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Any facility that uses hazardous materials or generates a hazardous waste is required to follow certain procedures when handling those materials of wastes. A good summary of the requirements is provided in the Florida Department of Environmental Protection (DEP) guide for Small Quantity Generators of Hazardous Waste.
Below are some important general issues and best management practices for hazardous waste generators. This is not a comprehensive description of the regulations, nor does it include specific permit conditions that may apply to a facility. There are also additional guidelines available based on generator status.
It is the facility's responsibility to comply with Occupational Safety & Health Administration (OSHA) worker safety and protective clothing rules; fire codes; Florida's Right to Know Law; Superfund Amendments and Reauthorization Act (SARA); etc.
Waste disposal requirements
- All hazardous waste must be disposed of via a permitted hazardous waste transporter and taken to a federally-approved hazardous waste disposal or treatment facility. Receipts of all waste disposals and hazardous waste manifests must be retained for no less than three years at the generator’s facility and available for review.
- In all situations where the waste is deemed to be hazardous, a permitted hazardous waste transporter must be used to transport the waste to a federally-approved hazardous waste treatment or disposal facility. The facility generating the hazardous waste is required to obtain an Environmental Protection Agency identification number unless classified as a conditionally exempt generator, by contacting:
Florida Department of Environmental Regulation
Department of Waste Management, HWRS, MS4
2600 Blair Stone Road
Tallahassee, Florida 32399
- If the waste solvents can be recycled by the facility generating the waste, the solvent still-bottoms/sludge from the reclaiming operation must be collected and handled as a hazardous waste, unless proven otherwise.
- If the waste solvent is recycled by a permitted solvent recycler, receipts must be obtained from the recycler and copies kept at the facility.
- Regardless of generator designation, all hazardous waste shall be properly disposed of.
- Conditionally Exempt Small Quantity Generators (CESQGS) are exempt from the requirement to manifest their wastes.
- Small Quantity Generators (SQG) and Large Quantity Generators (LQGs) shall manifest their waste and obtain an EPA/DEP generator number.
- Disposal records shall be maintained on site for a period of three years.
Storage areas and requirements
In Miami-Dade County, because of the need to protect our drinking water supply, many of the storage requirements for hazardous wastes also apply to storing virgin chemicals.
- Containers shall be maintained in good condition, i.e., sound (not damaged). Containers shall be compatible with the hazardous waste stored in them and approved containers shall meet US Department of Transportation standards (DOT).
- Containers holding hazardous waste shall be maintained closed, except when adding to or emptying the container.
- Containers shall bear labels identifying their content as well as the date storage began.
- When stored outside of working bays, used oil containers shall be labeled as such, covered, and equipped with secondary containment.
- Chemical storage areas must be on an impervious surface with secondary containment or a bermed and covered area away from drainage structures (e.g. floor drains or storm drains). This containment area should be able to hold 110% of the volume of the largest single tank/drum to be stored in this area.
- In large storage areas, there must be aisle space between storage products. This will enable inspection of the container for leaks and/or corrosion.
- Incompatible chemicals or materials should be stored separately.
- Provide appropriate signs and markings so that the Hazardous Waste Storage Area may be readily identified.
- Label each container with the type of material in it and in the case of hazardous wastes, use the words "Hazardous Waste."
- All above ground tanks and storage areas for hazardous materials and hazardous wastes shall be stored in covered, secondary containment. Design and construction details require Department approval.
- Filters and batteries shall be properly stored and disposed of.
- All discharges to sewers shall meet Miami-Dade County discharge standards.
- Rags used during mechanical repairs or cleaning processes which become contaminated with waste oil or hazardous materials such as solvents, ink, etc. are considered hazardous wastes and may be handled by an approved rag service or an approved hazardous waste transporter. Used rags must not be disposed of in the trash/dumpster unless a hazardous waste profile indicates otherwise and approval is granted by this department.
- Facilities generating more than 10 spent fluorescent and/or high-intensity discharge (HID) lamps per month must have them recycled. Primarily because of the mercury that they contain, these lamps cannot be disposed of in the regular trash. Spent lamps must be stored in a safe location in order to prevent them from breaking. More information can be obtained from the FDEP Mercury Program.
- Try to keep your receipts organized in a single place so that they are easier to review. They should be readily available any time an inspector shows up.
- Waste fluids should be segregated by type and kept separately. This prevents mixing incompatible substances and prevents contamination of a non-hazardous waste by a hazardous waste. This is a good way to reduce disposal costs and often allows each of them to be recycled.
- Waste drum labeling violations are one of the most common. Make sure the correct label goes on it, before anything goes in it.
The federal regulations regarding the determination of hazardous wastes (40 CFR 261) were revised effective September 25, 1990, to replace the Extraction Procedure Toxicity Characteristic (EP Toxic) with the Toxicity Characteristic Leaching Procedure (TCLP).
Information about the TC final rule can be obtained from the March 29, 1990, Federal Register (55 FR 11798 - 11877). Further information regarding the TC Rule can be obtained from the RCRA / Superfund Hotline (1-800-424-9346).
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