Washington RCRA Hazardous Waste Reporting

Federally, hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA). At the state level in Washington, specific hazardous waste regulations are administered by the Washington State Department of Ecology (Ecology). Washington has hazardous waste designations and regulations that are more stringent than federal requirements. Throughout the state, hazardous waste is referred to as dangerous waste, and facilities in Washington are required to submit Dangerous waste annual reports to Ecology each year. 

Understanding Washington Hazardous Waste/ RCRA Reporting Requirements

Who Needs to Report?

Any facility with an active EPA/State Identification (ID) number must submit a dangerous waste annual report, regardless of generator status. There are 4 types of dangerous waste annual reporting forms that may be required to fulfill reporting requirements. The forms required are determined by a facility’s generator category and dangerous waste activities. In WA, generator categories are determined based on the quantities of dangerous waste generated per calendar month and vary slightly from federal designations:

• State no regulated waste generator (XQG): A facility where no dangerous waste was generated during the reporting year. Not required to report unless the generator has an active EPA ID.
• State small quantity generator (SQG): A facility that generated all of the following in a calendar month:
  • 220 lbs or less of dangerous waste that is not acute hazardous waste (AHW) and/or Washington designated extremely hazardous waste (WT01 EHW)
  • 2.2 lbs or less of AHW and/or WT01 EHW
  • 220 lbs or less of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or any any land or water 
  • Not required to submit a complete report unless the SQG has an active EPA ID. An active EPA/State ID is required if the site manages dangerous waste under:
    • Episodic generation
    • State defined special dangerous wastes
    • If an SQG has an active EPA/State ID, but does not manage dangerous waste under the above conditions, only a site ID form is required for annual reporting
• State medium quantity generator (MQG): Required to have an EPA/State ID and to report annually. Defined as a facility that generated all of the following in a single calendar month.
  • More than 220 lbs but less than 2,200 lbs of dangerous hazardous waste that is not AHW and/or WT01 EHW
  • 2.2 lbs or less of AWH and/or WT01 EHW
  • 220 lbs or less of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or any any land or water 
• State large quantity generator (LQG): Required to have an EPA/State ID and to report annually. Defined as a facility that generated any of the following in a calendar month. Re
  • 2,200 lbs or more of dangerous waste that is not AHW and/or WT01 EHW
  • 2.2 lbs or more of AHW or WT01 EHW

More than 220 lbs of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or any any land or water

State Listed Dangerous Wastes in Washington

Washington’s definitions of dangerous wastes are based on the federal RCRA definitions but include more wastes than those included under RCRA. In WA, there are state-specific criteria that determine if wastes are dangerous. It is the responsibility of a business or facility to conduct tests and classify if their wastes are hazardous based on state criteria.

These criteria include: 

• Toxic wastes (State Codes WT01 or WT02)
  • Based on the concentration of a waste’s toxic components
• Persistent wastes (State Codes WP01, WP02, WPCB, or WP03)
  • Wastes that have chemicals that are slow to breakdown, linger in the environment, and can accumulate in living tissue. Examples include Polycyclic aromatic hydrocarbons, halogenated organic compounds, and polychlorinated biphenyls 
• Solid Corrosive wastes (State code WSC2)
  • Solid or semi-solid wastes that (when tested with a solution of 50% DI water and 50% waste solution) have a pH that falls within the corrosive ranges of:
    • Less than or equal to 2 or 
    • Greater than or equal to 12.5

More information on WA specific listed wastes and testing methods cam be found here.  

