‘Hazardous waste’ calls to mind glowing tubs of nuclear or biological residues. But in fact, every household and most businesses will generate some hazardous waste. This could be used lightbulbs or old batteries, residues from auto engine maintenance — or large quantities of sludges left over from complex chemical manufacturing, and everything in between. It all needs to be disposed of appropriately.
In this post, we’ll look at what hazardous waste is, where it needs to be disposed of, and how to find the right place to dispose of it. We’ll look at how the international community views trade in hazardous waste, which US laws govern what we do here at home, and how to locate appropriate transport and disposal facilities for commercial-scale hazardous wastes.
We’ll start at the beginning.
What is hazardous waste?
Hazardous waste seems like it has a commonsense definition: if you throw it away, and it could be dangerous, it’s hazardous waste.
In fact, there are complex laws that define what is and isn’t hazardous waste around the world. In the USA, the main agency that defines and regulates hazardous waste is the Environmental Protection Agency (EPA). A waste is hazardous if it appears on the F, K, P or U lists of the Code of Federal Regulations (CFR), Part 261.
When we talk about hazardous waste here in America, here’s what we’re talking about:
The F list and the K list
The F list is a list of hazardous wastes that are defined by what they are, not by where they come from. It includes solvents, wood preservatives and mining leaching wastes. You can view the full F list here.
The K list defines hazardous wastes in terms of where it comes from. It addresses the wastes from 13 industries, including chemicals and explosives manufacturing, iron, steel, aluminum production, and lead processing. You can view the full K list here.
The P list and the U list
The P and U lists designate hazardous chemicals that are unused. Rather than being waste products from production or processing, they’re chemicals and substances that are dangerous in and of themselves and are being thrown away unused. To qualify, the substance has to be commercially pure and unused.
Characteristic wastes are identified by what they can do. So rather than define certain molecules as dangerous, the law says, ‘if it might explode, it’s hazardous.’ The four types are ignitable, corrosive, reactive, and toxic. The definitive list of characteristic wastes is the CAL/EPA index.
Finally, there are the HAZMAT (HAZardous MATerial) definitions. These include nine types of universal waste defined by how it needs to be treated and the hazards it presents during transportation. So in the HAZMAT system, explosive wastes are broken down six different ways, including Type 1.3: minor blast hazards, and Type 1.6: very insensitive explosives.
To see more detail on how all this works, check out our post on different types of waste.
You and your hazardous waste: where does household hazardous waste end up?
Households are a major source of hazardous wastes. And it’s where most of us are going to experience the process directly. Where do all those lightbulbs, used batteries, spent cartridges, car parts, lubricants and solvents, paints, and so on go to?
In Oregon City, city facilities collect multiple classes of hazardous wastes, and most are recycled or reused. Latex paints, about 40% of the hazardous waste at the Metro waste center, are reblended. Fluorescent lightbulbs are transported to a facility to have their mercury safely removed.
Fuel-usable waste is crushed and the fuel extracted, allowed to off-gas to reduce explosion risk, and shipped to plants that use mixed fuels elsewhere in America, including an alternative-fuels cement kiln in the Midwest. If they don’t know what it is or if it’s safe, they take it to an onsite lab to test it.
But not every household is in Oregon. What about other locations? In South Carolina, most household waste is landfilled (see below), in landfills that aren’t designed to handle hazardous wastes. That would include everything we mentioned from the Oregon City facility. If hazardous wastes aren’t removed from the waste stream they can poison, injure or maim city waste workers, as well as leaching into soil, water and the atmosphere.
The situation is not much better if these wastes are poured down the drain. In septic systems they can prevent filtration and purification from working properly, or pass through the process unchanged and contaminate standing water and drinking water. The situation is similar in sewage treatment plants which also rely on bacteria for their effects.
Even so, both options are better than burying it or pouring it into ditches, where it can directly poison pets, injure people and damage local streams, rivers and fields. Burning carries its own risks of poisonous fumes, explosions, and uncontrollable fires.
So what should you do if you don’t have an Oregon City-type recycling station on your doorstep?
The responsibility falls to you to manage household hazardous waste. Find a gas station that will take your old oil and transmission fluids from your car or lawnmower. Strain old paint thinner, trash the solids and store the thinner safely in a jar to be reused. You can wait for a community collection day, store the material safely at home until you figure out what to do with it, or donate it to local groups, charities or individuals that need your unfinished paints, solvents and so on.
