8 Step Hazardous Waste Management Guide

Step 1: Evaluate Your Waste

Step 2: Apply for a Hazardous Waste Identification Number and the Required License

Step 3: Store and Label Your Waste Properly

Step 4: Transport and Dispose of Your Waste Properly

Step 5: Manifest Shipments of Hazardous Waste

Step 6: Plan for Emergencies

Step 7: Train Personnel

Step 8: Keep Records


Businesses routinely use hazardous materials which, when improperly handled, pose a threat to human health and the environment. These materials are found in everyday items such as fluorescent lamps, electronic devices and certain batteries, as well as in substances like oil and solvents. Federal and state laws require special handling and disposal of these items. It is important to remember that businesses are responsible forever for any waste they generate.

Hazardous Waste Management Requirements

The following overview of the Minnesota Pollution Control Agency (MPCA) requirements for hazardous waste generators is significantly abbreviated from Minnesota Hazardous Waste Rules, Chapter 7045. Call your county hazardous waste office for further assistance, as the requirements are subject to change and not all requirements are detailed here.

FGet up-to-date information on managing hazardous waste from the Minnesota Pollution Control Agency's HHW page.


Who is a Generator?

A generator is any person, company, or organization by site whose act or process produces hazardous waste. Included in this definition are businesses that are serviced by companies that regularly provide clean solvent and pick-up used solvent for recycling. Home-based businesses may also be generators. To determine if you are a generator, you must evaluate your waste.


Step 1: Evaluate Your Waste

In Minnesota, every business is required to evaluate its waste to determine if any is hazardous.

A waste is hazardous if:

  • The waste is listed in the Minnesota Hazardous Waste Rules. Check with your county hazardous waste office or contact the Minnesota Pollution Control Agency (MPCA) at (651) 296-6300.
  • The waste is ignitable, corrosive, reactive, lethal and/or an oxidizer (read your material safety data sheets and container labels carefully).
  • The waste fails the Toxic Characteristics Leaching Procedure (TCLP), a laboratory test that determines the toxicity level of a substance.
  • The waste contains polychlorinated biphenyls (PCBs) at a concentration of 50 parts per million (ppm) or more.

 

Depending on the amount of hazardous waste generated, your business can fall into one of three categories:

  • Very Small Quantity Generator (VSQG)
    220 pounds or less per month (about 1/2 drum liquid or less)
  • Small Quantity Generator (SQG)
    More than 220 pounds but less than 2200 pounds per month (about 1/2 to 4 drums liquid)
  • Large Quantity Generator (LQG)
    2200 pounds or more per month (about 4 drums liquid or more)

 

Some, but not all, metro counties have established a fourth category, Minimal Generator. This category, for businesses that generate less than 100 pounds (10 gallons) of hazardous waste per year, is also available to generators outside the six county Twin Cities metro area.

Different management requirements apply to each category. Contact your county hazardous waste office for help in evaluating your waste or determining your status as a generator.

See the MPCA fact sheet Evaluate Waste; Determine Generator Size (from the "10 Steps to Compliance" series) for additional help.

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Step 2: Apply for a Hazardous Waste Identification Number (formerly a U.S. EPA ID) and the Required License

With few exceptions, all businesses that generate hazardous waste are required to obtain a license for that activity. First, obtain a hazardous waste identification number specific to your site from the Minnesota Pollution Control Agency (MPCA). This number has replaced the U.S. EPA identification number. Second, contact your county hazardous waste office to apply for a hazardous waste generator license.

Contact your county hazardous waste office for assistance in fulfilling these requirements. Generators must apply for an identification number within 75 days after first generating a hazardous waste - prior to any transportation, treatment, disposal, or shipment of hazardous waste.

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Step 3: Store and Label Your Waste Properly

Hazardous waste must be stored in a sturdy, leak proof container that is kept closed when not adding or removing waste. Different kinds of waste may require different types of storage containers. The container must be labeled with the words "Hazardous Waste," a clear description of the contents and the date waste is first placed in the container. Containers must be stored on an impermeable surface with enough aisle space to allow for weekly container inspections.