Key Points: 

• WA has generator categories that differ from the federal designations. Facilities will indicate both their state and federal generator category on annual reports.
• WA classifies hazardous waste as dangerous waste.
• In addition to federally listed wastes, it is the responsibility of businesses to ensure their wastes are not considered dangerous under the criteria laid out by the state
• SQGs are not required to report (unless they meet criteria above) but are encouraged to do so by the state

Washington Generator Statuses and Requirements

Small Quantity Generators (SQG) Requirements

Federally, facilities who generate 220 lbs (100kg) or less of hazardous waste are considered VSQGs and are exempt from waste reporting. In WA, facilities who generate 220 lbs (100kg) or less of hazardous waste are considered SQGs and must submit a Dangerous Waste Annual Report if they have an active EPA/State ID. SQG reporting requirements include:

• Obtain state ID number if the site manages dangerous waste under episodic generation or conditional exclusion for special waste
• Complete Site ID Form for annual reporting: provides contact information and a summary of waste activities for the previous year. This form is required for all facilities, regardless of generator status. If an SQG has an active EPA/State ID, but did NOT ship episodic waste or special waste, the Site ID form is the ONLY form required for annual reporting. If an SQG DID ship episodic or special waste, the following are required: 
  • Must use and submit Uniform Hazardous Waste Manifests
  • Only use permitted TSDFs or waste recyclers
  • Keep records of dangerous waste quantities generated, accumulated, and how the wastes are managed
  • Use both Federal and State waste codes 
    • Pay report fees and submit reports electronically through TurboWaste

Medium Quantity Generator (MQGs) Requirements

Federally defined SQGs are considered MQGs in WA. MQGs generate between 220 lbs and 2,200 lbs of dangerous waste.

Requirements:

• Obtain EPA/State ID number
  • File Dangerous Waste Site ID Form to notify the state of waste activities: provides contact information and a summary of waste activities for the previous year. 
• Use and submit all Uniform Hazardous Waste Manifests 
• Only use permitted TSDFs or waste recyclers
• Keep records of dangerous waste quantities generated, accumulated, and how the wastes are managed
• Use waste containers in good condition:
  • Closed, non-leaking, stored in a secondary containment system, and inspected weekly
• Use both federal and State waste codes 
• Schedule and document facility inspections 
• Familiarize employees with proper waste handling procedures
• Must have emergency response information posted near hazardous waste accumulation areas
• Complete Pollution Prevention Plan if more than 2,460 lbs of waste in generated annually or toxic releases are reported
• Pay report fees and submit reports electronically through TurboWaste by March 1 each year

Large Quantity Generator (LQG) Requirements

Any facility that generates more than 2,2000 lbs of hazardous waste per month is an LQG. LQG requirements include: 

• Obtain EPA/State ID number
  • File Dangerous Waste Site ID Form to notify the state of waste activities: provides contact information and a summary of waste activities for the previous year. 
• Use and submit all Uniform Hazardous Waste Manifests
• Only use permitted TSDFs or waste recyclers
• Keep records of dangerous waste quantities generated, accumulated, and how the wastes are managed
• Use waste containers in good condition:
  • Closed, nonleaking, stored in a secondary containment system, and inspected weekly
• Use both federal and State waste codes 
• Implement a formal written training program to all employees on waste handling and emergency response procedures
• Must have a formal contingency plan in place
• Complete Pollution Prevention Plan if more than 2,460 lbs of waste in generated annually or toxic releases are reported
• Pay report fees and submit reports electronically through TurboWaste by March 1 each year

Examples of Facilities Subject to Waste Reporting

Below are some examples of facilities in Washington  and the industrial hazardous wastes that would most likely trigger the need to submit an annual report:

• Manufacturing facilities who generate waste such as solvents, heavy metals, scrap metals, and spent acids
• Healthcare facilities: wastes such as expired medications and chemotherapeutic agents
• Agricultural operations generating pesticide residues, fertilizer wastes, unused chemical, and animal waste
• Automotive repair shops: generating waste such as spent solvents, degreasers, paint residues, and lead-acid batteries
• Wood treatment and processing facilities who generate waste such as creosote-treated wood waste, sawdust or chips containing preservatives and spent coatings

Key Points:

