Hazardous Waste Requirements
Hazardous waste is a special class of solid waste that must be managed properly to protect human health and the environment. Federal and state laws regulate how businesses, institutions, governments and other non-households must manage this waste.
Common Hazardous Waste Violations:
- Not marking containers/tanks as "Hazardous Waste"
- Accumulating too much hazardous waste at a satellite station
- Not marking start date of accumulation on the container/tank at the accumulation point.
- Accumulating hazardous waste on-site for more than 90 days.
- Open containers
See WI DNR Management of Hazardous Waste in Wisconsin page for more details.
Waste Determination and Record Keeping
Accurate waste determinations are the first step in ensuring safe management of hazardous waste.
Waste Determination Process:
There are five principal steps in the waste determination process:
- Identify the waste streams
- Determine whether the waste stream is a solid waste
- Determine if the solid waste is excluded
- Determine whether the solid waste is a hazardous waste under NR 662.011
- Document the information in steps 1-4: Compile the information used to make the waste determination, including a statement on whether the waste is a hazardous waste. If it is hazardous waste, list the applicable waste codes (D001, F003, U183, etc.) and what the generation rate of this waste is per month.
See WI DNR WA 1152 Waste Determination and Recordkeeping for more details.
Waste Accumulation Areas - Proper Container and Labeling
There are many factors to take into account when having a waste accumulation area:
Mark/Label Containers:
Hazardous Waste: Mark or label the container as "Hazardous Waste" when waste is put into it.
Start Date: Label hazardous waste containers with a “start date" which shows when the first drop of waste was added.
Keep All Containers Closed:
With the exception of when waste is being added to a container, keep the container closed.
Keep Waste in Sturdy, Appropriate Containers:
The containers that use for accumulate hazardous waste in must be sturdy. The containers must also be made of an appropriate material so as not to react with the waste that placing into the container.
Keep Containers Easily Accessible
It is important to maintain enough space between and around containers to easily access. Keeping an aisle open makes inspections and removal easier.
Inspect Containers
Once a week inspect containers for signs of stress, or damage that would lead to leaking or a release of hazardous waste.
Keep Incompatible Wastes Separate and on Impermeable Surfaces
Do not keep containers of incompatible wastes near each other. Ensure that they are labeled properly to avoid any accidental mixing. Do not keep containers of liquid hazardous waste on a surface that has a floor drain.
Prepare Wastes for Shipment
They often supply proper containers, labels and placards to meet DOT requirements. However, it is your responsibility to ensure that any hazardous waste transported from your facility is managed per DOT specifications.
Leaks and Spills
Any leaking containers must be transferred to a non-leaking container immediately. If a spill or a leak occurs, the materials must be cleaned up and properly managed. See Hazardous Substance Spill section for more details about spills.
For more information see DNR Closed Container Guidance for Hazardous Waste Generators.
Waste Accumulation Areas - Proper Container and Labeling
Once a week containers must be inspected for signs of stress, or damage that would lead to leaking or a release of hazardous waste.
Use UWSP Hazardous Waste Container Weekly Inspection Checklist for your weekly inspection and check for;
- Containers marked/labeled properly
- Start date
- Closed tops
- Stored 90 days or less
- No leaks/staining
- No dents/corrosion
- Incompatible wastes and materials stored separately
- Aisle space maintained
- Secondary containment liquid free
Training Requirements
Training requirements for the management of hazardous waste, universal waste, and used oil are outlined in the NR 600 series of the Wisconsin Administrative Code. Training employees to safely handle hazardous waste is the most effective and economic way to ensure proper waste management while protecting human and environmental health. The training requirements cover safety and emergency response and must be specific to the employee's job function.
Training programs must teach hazardous waste management procedures and how to:
- Document and maintain required records
- Characterize hazardous wastes
- Identify appropriate waste containers for storing and shipping
- Label and mark containers during storage and for shipment
- Protect employees from hazardous waste
- Inspect waste-storage areas
- Utilize manifests
- Respond to hazardous waste emergencies and spills
All facility personnel, including office staff and on-site contractors, must be trained on emergency procedures which includes training on UWSP contingency plans and evacuation procedures.
Annual refresher training is required. Send the copy of any hazardous waste training certificates to EHS office (002D Old Main) or scan and email to risk.management.office@uwsp.edu .
See DNR Training Requirements and Records: Hazardous Waste Generators, Collection Sites and TSD Facilities for more details.