Insights into the regulatory aspects of handling business waste at HHW facilities.
By Kiana Sladick

Welcome to NAHMMA Corner! Continuing our discussion on “Establishing Operations at Household Hazardous Material and Very Small Quantity Generator Collection Facilities” (Waste Advantage Magazine, February 2023), this month’s article will provide a more in-depth discussion on generator status. Specifically, handling the Very Small Quantity Generators (VSQG) of hazardous waste and assisting larger generators, Small Quantity Generators (SQG), and Large Quantity Generators (LQG) of hazardous waste, at Household Hazardous Waste (HHW) facilities.

In reading February’s NAHMMA Corner article, you may have classified your HHW facility as one that serves both residential customers and business customers who are VSQGs. Or, maybe, you are weighing the pros and cons of expanding your HHW facility operations to include this service. Along with operations that were considered in previous articles, there are a handful of regulatory aspects to keep in mind to properly handle and assist hazardous waste generators.

Handling VSQGs
Let’s take a step back and discuss what a VSQG is. Note that VSQG replaced the term Conditionally Exempt Small Quantity Generator (CESQG) in states that have authorized the Generator Improvements Rule. Any non-household facility such as, but not limited to, a business, educational institution, non-profit organization, municipal facility, or hobbyist could be a VSQG. To fall into the VSQG generator category, a facility must generate between zero to 220 pounds of hazardous waste and/or less than 2.2 pounds of acute hazardous waste in a calendar month. When we talk about acute hazardous waste, think unused, commercial grade chemicals (like certain “old brown bottles” from a laboratory or most commonly, pure liquid nicotine). You can check out the full list of acute hazardous waste in 40 CFR Section 261.33. In addition, a VSQG cannot accumulate more than 2,200 pounds of hazardous waste and/or 2.2 pounds of acute hazardous waste onsite at any one time.

Anything over these limits brings a facility into the generator status of SQG or LQG, which is important because regulations prohibit SQGs and LQGs from self-transporting their hazardous waste. Regulations require their hazardous waste to be manifested by a licensed hazardous waste hauler from their site for disposal. This does not let VSQGs off the regulatory hook though. VSQGs are legally required to make a hazardous waste determination on any waste they generate, properly treat their waste, or ensure proper delivery to a Treatment, Storage, and Disposal Facility (TSDF), and in some states keep their disposal records. This of course brings financial costs and burden to the table for VSQGs when needing to find a disposal outlet.

While a VSQG generates a lot of typical HHW streams, there is a lot of industry specific waste they can generate to take into consideration. Process wastewaters, laboratory chemicals, solvent parts washer waste, and contaminated rags to name a few. These wastes may even carry certain waste type codes from the F, K, U, or P (acute hazardous) lists—all of which can be found in 40 CFR 261 Subpart D.

Check with your state regulatory agency on what options an HHW facility has regarding VSQG collection, whether it is comingling business waste with HHW or having dedicated drop-off times for VSQG waste. With both, there are also regulatory guidelines for the HHW facility to follow. Aside from the paperwork, training, container requirements, and other HHW facility regulatory requirements that may apply, verifying the amount of waste from a VSQG is crucial to ensure regulatory requirements are met. Having limits specific to your HHW facility or monitoring the poundage of waste coming in from a VSQG will aid in regulatory compliance for all parties involved. In addition, if your city or county does not have a local SQG inspection program that is aware of who the SQGs and LQGs are in your area, your state regulatory agency may have a list of businesses that have notified the state of their generator status. This, along with monitoring VSQG waste drop-offs, can help you run a successful operation.

All in all, hosting an option for VSQGs to self-transport their waste to your HHW facility can save them from the financial costs and burden of having a hazardous waste transporter come to their site and instead offer them a convenient option to pay for their disposal and get a disposal record. Having a certain timeframe, appointment, or even an event to allow this type of waste to come in ensures this type of waste will be properly managed. Having your vendor present for this collection may also aide in a smooth experience for the VSQG.

Assisting Larger Generators
Hosting a collection for VSQGs may draw the attention of SQGs and LQGs and even though they cannot self-transport their hazardous waste, an HHW facility can still offer assistance to these larger generators. For instance, the HHW facility can offer their vendor
information and their contract negotiated rates to larger generators so the business can reach out to the vendor and set up a pickup directly at their site. Another option is allowing larger generators to self-haul non-hazardous waste, universal waste, or electronics to the VSQG collection at your HHW facility. Non-hazardous waste can be self-transported and does not need to be manifested from a generator’s site. If your vendor is properly recycling universal waste, electronics, or used oil and antifreeze, these wastes do not count as a hazardous waste to the generator if they are properly recycled, allowing larger generators to self-transport these waste streams.

Putting it into Practice
Since June 1992, Pinellas County Solid Waste has hosted a Business Electronics and Chemical Collection Event the second Wednesday of every month from 9:00 A.M. to 4:00 P.M. at our HHW facility in St. Petersburg, FL. In its first quarter, the event saw a mere 22 VSQG (known as CESQG then) customers from June to September 1992. Operated by our contracted vendor, businesses can come at any time during this window and directly pay the vendor who
packages the waste in accordance with all DOT requirements, gives the business a disposal receipt, and takes all waste at the end of the event for proper management.

Since January 2018, we have staffed this event with one of our County SQG Program inspectors to work alongside our contracted vendor. By staffing this event with a County SQG Program inspector, we can better screen and educate the businesses to ensure they are a VSQG or are a larger generator only bringing in non-hazardous or universal waste or electronics. The event has grown exponentially since its inception in June 1992. Since January 2018, we have hosted 2,699 business participants, collecting 423,748 pounds of chemicals, 360,599 pounds of electronics, and 443,580 pounds of latex paint, providing a convenient disposal option for our local generators. | WA

Kiana Sladicki works at Pinellas County Solid Waste as a Hazardous and Solid Waste Inspector for the Pinellas County SQG Program. Prior to that, she was a Compliance Inspector for the State of Florida Department of Environmental Protection. She has conducted more than 500 hazardous waste facility inspections between both agencies, visiting everything from small VSQGs to TSDFs. At Pinellas County, she also works the monthly VSQG collection events and assists the HHW facility operations and their mobile collection events. Kiana can be reached at (727) 464-7548 or [email protected].