• Any facility that generates special waste must complete annual reports, regardless of generator status. Special waste is a category of WA state-specific dangerous waste that are fully solid and pose a relatively low hazard to human health and the environment. Forms required for annual reporting of special waste include:
  • Generation and management form 
  • Off-site identification form (OI form)
• Annual reports must be submitted electronically. WA state encourages reports to be submitted online through TurboWaste. Facilities who must file on paper can request copies of forms from Ecology. These forms must be scanned and emailed to turbowaste@ecy.wa.gov and physically mailed to Ecology

Hazardous Waste Manifest Requirements for Washington Facilities

A Hazardous Waste Manifest is a document that travels with hazardous waste throughout the shipping and treatment process. This document allows regulatory agencies to track waste from its origin to disposal, ensuring correct handling of waste from “cradle” to “grave”. Federally, all hazardous waste shipments must be accompanied by a Uniform Hazardous Waste Manifest (EPA Form 8700-22) from generation through disposal, unless the waste meets certain exceptions. At the state level in WA, all facilities who are subject to annual reporting are required to follow federal regulations and use the Uniform Hazardous Waste Manifest throughout the generation and shipments of their waste. These manifests will be submitted as part of your annual reporting requirements.

Waste manifests must include:

• RCRA ID numbers 
• Generator name, address, and emergency contact information
• Name, address, phone number, and RCRA ID for receiving facilities
  • Above information for an alternate receiving facility
• Transporter companies with U.S. DOT descriptions
• Dangerous Waste Numbers for each waste 
• Waste descriptions including:
  • State and federal waste codes
  • Quantities
  • Container information
  • Any special handling instructions
• Signatures from generators, transporters, and receiving facilities
• Emergency response numbers and emergency spill cleanup procedures
• For Generators:
  • Manifest submissions: Washington requires UHM to be uploaded through TurboWaste as part of annual reporting requirements 
  • Starting January 22, 2025, all SGQs and LGQs will be required to register for the e-Manifest system through RCRAInfo
  • All generators must retain copies of all hazardous waste manifests for a minimum of 5 years, which is longer than the federal requirement of 3 years
  • After January 22, 2025, TSDFs will no longer be required to submit final manifests to generators.

Common Manifest Errors

• Expired state/EPA ID
• Inaccurate container and quantity counts
• Unauthorized signatures
• Mismatches dates, transporter names, and EPA IDs

Washington Electronic Waste Reporting System (TurboWaste)

Overview of TurboWaste

Washington utilizes the electronic TurboWaste system for annual dangerous waste reporting. Electronic data storage and state level reporting supports federal RCRA compliance by keeping track of certain waste streams, emergency response plans, employee training, and hazardous waste generation and storage. Facilities required to submit federal biennial reports will also use TurboWaste to comply with federal reporting requirements. Waste manifests uploaded and stored in TurboWaste are accessible by fire departments and local agencies throughout WA. WA encourages electronic reporting to ensure a unified, standardized platform that is accessible to all authorized agencies across Washington. 

How to Submit a Hazardous Waste Report in TurboWaste

Here are the key steps for using Washington’s TurboWaste online reporting system:

• Create your TurboWaste account
  • In WA, all generators must access TurboWaste using SecureAccess Washington (SAW).
  • To create a TurboWaste account, facilities must first create and activate a SAW account at https://secureaccess.wa.gov/myAccess/saw/select.do
  • To access TurboWaste, log in to SAW and select “Add a new service” > Department of Ecology > TurboWaste
  • Apply and register for a TurboWaste account and register for an Electronic Signature Account (ESA). ESAs are needed to sign and submit dangerous waste reports 
• Prepare Data for Reporting:
  • Gather information such as facility IDs, waste stream details including types, quantities, and management methods, and TSDF details 
  • Compile copies of manifests for submission
  • Complete the necessary forms:
    • SQG:
      • Site ID Form: provides contact information and a summary of waste activities for the previous year. This form is required for all facilities, regardless of generator status.
      •  Off-site identification form (OI) form: this form must be submitted for facilities who:
        • Shipped away waste that was on a UHM
        • Generated special waste, regardless of generator status
        • Received waste from off-site
        • Had a planned or unplanned episodic event
      • Generation and management (GM form): describes waste streams generated and how the waste is managed. Uses information from manifests including state and federal waste codes, source codes, UHMs, recycling credits, and bills of landing
      • Waste Received (WR) form (if applicable)
    • MQG:
      • Site ID Form
      • Off-site identification form (OI) form
      • Generation and management (GM form)
        • Waste Received (WR) form (if applicable)
    • LQG:
      • Site ID Form
      • Generation and management (GM form), 
      • Off-site identification form (OI) form: this form must be submitted for LQGs who receive waste for consolidation
        • Must also complete a Waste Received form
• Submit completed forms and pay report fees through TurboWaste
• Keep copies of submitted reports for at least 5 years
• Facilities may submit annual report forms by mail if unable to use TurboWaste
  • Contact Ecology to request reporting forms
  • Complete and assemble forms in the correct order:

