We're all aware of the importance of following safety precautions when we work with hazardous chemicals. But we may not realize that safety is just as important with hazardous substances that are no longer used or are produced by our work. These are considered hazardous wastes, and the way we handle and dispose of them can affect the health and well-being of a lot of people.
Improper disposal of hazardous waste can create terrible long-lasting problems. We've all heard or read about Love Canal and other hazardous waste sites that take years and years and millions of dollars to clean up. The problems arise because, over time, the wastes often leak into the soil and water around the sites. That creates a great health risk for people who live, work, play, and attend school on or near these sites. As you may know, the problems are so great in some places that people have had to evacuate their homes.
The hazardous waste sites we hear about were often created at a time when no one knew about the hazards of the substances they dumped. Even where hazards were known, it was believed that the wastes were safe in containers at the dumpsites. And there were no laws restricting where waste was dumped. Unfortunately, containers do deteriorate over time, and the hazardous wastes leak out.
In more recent years, there have also been cases where people illegally dumped hazardous wastes in out-of-the-way places. These people knew the wastes were hazardous, but were more concerned with saving money or avoiding regulation than with protecting the health of people and the environment.
There are no longer any excuses for careless hazardous waste dumping. We know which wastes are hazardous and we know how to dispose of them without causing health or environmental problems. Laws exist and are enforced to make sure that hazardous waste disposal is done in ways that protect ourselves and others and don't create new hazards and new multi-million dollar cleanup bills. This article discusses the laws and procedures we must follow to assure that hazardous waste is disposed of properly and that it's handled carefully at every stage to assure its safe arrival at its final destination.
Let's start by making sure we know just what hazardous waste is. Waste, obviously, is something left over—something we no longer need and throw away. We throw most waste in the trash, and it goes to a landfill or is burned in an incinerator. But it's dangerous—and illegal—to dispose of hazardous waste that way. Hazardous waste is regulated by the Environmental Protection Agency (EPA), which only allows disposal at specific sites that have special permits. These sites are designed especially to dispose of hazardous waste in ways that won't harm people or the environment.
EPA is clear about just what it considers hazardous waste. The federal environmental agency says a waste is hazardous if it has one or more of the following characteristics:
- Contains any of several hundred chemicals specifically listed by EPA as toxic or acutely toxic
- Results from a process listed by EPA as generating hazardous waste. For example, EPA lists a number of spent solvents as hazardous waste
- Is corrosive—can burn the eyes or skin or body tissue on contact. Corrosives can also corrode standard containers
- Is ignitable—can catch fire or explode easily when exposed to heat or a spark
- Is reactive—can catch fire, explode, or give off dangerous vapors if it comes in contact with air, water, or certain other substances
- Is toxic (poisonous)—can cause illness. Some substances are toxic if inhaled, some if they get on the skin, and some if they're swallowed. Some substances may be toxic on the first exposure; others cause health problems as a result of repeated exposures. Sometimes the effects show up immediately—for instance, nausea or rash; other health problems may not show up for years. Often these long-term effects are very serious—for example, organ damage, cancer or even death.
As you can see, wastes that EPA considers hazardous really can pose great risks to human health and the environment. That's why hazardous waste disposal is so carefully regulated. You can never, under any circumstances, dispose of hazardous waste along with the regular trash.
By the way, that's as important at home as in the workplace. If, for instance, you use refinishing products or change the oil in your car, you're creating hazardous wastes. And if you toss these wastes down a drain or throw them out with your trash, you can poison the ground where you dump them or under the landfill where your trash goes. These poisons may also eventually seep into underground drinking water, which puts a whole community at risk.
To prevent these problems, many communities have special hazardous waste collection days. Trained people wearing protective gear collect homeowners' waste and place it in special containers for proper disposal.
There are several forms of safe and proper disposal for hazardous waste. The most common are:
- Incineration. Hazardous waste can only be burned in special incinerators, which burn hotter than those used for other trash and hold the materials longer. These incinerators are also designed to clean any contaminated air or water produced by the burning process. Of course, the operators must prove their incinerators do all this safely in order to receive an EPA permit.
- Landfills. Again, these are not the same landfills that are used for normal trash. They have liners and other protections against the spread of contamination. Even so, they're often viewed as temporary resting places for the hazardous wastes. No container is likely to be able to hold waste safely forever.