Finally, you can take it to an approved facility for disposal. In other words, households face more or less the same choices as businesses and institutions when it comes to disposing of hazardous waste!
How does the world deal with hazardous waste?
Different countries around the world have different approaches to hazardous wastes. To generalize, more-developed nations tend to have stricter environmental health laws. Alongside national regulations there are international rules that establish a global floor for hazardous waste management, though they’re regularly flouted.
Alongside this, there are countries and jurisdictions that lead the way in domestic or regional hazardous waste handling, or that pursue ambitious programs of waste reduction.
In the USA, California’s successful beverage container recycling program includes ‘nudge’ incentives to recycle aimed at individuals combined with recycled-material content requirements aimed at manufacturers.
In the EU, a bloc-wide recovery, recycling and reuse approach aimed at a ‘circular economy’ in which waste streams are re-fed back into supply chains is under discussion.
The international hazardous waste trade
Hazardous waste sometimes contains economically salvageable materials. Especially in countries with low labor costs and weak environmental health legislation, this can make hazardous waste a valuable raw material. Alongside this effect, there are companies that simply pay less-developed nations to accept and landfill or otherwise dispose of hazardous waste beyond the remit of their environmental health agencies.
The extent of this trade can be overstated. While transboundary hazardous waste transactions are common they are also regulated, most notably by the Basel Convention (see Hazardous waste and international law).
Hazardous waste and human rights
Hazardous waste disposal can fall under international human rights legislation if it imperils life and health, as:
‘Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family’
The Probo Koala toxic spill in Côte d’Ivoire continues to attract international attention precisely because of these human rights implications; human rights bodies continue to discuss the wider implications of the subject. In particular, the people most likely to suffer ill effects from mishandled toxic wastes include indigenous people, people of color, women and children, especially in the global South.
And the UN Special Rapporteur on Toxics and Human Rights continues to work based on a mandateestablished in 1995 and most recently expanded in 2020, which includes a cradle-to-grave approach to waste management and takes in industries like shipbreaking, not just waste disposal per se.
Hazardous waste and international law
International law governs how countries and companies can trade in hazardous waste as well as establishing a theoretical floor for management and disposal worldwide.
When waste is transported across national borders, it’s regulated by the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, adopted in 1989. (The USA has not yet ratified this convention.)
The Basel Convention imposes the following requirements:
- Exporting countries must notify receiving countries and any countries the waste will be transported through of the proposed shipment
- The shipment can only take place once the receiving and transit countries have given consent
- An international movement document must accompany the shipment from its point of origin to its ultimate recycling or disposal
- Shipments must be packaged, labeled and transported according to international rules
- If an accident occurs, the responsible parties must inform any potentially affected countries of the accident
- Parties to Basel must submit an annual report to the Basel Secretariat summarizing the amounts and types of hazardous waste exported or imported, and the destinations and disposal methods
- Exports of waste cannot take place between parties and non-parties to the Basel Convention, except where these take place under a separate agreement that provides an equally sound management structure for transboundary waste movement.
- Exports of waste can only take place:
- If the exporting country does not have enough recycling or disposal capacity
- If the exporting country does not have disposal and recycling facilities that can manage the waste in an environmentally sound way
- If the wastes are required as a raw material for recycling or recovery industries in the destination country
Hazardous waste in the USA
We’ve looked at what constitutes hazardous waste in the USA. And we’ve talked about how households should get it out of the general waste stream. When households and businesses do this, where does it go next?
This depends on the type and level of hazard involved. Most hazardous waste in the USA goes to specific landfill types, some is chemically treated, and some is incinerated.
Where does it go?
Landfill is the most common waste disposal method. It’s not the same as just dumping trash in a hole. Even fairly basic landfill sites use membranes to prevent leaching. US landfill types are defined by the EPA as:
- Industrial waste, construction and demolition (C&D)
- Coal combustion residue (CCR/Coal ash)
- Polychlorinated biphenyl (PCB)
- Municipal solid waste (MSW)
- Hazardous waste
We’re interested in the last two, because not all hazardous waste has to go to a hazardous waste landfill.
