Steps to Consider When Recycling Industrial Hazardous Waste
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.
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First, determine how your waste is regulated. EPA developed a regulatory definition and process that identifies specific substances known to be hazardous and provides objective criteria for including other materials in the regulated hazardous waste universe.
- Find information on how materials that are recycled are regulated under Subtitle C of the Resource Conservation and Recovery Act (RCRA) on the hazardous waste recycling regulations Web page.
- To determine if your material meets the definition of solid waste under RCRA Subtitle C, read more about the criteria here.
- Learn more about hazardous waste listings and characteristics.
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.
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:
- Choosing a Responsible Recycler: A Guide for Generators of Secondary Hazardous Materials: A resource for generators of secondary hazardous materials that provides information about how to choose a responsible recycler.
Confirm your waste will be legitimately recycled. EPA has established guidelines for what constitutes legitimate recycling and has described activities it considers to be illegitimate or sham recycling. Considerations in making this determination include whether the secondary material is effective for the claimed use, if the secondary material is used in excess of the amount necessary, and whether or not the facility has maintained records of the recycling transactions. EPA’s definition of legitimate recycling is found in Title 40 of the Code of Federal Regulations (CFR) section 260.43.
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.