- Recycling. Hazardous wastes, like other forms of trash, can sometimes be recycled and reused again for other purposes. Because of the cost and complexity of proper hazardous waste disposal, more and more companies are seeking ways to recycle their waste. But even recycling has to meet strict standards designed to assure that the wastes don't find their way into the environment.
A lot of scientists are working on better and safer ways to dispose of hazardous waste, including experiments with bacteria that 'eat' the wastes. But we can never forget that the waste is hazardous. So we must take every precaution to assure that our disposal methods don't cause a fire or other accident or create a risk to the environment or to human health.
Most workplace chemical safety issues are the responsibility of the federal Occupational Safety and Health Administration (OSHA). OSHA does have a rule (29 CFR 1910.120) that regulates hazardous waste emergency response and clean-up at dangerous hazardous waste sites. That regulation, however, applies mainly to trained emergency response and cleanup crews.
The key federal hazardous waste law is the EPA's Resource Conservation and Recovery Act (RCRA). RCRA regulates the generation, treatment, transportation, and disposal of hazardous waste. In addition, when any hazardous material, including waste, is transported, it has to meet rules issued by the Department of Transportation (DOT).
Many of these legal requirements are the responsibility of employers, not individual workers. For example, RCRA requires employers to identify, handle, store, treat, and dispose of hazardous wastes safely and correctly. Companies must have a plan for responding to hazardous waste fires, explosions, and spills. But some company responsibilities relate directly to you. RCRA requires employers to train everyone who works around hazardous waste to:
- Understand and follow general hazardous waste regulations
- Know how to work safely with hazardous wastes
- Know what to do in an emergency.
DOT has two key regulations designed to assure safety when hazardous wastes are moved from one place to another. These rules mesh with international standards to reduce confusion when wastes move from country to country. The DOT regulations:
- Establish classifications and packing groups for hazardous waste
- Require use of special labels, markings, and placards
- Set out training requirements for anyone who is involved in any way with hazardous materials handling and transport.
How do you know when you're dealing with a hazardous waste? The first thing to check is the container label. These labels are not quite the same as the hazardous chemical labels required by OSHA's Hazard Communication Standard. RCRA requires hazardous waste containers to have a label that:
- Identifies the substance
- Warns against improper hazardous disposal
- Provides the name of the company that generated the waste and the company's EPA identification number. (Any company that generates hazardous waste must receive an identification number from EPA.)
Even empty containers are covered by this rule. A container that once held hazardous wastes must be tested to be sure there are no hazardous residues; then it receives a label that says it's clean and empty.
Follow the same procedures with waste that you use with any hazardous substance. Always check every hazardous waste container to be sure it has a label—and that the label is complete and readable. If you find an unlabeled container, or one whose label is incomplete or illegible, report it immediately.
If a container is ready to be shipped or is en route when you spot it, it should have additional hazard identification required by the Department of Transportation.
- DOT markings identify the contents of a package or container. Markings have the proper shipping name and identification number of the waste and sometimes other information.
- DOT labels are usually diamond-shaped with a picture of the hazard. A flammable waste, for instance, has a picture of a flame. DOT has a detailed Hazardous Materials Table that places each hazardous material into one of nine hazard classes; some hazard classes are also divided further into divisions. The substance's hazard class is identified on the label by a number.
- DOT placards are put on the ends and sides of some motor vehicles, rail cars and freight containers. They have the same graphic hazard identification that's on the labels.
There's a lot of other information on hazardous substances in DOT's Hazardous Materials Table. If, for example, you're involved in preparing a hazardous waste for shipment, the table would tell you what type of packaging to use. It divides substances into three packing groups, based on degree of danger, with packing group I considered the most dangerous.
The Hazardous Materials Table can also tell you a substance's:
- Proper shipping name
- Identification numbers
- Required labels
- Packaging authorizations
- Quantity limitations
- Vessel stowage requirements
- Special provisions.
Another source of information on waste hazards is the substance's material safety data sheet (MSDS). As you know, the MSDS provides a great deal of detailed information on a substance's hazards and the safety precautions you have to follow when you work with it.
The most important document associated with hazardous waste is required by the EPA. It's called the manifest, and it's the key to EPA's management of hazardous waste. EPA uses the manifest to track all hazardous waste from 'cradle to grave'—that is, from the time it's generated to its final disposal.
