Waste generation and disposal

You need to know how and where a waste is generated to minimize or eliminate it. You can decrease the amount of waste your business produces by not mixing wastes, replacing a material or process with another that makes less waste, recycling and reusing manufacturing materials such as oil, solvents, acids, and metals, and safely storing hazardous products and waste containers in secure areas.

The amount of hazardous waste generated per month determines how a generator is categorized and what regulations must be followed. Decreasing the amount of hazardous waste generated through a successful EMS can change your generator category from Large Quantity Generator to Small Quantity Generator or Small Quantity Generator to Very Small Quantity Generator.

Federal regulations identify five specific categories of materials that can be managed as universal wastes: batteries, pesticides, mercury-containing equipment, lamps, and non-empty aerosol cans. Universal wastes must be collected and stored in appropriate containers labeled with the words “Universal Waste”, the type of universal waste (e.g., waste batteries, waste lamps), and be shipped offsite within one year. Like hazardous wastes, there are generator categories for universal waste. Decreasing the amount of universal waste you generate through an EMS can change your generator status and thus what is required of you. Small quantity handlers accumulate less than 5,000 kg of universal waste. Large quantity handlers accumulate 5,000 kg or more of universal waste.

Regulatory citations:

• 40 CFR 240-299

Related Compliance Network subject:

• Waste (SMS topics: waste rags, special waste, universal waste)

Water discharges

The Clean Water Act prohibits anybody from discharging “pollutants” through a “point source” into a “water of the United States” unless they have a National Pollutant Discharge Elimination System (NPDES) permit. The permit will identify limits on what can be discharged, monitoring and reporting requirements, and other provisions to ensure that the discharge does not harm water quality or human health. If your EMS decreases your discharge from your point source into waters of the U.S. it will likely impact your NPDES permit.

Federal regulations at 40 CFR 122.26(b)(14)(i)-(xi) require stormwater discharges associated with specific categories of industrial activity to be covered under NPDES permits (unless otherwise excluded). The Multi-Sector General Permit (MSGP) covers industrial facilities in 29 different industrial sectors. A site-specific stormwater pollution prevention plan (SWPPP) explains how you will control pollutants in stormwater runoff from your facility. It must be completed before you apply for permit coverage. The SWPPP relates to an EMS because both are reducing environmental impacts and increasing operating efficiency.

Regulatory citations:

• 40 CFR 100-145
• 40 CFR 220-232
• 40 CFR 410-471

Related Compliance Network subject:

• Water Programs

Air emissions

EPA has set air quality standards for six common “criteria pollutants”: particulate matter, ozone, sulfur dioxide, nitrogen dioxide, carbon monoxide, and lead. Federal regulations require each major source of air pollutant emissions to obtain an “operating permit” that consolidates all the air pollution control requirements into a sole, inclusive document covering all parts of the source’s air pollution activities. Air pollution permits are also required for businesses that build new pollution sources or make substantial changes to current pollution sources. Decreasing air pollution through an EMS could alter your air pollution permit if you are a major source.

Regulatory citations:

• 40 CFR 50-99

Related Compliance Network subject:

• Air programs