hazardous Waste Generator Database is available to identify and keep track of chemicals that are known to generate hazardous waste. Various database resources and guides are listed on the EPA’s Hazardous Waste Generator web page. From that page, you can use the EPA database search or the EPA hazardous waste generator ID number lookup to find more information.
Hazardous waste generators fall under three categories:
Categories are determined by the amount of hazardous waste generated onsite in a single month, and generators can change their status based on the amount. (It’s easier to adjust up than down.) State regulations may differ and are more stringent.
A very small quantity generator can produce 100 kg or less of hazardous waste each month. Alternatively, they can produce less than one kg a month of acutely hazardous waste. A generator that does these things and has less than 220 pounds of spill residue a month can be considered a very small quantity generator. Note: Not all states recognize facilities as VSQG.
As a waste generator, a very small quantity generator must still maintain certain standards. Among them, VSQGs must be able to:
A VSQG must never generate more than 100 kg of hazardous waste a month, and must never store more than 1,000 kg of hazardous waste at any given time. VSQGs must additionally ensure that hazardous waste is delivered to a person or facility who is authorized to manage it. A very small quantity generator is not required to submit a biennial waste report. There are no exemptions or more stringent rules for VSQGs in these States: CA, CO, CT, DC, FL, IA, ME, MA, MN, MO, NV, NY, RI, VT, WA, WV.
A small quantity generator can generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste per month. They may also accumulate hazardous waste on-site for 180 days without a permit, although an exception allows storage for up to 270 days if shipping a distance greater than 200 miles. The quantity of hazardous waste accumulated on-site for an SQG must never exceed 6,000 kilograms at any given point in time. Also, an SQG must always have at least one employee available to respond to an emergency. This employee is generally the emergency coordinator responsible for coordinating all emergency response measures. SQGs are not required to maintain detailed, written contingency plans. There is no requirement for SQGs to submit a biennial report.
A large quantity generator can generate more than or equal to 1,000 kilograms/month of hazardous waste OR more than 1 kilogram/month of acutely hazardous waste. Once a facility is an LQG, there are no limits on the amount of hazardous waste that can be accumulated on-site. However, these additional federal compliance requirements apply:
State regulations may be more stringent for LQGs in these States: CA, CO, CT, FL, IL, IA, MD, MN, MO, NV, NY, RI, VT, WA, WV.
See the EPA Hazardous Waste Generator Database for examples of a RCRA hazardous waste generator or the hazardous waste generator requirements table to learn more.
It can take up to 15 business days to receive a RCRA EPA ID number as a business needs to apply for it. They will need to send in a form called a Notification of Regulated Waste Activity, which is what the EPA will use to assign their ID.
The RCRA hazardous waste definition is any waste classified as hazardous under RCRA that must be controlled and reported on.
EPA Form 8700-12 and the RCRA Subtitle C are both used for compliance reporting. EPA Form 8700-12 is the Hazardous Waste Report, which must be filed including the Waste Generation and Management, Waste Received from Off-Site, and Off-Site Identification forms. These are part of the RCRA Subtitle C forms. This includes a detailed report on how the forms should be filled out, which can help organizations that are new to waste management reporting.
The forms themselves include the EPA ID number, waste descriptions, sources, generation, and off-site shipment. All waste has to be tracked from “cradle to grave,” which means that as waste moves through the system, EPA ID numbers must remain linked. Off-site installers and off-site transporters must also be logged, so that waste is never moved without an identifiable responsible party.
Each type of hazardous waste has its own requirements, both in terms of classification and potential requirements. Companies should be up to date on their RCRA reporting standards — something that can be helped with a RCRA compliance platform.
If you’re interested in how Encamp helps EHS managers deliver consistent processes and first-rate compliance programs, request a demo.