The manifest begins in the 'cradle'—with the company that generates the hazardous waste. That company has to create a typed manifest to make sure that the many people who receive the document can read everything on it. The generator fills in most of the basic information about the waste. When you check a manifest, you should find:
- The manifest document number.
- The name, address, phone number, and EPA identification number of the company that generated the waste.
- The name and EPA identification number of every company that transports and receives the hazardous waste up to and including final disposal.
- A description of the hazardous waste, including its DOT shipping name, the weight and volume of the shipment, the type of containers used, and the number of containers shipped.
- Any other information required by a state where the waste is generated or where it receives treatment or disposal.
- Signed certification that the wastes are properly classified, described, packaged, marked, and labeled to meet transportation regulations.
- Any special handling instructions, etc.
Everyone who receives a container of hazardous waste must check its manifest to make sure all the information is there and that it's all correct. To underline that responsibility, EPA requires all of them—the generator, shipper, treater, disposer to sign the manifest and keep a copy.
The generator knows that the waste arrived safely at its final disposal site when those responsible for disposal send the generator a signed copy of the manifest. And in case any questions come up later about the waste's handling or disposal, the generator and EPA keep copies of manifests on file for at least three years.
Protection Against Hazards
I'm sure you get the point that hazardous wastes are potentially dangerous and have to be handled and disposed of with care. One of the most important protective measures you can take hazardous wastes: Don't create them in the first place!
Because hazardous waste has so many risks—and because it takes a lot of time, effort, and money to assure proper disposal—we try to avoid creating the waste in the first place. We might do this by:
- Looking for safe alternates to hazardous substances.
- Using up hazardous substances, rather than letting them get outdated so they require disposal.
- Preventing spills and leaks that create hazardous waste.
Despite these efforts we still sometimes do create waste that's hazardous. That means we have to use all the preventive measures at our disposal to reduce the possibility of accidents.
One of the most important preventive measures is to train every employee who has any role having hazardous waste to understand the hazards and follow safety procedures.
RCRA's training requirements are much like OSHA's rules for anyone who works with hazardous chemicals. As I mentioned earlier, RCRA requires those who work in a facility that treats, stores, or disposes of hazardous waste to know:
- General hazardous waste regulations.
- How to identify hazardous wastes and handle them safely.
- How to select and use protective clothing and equipment, including respirators.
- What to do in an emergency.
The Department of Transportation also requires similar training for anyone who handles hazardous materials or their shipping containers, prepares hazardous materials paperwork, or is involved in transport. DOT requires different levels of training, depending on the employee's job, but it covers much the same ground as the chemical safety training required by OSHA's Hazard Communication Standard.
All the agencies have similar training requirements because they focus on increasing your knowledge of the hazards you work with and making sure you know how to protect yourself and others from those hazards. Let's look at a few key areas now.
Personal Protective Equipment
Personal protective equipment (PPE) and clothing is an important defense against dangerous exposure to any hazardous substance including hazardous waste. When you work with hazardous wastes, you'll be provided with PPE that's designed to be an effective barrier between you and the waste's particular hazards. You may also be asked to refer to material safety data sheets for additional information on selecting gear that can protect you.
Safe handling of corrosive or toxic wastes may require you to wear:
- Safety goggles and/or a face shield.
- Gloves and/or protective clothing that resist the particular substance.
- Boots or shoe covers.
- Respirator, if there's a danger associated with inhaling the substance.
As you know, your health and safety often require you to use assigned PPE—after inspecting it to be sure it's in good condition to protect you. You also have to remove PPE carefully so you don't contaminate yourself or any clean area.
Another way to protect against the dangers of hazardous waste is to prevent spills—or, at worst, spot them as soon as a tiny leak develops. To assure that, EPA requires frequent inspections of the portable containers and stationary tanks used to hold the wastes.
Hazardous waste containers should be inspected at least weekly for leaks or any corrosion that could cause leaks. As a further protection, the containers must be stored on a base that won't let leakage seep out. That base must not, of course, have any cracks, holes, etc.
Hazardous waste storage tanks sit above the ground or floor and should be inspected daily for leaks or corrosion. The daily inspections should also include the tank's gauges and controls—for temperature, pressure, overfilling, etc.—to be sure they're accurate and don't reveal any danger.
One of the key forms of hazardous waste protection is to keep wastes separated from incompatible substances. As you know, when incompatible substances come together, they can produce dangerous reactions such as heat, pressure, fire, explosion, and release of toxic or flammable fumes.
