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Are you being hazardous?

November 23, 2011
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In the past, it seemed only large businesses, such as chemical manufacturers, had to worry about hazardous waste. Today, any business that generates hazardous waste, especially small businesses, must understand the hazardous wastes they produce, how they are to be handled and even recorded.

To shed more light on the issue, let us talk a moment about hazardous waste and what they are by EPA law. A hazardous waste is a material you have used that can cause serious problems if not handled or disposed of properly and carefully. Such waste has the potential to cause:

  1. Injury or death, or
  2. Damage or pollute land, air, or water.

Do you generate hazardous waste?

It is an important question. If the answer is “no,” you do not need to read further. But, the detail business does generate hazardous waste, so read on.

If you don’t believe me, and choose to answer, “I don’t know,” “I’m not sure,” or “I don’t think so,” then you must find out if any of your wastes are hazardous to determine what regulations would apply to your detail business.

What is considered hazardous?

There are two ways for a waste to be considered hazardous:

  1. It is specifically listed as hazardous which means it appears on any one of the four lists contained in RCRA regulations. There are over 400 on the list. And, I can guarantee you, there are many detail chemicals, or elements thereof, that are on the list.
  2. It can possess one or more of these characteristics:
    1. Ignitable: Easily combustible, such as solvents, lacquer thinner, etc.
    2. Corrosive: It dissolves or corrodes metals or burns the skin.
    3. Reactive: It is unstable or undergoes violent reactions in combination with water or other materials. For example, gold plating wastes, bleaches, oxidizers.
    4. Extractor Procedure Toxic: It contains high concentrations of heavy metals, which can be released into the ground water.

This is exactly what engine cleaning does, with or without using engine-degreasing chemicals. Metals from the engine mixed with water and/or chemical create a hazardous waste.

It is your responsibility to know if your wastes are hazardous.

Some hints on determining what’s hazardous

There are a few hints to use to determine if you are generating hazardous wastes.

  1. Do you use chemicals that foul the air in your shop?
  2. If yes, how do you provide for ventilation?
  3. Are you using common sanitary sewers or storm drains for wastes that contain chemicals you are using?
  4. If storm drains, do you have special traps to stop or separate the chemicals, or to treat or neutralize them?
  5. Do you let waste material runoff into the ground or leak into the ground?
  6. Do you store any waste materials?

In every one of the above-mentioned cases, you need at least a permit or to register with one of the EPA agencies to comply with the law. Have you done this? It is very likely you are dumping hazardous wastes in the operation of your detail business.

If you need assistance, you have two choices:

  1. Call in a professional consultant to evaluate your business.
  2. Call EPA’s Small Business Ombudsman Hotline: 1-800-368-5888.

Never, under any circumstances, do nothing.

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