Additional requirements for outdoor storage include:

  • Controlling access to the containers.
  • Protecting the containers from the elements.
  • Storing containers of liquid waste on a curbed and impermeable surface to contain accidental leaks.

 

See the MPCA fact sheet Mark and Store Hazardous Waste Correctly for additional help.

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Step 4: Transport and Dispose of Your Waste Properly

Generators are responsible for their hazardous waste forever. To help ensure that hazardous waste is transported and disposed of properly, and to reduce your liability, choose a transporter that fulfills the following requirements:

  • Has a hazardous waste identification number (formerly a U.S. EPA ID).
  • Is currently licensed or permitted as a hazardous waste transporter by the Minnesota Department of Transportation.
  • Has fulfilled specific training requirements.
  • Maintains adequate liability insurance.
  • Carries credentials in the vehicle.
  • Transports the waste to a permitted hazardous waste facility.

 

See Hazardous Waste Brokers, Transporters and Disposal Facilities for businesses that offer services to help companies properly dispose of hazardous waste.

See the MPCA fact sheet Treat and Dispose of Hazardous Waste Correctly for additional help.

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Step 5: Manifest Shipments of Hazardous Waste

A manifest is a specialized, multi-page shipping document that must (with a few exceptions) accompany off-site shipments of hazardous waste. It's a "cradle to grave" record of what happens to your hazardous waste from the time it leaves your facility until it reaches a proper destination. Generators are responsible for preparing a manifest to accompany the waste when it leaves the site. Transporters may prepare the manifest as part of their service; however, the hazardous waste generator is responsible for the contents of the manifest.

Check the manifest carefully. Generators should contact the facility if they have not received the final copy of their manifest to ensure that the waste was received and was properly treated and/or disposed. Qualified businesses may also use the Very Small Quantity Generator Collection Programs. Call your county hazardous waste office for more information on manifests.

See the MPCA fact sheet Manifest Shipments of Hazardous Waste for additional help.

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Step 6: Plan for Emergencies

Plan for emergencies in the following ways:

  • Maintain spill and appropriate emergency response equipment in an accessible area.
  • Train employees in the emergency response procedures that are appropriate for your site.
  • SQGs and LQGs are subject to further requirements. Contact your hazardous waste regulator for further information.

 

Contact the Minnesota Pollution Control Agency or your county hazardous waste office for more detailed emergency planning requirements.

For additional help, see the following MPCA fact sheets:

 

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Step 7: Train Personnel

Training all personnel who have any role in handling, storing or otherwise managing hazardous waste is a necessary step for ensuring compliance with hazardous waste rules. Personnel must be familiar with each waste's hazards, appropriate safety procedures and all aspects of compliance.

While some issues may be similar, hazardous waste training is not the same as employee right-to-know training.


Personnel training requirements vary with generator size. For example, SQGs and LQGs are required to document personnel training. Although VSQGs do not have training requirements under the hazardous waste rules, it is highly recommended that training be provided to ensure that the rules are followed.

In addition, the United States Department of Transportation requires training for employees that package or prepare hazardous waste or materials for transport, regardless of generator size. Supervisors of these employees must also receive training, which must be documented in the employee's file. For more information, visit the Minnesota Department of Transportation (MnDOT) web site or call (651) 405-6060. For information on training opportunities, call your county hazardous waste office.

For additional help, see the following MPCA fact sheets:

 

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Step 8: Keep Records

Unless otherwise noted, the following records must be kept onsite and available for inspection for 3 years:

  • Manifests and recycling receipts.
  • Weekly inspection logs.
  • License applications and renewals.
  • Analytical and other reports.
  • Training documents (SQGs and LQGs).
  • Land Disposal Restriction (LDR) forms for a minimum of five years.
  • Documentation of emergency notification of local authorities for SQGs and LQGs
  • Contingency plan for LQGs

 

In addition, the United States Occupational Safety and Health Administration (OSHA) requires businesses to keep pertinent Material Safety Data Sheets (MSDS) for 30 years. Companies are advised to keep all inspection reports, compliance letters and other correspondence regarding their hazardous waste. For more information, call your county hazardous waste office.

See the MPCA fact sheet Keep Records for additional help.

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