Municipal solid waste landfills are state-managed mixed-waste landfill sites that take household and nonhazardous waste as well as some sludges and some hazardous waste. They’re regulated under Subtitle D of RCRA (Resource Conservation and Recovery Act). CFR Title 40, Chapter 1, Subchapter 1, part 258 subjects them to rules regarding groundwater testing and requirements for specific types of liner, leachate removal, and rules regarding operating practices and financial assurances to ensure the money will be there to safely close them up when they’re full.
They’re not the preferred destination for hazardous wastes and it’s against the law to dump hazardous wastes in most of the USA’s 1,908 MSW landfills. But the EPA does permit the disposal of a particular type of hazardous waste, PFAS waste, in MSW landfills.
If you need to dispose of solvents, explosives, toxic chemicals or anything else off the lists we talked about earlier, you’ll need a hazardous waste landfill licensed under Subtitle C of RCRA. The good news about these landfill sites is that they’re much more strictly controlled than MSW landfills, and therefore much safer. The bad news is that the USA has just 21 of them. Management of hazardous waste is therefore a matter of transporting them, storing them and finding the right site, not simple disposal.
Some wastes can safely be disposed of by incineration. The waste mixed fuels from the Oregon recycling facility we talked about earlier are in a sense being incinerated!
Incineration in the USA comes in two main forms, ordinary low-temperature incineration and special very high-temperature incineration. Incineration sites for ordinary incineration are more common, but very high-temperature sites operating at over 1,000°C are much rarer.
The EPA matches storage and disposal requirements to waste type, so it’s vital to get the whole process right. Waste producers remain responsible for their waste right up until it’s finally disposed of, and the most common reason for citations for hazardous waste is incorrectly filled out manifests and mislabelling. These citations can run to tens of thousands of dollars, per incident, per day.
How does it get there?
Specialized waste transportation companies handle movement and in-transit storage of hazardous waste. Some do this as part of a suite of related services, as with Texas-based Sprint Waste, which offers specialty haulage and waste management services.
Sometimes waste producers handle some of their own waste on-site. Others have longstanding agreements with haulage companies, or near-vertical integration along the waste lifecycle. But for most waste producers, if we’re looking beyond a quart of paint thinner in the garage and to commercial applications, you’ll need to put together transportation and disposal infrastructure to match the waste type and the corresponding regulatory requirements.
Stitching together the hazardous waste management process
It’s time to meet Wastebits Insights. If you’re completely new to Insights, there’s a guide here — and if you’re more interested in tracking down waste generators, there’s a guide to doing that here. But we’re going to assume that you are the generator, that you’re looking at a significant amount of waste that you need to dispose of in a compliant manner, and that you don’t have arrangements already made.
First port of call: head over to wastebits.com/insights and hit ‘sign up for free.’ No credit card, no commitment, and you’ll be able to easily follow along with a lot of this how-to section.
Now, what kind of waste are you dealing with? Insights lets you search by federal code, state codes, and descriptions. Let’s go with wastes from secondary lead processing, as those can be pretty nasty and require specific handling at every stage.
The federal code for those wastes is D008 — Lead. So I can search for that in Insights under Transportation, using my (well, the 30 Rock building’s) New York zip code:
This produces a ton of transporters from all over the country. Let’s assume I just want to call up Shamrock Materials in New York. All I have to do is click on them and I get the contact details (including their postal and registered addresses):
I also get to see what kind of quantity they transport.
That’s not a lot of manifests. Maybe I should find another transport company. I set my preferred radius from 30 Rock at 25 miles to get all New York companies, and search again. On the right-hand side of my search results, you can see the manifest numbers and tonnage:
That lets me determine which size of company is best for me. All these companies are licensed to carry lead wastes, but Shamrock seems to carry very large shipments — over a quarter of a million tons, spread over just 171 manifests in the year to February 2021. ACV has a lot less volume, with a lot more manifests. Maybe they’re a better choice. It depends on how much waste you need to move, now and regularly.
Some transportation companies have their own preferred routes and destinations. Some, like Sprint, have their own landfills. But you can use Insights to identify disposal facilities too.
Up here, on the top left of the Insights dashboard, I just have to click Facilities to see the same search parameters applied to disposal facilities rather than to transporters.
I get five results:
These are all facilities that are licensed to dispose of lead wastes. But what about if I know my wastes need a specific disposal method?
To get my lead waste chemically treated, I have to expand my search to a 100 miles radius and find Pennsylvania- and Connecticut-based firms. But now I know who to call.
Using WasteBits to stitch together your waste management pipeline is that simple.
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