Hazardous waste. Just those two words alone evoke terrifying images — skull and crossbones, workers in protective "moon suits," leaking and corroded 55-gallon drums, Love Canal. Those are the images Hollywood and the nightly news would have us associate with the words hazardous waste. But hazardous waste need not be that dramatic. In fact, those of us involved in fleet maintenance are challenged with hazardous waste management issues on a daily basis. Hazardous waste regulations are the most comprehensive of all waste management regulations. We have all heard the phrase "cradle to grave," which describes the regulation of hazardous waste from the time it's generated to its final destination: landfill, recycling, treatment or incineration. For every hazardous waste you generate, there are regulations that cover its handling, storing, manifesting, transporting and disposal. And violations of these regulations carry severe penalties. Common yet potentially hazardous wastes generated by vehicle maintenance facilities include:
degreasing and cleaning solvents
used motor oils
used motor oil filters
spent engine coolant
water that has come into contact with gasoline, motor oil or other hydrocarbon products
water that has accumulated in the bottom of product storage tanks
used shop rags
"oil dry" absorbent floor cleaning materials
leftover paint, used paint thinners, etc. Do you generate hazardous waste? If you don't know, you'd better find out! According to current hazardous waste regulations, it is the responsibility of waste generators to determine if their wastes are hazardous. Ignorance of the regulations is no defense!
Characteristics of waste
By definitions developed by the U.S. Environmental Protection Agency (EPA), a waste material is hazardous if it is a characteristic or listed waste. Listed wastes are automatically considered hazardous if they appear on any of four lists contained in the Federal Resource Conservation and Recovery Act (RCRA) regulations. Characteristic wastes are those that have one of the following hazard characteristics: ignitable, corrosive, reactive or toxic. OK, so what do those mean? Well, here's how the EPA describes each of these hazardous waste characteristics:
Ignitable: A material that exhibits a flash point of less than 140°F. In other words, it can easily catch fire. Common examples include parts cleaning solvents, gasoline and paint thinners.
Corrosive: A material with a pH of less than or equal to 2.0 (acidic) or greater than or equal to 12.5 (caustic). These materials will burn eyes and skin on contact or corrode standard steel containers. Common examples include battery acid, rust removers, aluminum brighteners and cleaners, many floor cleaners used on shop floors, and caustic paint strippers. Reactive: Those wastes that are unstable, explosive or produce toxic fumes, gases and vapors are reactive. While this type of waste is not usually present in vehicle maintenance facilities, examples include cyanides, peroxides, strong acids and hypochlorites.
Toxic: Wastes that can be harmful or fatal when ingested, inhaled or absorbed through the skin are called toxic. These are determined by conducting a Toxicity Characteristic Leaching Procedure (TCLP) test. If the results indicate concentrations above regulatory levels of certain listed chemicals, then those materials may be considered a hazardous waste. Examples of potentially toxic wastes found in the shop include:
water and sludge from the clean-out of shop floor drains, pipes and oil/water separators
water that has been in contact with gasoline, diesel fuel, used motor oil or other hydrocarbon products
water and sludge that have accumulated in the bottom of fuel storage tanks, used oil tanks or other vessels
debris contaminated with used oil such as used oil filters, shop rags and absorbents
used gasoline filters (diesel fuel filters are typically considered non-hazardous)
Robert Yanchis is director of environmental affairs for Laidlaw Transit Inc. in Burlington, Ontario.