Industrial Hazardous Waste Recycling
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How do I recycle my waste if it is not hazardous?
Recycling hazardous waste conserves precious resources and makes sense for the bottom line. EPA grants regulatory relief for many types of recycling which reduces regulatory and compliance costs for your company. Furthermore, safe recycling of hazardous waste helps to meet corporate environmental stewardship policies and goals.
To recycle your industrial hazardous waste, consider the following steps:
First, determine how your waste is regulated.
For information on how materials that are recycled are regulated under RCRA Subtitle C, see the Hazardous Waste Recycling Regulations web page. To determine if your material meets the definition of solid waste under RCRA Subtitle C, see the Definition of Solid Waste area. For general information on Hazardous Waste Identification, see the Hazardous Waste Identification area.
Consider using cost-accounting tools.
Many calculators and other cost-accounting tools are available to companies to help them track and improve resource use. Generally, these tools estimate the environmental benefits of pollution prevention and recycling activities and decisions, such as greenhouse gas emissions reductions and energy savings. An example list of tools is available at the Pollution Prevention Regional Information Center's Website.
Choose a responsible recycler.
A responsible recycler is one that is fit to handle hazardous secondary materials and conducts legitimate recycling (see the following discussion on legitimate recycling). Hazardous waste generators can use numerous tools to evaluate a potential recycler. For example, generators may audit recyclers to ensure their fitness to handle hazardous secondary materials. Some common questions that generators may ask when evaluating recyclers include:
- What is the facility's site history and ownership history? Have there been any previous activity and/or contamination at the site?
- Does the facility have a history of environmental compliance? Have they been subject to any enforcement actions?
- Is the facility in compliance with all required permits?
- What is the general housekeeping at the facility?
- Does the facility employ responsible practices such as waste screening and acceptance procedures, residuals management, drop-off and tracking protocol and certificates of recycling?
- Is the facility financially sound? Does it have adequate pollution liability insurance and provisions for necessary closure and cleanup costs if necessary?
For more information about responsible recycling practices, see:
- An Assessment of Good Current Practices for Recycling of Hazardous Secondary Materials
- Choosing a Responsible Recycler: A Guide for Generators of Secondary Hazardous Materials (PDF) (2 pp, 312K, about PDF) - For best results when printing, use legal size paper and print double sided with both sides flipped up. Fold paper into fourths to view as a brochure.
- Confirm your waste will be legitimately recycled.
Some facilities may claim that they are recycling a material in order to avoid being subject to RCRA regulation, when in fact the activity is not legitimate recycling. This practice is called "sham recycling." The determination of whether an activity represents legitimate versus sham recycling depends on several factors, including whether the secondary material is effective for the claimed use, if the secondary material is used in excess of the amount necessary, and whether the facility has maintained records of the recycling transactions. Making this determination can be a difficult task and involves assessing the intent of the owner or operator by evaluating circumstantial evidence. Key considerations regarding this determination include:
- Is the secondary material similar to an analogous raw material or product?
- What degree of processing is required to produce a finished product?
- What is the value of the secondary material?
- Is there a guaranteed market for the end product?
- Is the secondary material handled in a manner consistent with the raw material/product it replaces?
For additional information on these and related questions, see the April 26, 1986 memo on F006 recycling (aka "Lowrance Memo") (PDF) (6 pp, 43K, About PDF)
Examples of "sham" recycling:
- Ineffective or only marginally effective for the claimed use - e.g., using certain heavy metal sludges in concrete when such sludges do not contribute any significant element to the concrete's properties.
- Used in excess of the amount necessary - e.g., using materials containing chlorine as an ingredient in a process requiring chlorine, but in excess of the required chlorine levels.
- Handled in a manner inconsistent with its use as a raw material or commercial product substitute - e.g., storing materials in a leaking surface impoundment as compared to a tank in good condition that is intended for storing raw materials.
Consider participating in an EPA Program.
WasteWise is a free, voluntary EPA program through which organizations eliminate costly municipal solid waste and select industrial wastes, benefiting their bottom line and the environment. WasteWise is a flexible program that allows partners to design their own waste reduction programs tailored to their needs.
Keep track of your recycling success!
There are two key reasons why companies measure their environmental performance: costs savings and public relations. Many companies have found that monitoring and reporting environmental metrics is both cost effective and beneficial to their public image. By modifying business practices to be less wasteful, businesses can save money through reduced material and energy consumption or avoided disposal costs. Tracking performance also provides a way for companies to show their investors and other stakeholders that they are not in violation of environmental regulations, and, thus, are not incurring monetary fines. Through public relations, companies can promote environmental successes to preserve an environmentally friendly reputation or to establish themselves as environmental leaders in their sectors.