1. 1. 1. Site ID form, required
      2. OI form(s), if applicable 
      3. GM form(s), if applicable
      4. WR form(s), if applicable
      5. Addendum(s), if applicable

• Submit forms via email AND mail
  • Email scanned copies to turbowaste@ecy.wa.gov
  • Mail original copies. WA only accepts original signatures. Do not mail manifest copies

HWTR Annual Reporting Team

P.O. Box 47658

        Olympia, WA 98504

Key Points:

• WA encourages the use of electronic TurboWaste for report submissions
• Any facility with an active EPA/State ID is required to submit a Site ID Form by March 1 each year, regardless of generator status
• The use of UHM is required by all facilities who ship dangerous wastes, upload copies of manifests as part of annual reporting requirements
• All documents relating to generation, reporting, manifests, inspections, and training must be kept for a minimum of 5 years. This is longer than the federal requirement of 3 years

Deadlines,Timelines RCRA Reporting Frequency

Annual Reporting Deadline

In Washington, hazardous waste reports are due by March 1 each year regarding information on hazardous wastes generated by the facility in the previous calendar year.

Additional Reporting Requirements (additional waste reports)

• Recycling credit: recycling credits are the percentage of waste that is recycled by an off-site hazardous waste provider. Facilities who recycle their hazardous waste have additional reporting requirements, including:
  • Requesting documentation from service providers confirming recycling credits
  • Reporting recycling credits on Dangerous Waste Annual Report
• Pollution Prevention (P2) Plans: Some businesses are required to submit P2 plans to reduce dangerous waste generation. Facilities will be contacted by Ecology each year they are required to submit a P2 plan. A plan is required if your business generates more than 2,640 lbs of dangerous waste annually or reports toxic releases under section 313 of EPCRA. P2 plans are due by September 1 of each year and are submitted online through TurboPlan.
• Used Oil Report Addendum: Describes used oil activities for processors and re-refiners. Businesses who are considered processors will notify Ecology by filling out section 10c2 of the Site ID form and are required to submit a used oil report addendum

Tips for Effective RCRA Reporting

Maintain Continuous Records

• Continuously tracking waste generation data will help with making sure a facility is maintaining its generator status all year and assist in promptly identifying any changes. This is especially important because WA does not allow for episodic generation exemptions. 
• Continuously and thoroughly recording waste can help ensure waste data is accurate and ready to go when the March 1st deadline comes around each year. A good rule of thumb is to have data ready to review the first week of January.
• Employee training: Federal regulations require facilities that generate hazardous waste maintain records of their employee training. These records may need to be reported during inspections or upon request. Ensure the facility maintains up to date records of all training sessions including dates, topics covered, attendees, etc. and stores these records for 5 years to ensure compliance. 