So when you work with hazardous wastes, read the MSDS sections on fire and explosion hazards and on reactivity carefully. Then check that hazardous wastes are never too close to anything that could cause a dangerous reaction. If a waste is flammable or combustible, for instance, you'll need to keep it away from heat or ignition sources and follow other precautions to prevent fires or explosions.
Another way to protect against dangerous reactions is to make it a policy to never mix hazardous substances unless you've been specifically told that it's safe and acceptable to do so. Remember that some substances create dangerous reactions if exposed to water.
Reactions sometimes occur with containers believed to be empty. When an empty container hasn't been thoroughly cleaned—and certified as such—putting another substance in it can cause an explosion or other reaction. So don't assume a container is 'empty' unless it has a label that says so.
We've talked about some ways you protect yourself against the hazards of hazardous waste. Again, every waste, like every hazardous substance, is different and requires different protections. But if you follow some basic 'Do's' and 'Don'ts' you should be able to avoid accidents when handling hazardous waste and do your part to assure that the waste arrives safely at its final destination.
- Check labels and MSDSs before handling a hazardous waste.
- Report any container whose label is missing, incomplete, or illegible.
- Be sure that each hazardous waste container is accompanied by a complete and accurate manifest.
- Use the PPE provided by the company to protect yourself against hazards.
- Follow decontamination procedures when removing PPE.
- Wash thoroughly and carefully after handling hazardous waste.
- Keep hazardous waste work and storage areas well ventilated.
- Keep containers closed when not in use.
- Separate ignitable waste from sources of flame, spark, or heat.
- Know where to find fire extinguishers.
- Transfer hazardous wastes carefully to prevent spills.
- Be sure that waste containers are properly grounded and bonded to prevent accidental electrical ignition.
- Select and use tools that won't create dangerous sparks or chemical reactions.
- Block or brace packages so they won't move during transport, even within the facility.
- Turn off vehicle engines and block wheels before loading or unloading hazardous waste packages.
- Don't eat, drink, smoke, or apply cosmetics in an area containing hazardous wastes.
- Don't keep food, beverages, or utensils in a hazardous waste area.
- Don't enter hazardous waste storage areas without authorization.
- Don't mix hazardous wastes with anything—including water—without specific instructions.
All these precautions should prevent hazardous waste emergencies. But RCRA requires companies to prepare for the worst with a written plan that spells out how to handle any type of emergency involving hazardous wastes. In addition to training emergency responders to deal with these emergencies, companies must also train all employees so they know:
- How to report spills, fires, and other emergencies—and how to recognize alarms.
- How to evacuate the facility.
- Where to find first aid stations, emergency showers, or eyewashes, spill control or firefighting equipment, phones and alarms.
As you know, immediate, proper response is the best way to keep an emergency from becoming a disaster. You'll leave most emergencies to trained and equipped responders. Here's who to call and how to do it if there's a hazardous waste spill, fire, or explosion. (Note: Provide any appropriate instructions at this time.)
You also have to be able to react quickly if you're exposed to a corrosive or toxic waste. In most cases, you will:
- Get to the nearest emergency shower or eyewash and wash the affected areas immediately and thoroughly with water for at least 15 minutes.
- Check the substance's MSDS for more specific instructions.
- Get medical attention promptly.
Today we've had an overview of hazardous waste disposal—and the precautions we take to assure that hazardous waste gets to a proper and safe disposal site without causing an accident along the way.
I'm sure you realize that hazardous wastes are like any other hazardous substance; they demand respect and caution during every stage of handling, storage, transport, and disposal. EPA's rules—and the manifest that accompanies each shipment—track hazardous waste from cradle to grave to make sure safety is enforced. Since everyone who handles that waste has to sign and certify that the manifest is accurate, there's some pressure to make sure that the waste really does end up in the safe disposal site chosen for it.
When you encounter any form of hazardous waste, check its labels, MSDS, and manifest so you know exactly what you're dealing with and what its hazards are. If a waste is unidentified, report it immediately. And if you have any role at all in handling that waste, use our safety procedures and personal protective equipment to prevent accidents or dangerous exposure.
The law requires us to dispose of our hazardous waste in ways that won't put anyone at risk. And our own good sense supports the legal requirements. We don't want to risk an accident or discover that our waste was dumped carelessly and illegally at a site that could cause harm.