Understand Washington-Specific Reporting Requirements

Washington’s waste reporting guidelines are more stringent than federal regulations. Some key differences include:

• Terminology: WA uses the term Dangerous Wastes to refer to hazardous wastes
• Generator Categories: WA has 4 generator categories
  • State exempt generators are not required to report
  • Federal VSQG are considered SGQ in WA and may have to report if the facility has an active EPA/State ID

Keep Copies of All Submitted Reports

Make copies of all forms and securely store them for a minimum of 5 years to stay in compliance in WA

Common Mistakes in RCRA Reporting and How to Avoid Them

Incorrectly Estimating Quantity of Reportable Wastes

Reporting incorrect waste quantities or generator status can be due to events of underreporting to avoid reaching large quantity generator status and overreporting due to data management errors

Tips:

• Create standardized reporting checklists to ensure accurate information
  • Consider electronic tracking or digital software to automatically calculate quantities based on generation and shipments 
• Maintain up to date and accurate logs of waste generation and disposal all year long
• Conduct regular audits of waste totals

Failure to Report All Hazardous Wastes

Omitting certain waste types can happen unintentionally due to a variety of factors such as a lack of understanding WA regulations, incorrectly identifying wastes as non-hazardous, failure to assign correct waste codes, or failure to report wastes that are otherwise federally-exempted.

Tips: 

• Conduct regular waste assessments to ensure proper classification
• Verify waste information with waste disposal facilities 
• Use a digital waste management tracking system to reduce errors and improve record keeping
• Refer to WA guidelines for determining if waste is considered dangerous:

Failing to Keep Up-To-Date with Changes in Regulations

Failing to keep up with changes in regulations can be due to a number of factors. Facilities may lack designated staff members dedicated to tracking regulatory updates, incorrectly assume that long-standing waste management practices remain compliant, or fail to monitor changes from the state.

Tips: 

• Assign a designated staff member or team to monitor waste regulations
• Stay informed: subscribe to updates from WA Ecology to keep up to date of any deadlines 
• Join county and state EHS associations to stay up to date about regulatory changes

Lack of Compliance with Washington-Specific Waste Regulations

Failing to understand the differences between federal RCRA requirements and specific rules can lead to non-compliance at the state level. The following may cause a facility or organization to be out of compliance in Washington: 

• Not notifying authorities when changes in your waste generator status can lead to violations in WA as they do not allow for episodic generation exemptions
• Failure to apply state-specific waste codes
• Failing to complete annual reports by incorrectly assuming a federally designated VSGQ is exempt. WA has generator categories that vary from federal definitions.

Tips:

• Monitor waste totals monthly 
• Promptly notify Ecology if there are changes in  waste generation
• Regular refer to Washington Code of Regulations for state specific dangerous waste regulations

Late and Missed Submissions

Ineffective timeline management can lead to late and missed report submissions. Lacking a centralized compliance center, unclear designation of responsibilities, and insufficient training can contribute to missing deadlines. 

All reports must be submitted by March 1. Mailed reports must be emailed and postmarked by March 1

Tips:

• Create a shared compliance calendar and set reminders well in advance
• Start compiling hazardous waste data and facility information early (by January at the latest) to avoid last-minute errors
• Use a centralized digital filing system so data can be easily and readily accessed

Penalties for Non-Compliance with RCRA Reporting in Washington

Potential Fines and Legal Consequences

Non-compliance in Washington can lead to penalties, including civil and criminal fines. Penalties are imposed by both the Department of Ecology and federal agencies in WA and can be substantial. Fine amounts are based on the nature and gravity of violations, as well as if the facility has a previous history of non-compliance. Fines and penalties can include:

• Fines of $100-$10,000 per day for violations relating to repeated non-compliance, refusal to comply, or imminent threat to human and environmental health
• Late submissions result in fines and more frequent future inspections
• Significant non-complier (SNC): In WA, a SNC is a facility that meets one or more of the following:
  • Caused exposure or substantial likelihood of exposure to dangerous waste to humans or the environment
  • Is a chronic violator
  • Has violations that deviate substantially from the conditions or a waste regulatory requirement 
  • SNC determinations may result in more frequency inspections, administrative orders, and civil penalties