Did you know that hazardous waste generators are responsible for the hazardous waste they generate from cradle-to-grave? In other words, once you generate the waste, you have the responsibility of ensuring that it is properly managed even after it leaves your facility. There are actions your business can take to reduce the chances your waste is mismanaged.
First, pick a Treatment, Storage and/or Disposal Facility (TSDF) that is in compliance with Ohio EPA regulations. Qualifications should include:
- The facility has an Ohio EPA hazardous waste permit. Any facility that accepts hazardous waste for treatment, storage or disposal must have an Ohio EPA permit. The permit authorizes the types of waste a TSDF can accept and the treatment, storage and disposal activities that can be conducted. The permit outlines the operating conditions and recordkeeping procedures the TSDF must follow to ensure that wastes will be handled by Ohio EPA’s rules.
- The facility is authorized to accept the type of hazardous waste you generate. Find out if the TSDF is allowed to take your type of waste. You can contact the Division of Material and Hazardous Waste Management (DMWM) hazardous waste inspector for the appropriate county for this information.
- The facility is in compliance with environmental regulations. Ohio EPA inspects TSDFs. You can check to see if Ohio EPA inspectors have issued Notice of Violation letters to a TSDF by using Ohio EPA’s eDocs records search. You can also access compliance-related information for facilities through several national tracking systems maintained by U.S. EPA such as Envirofacts or Enforcement and Compliance History Online (ECHO).
If you find non-compliance issues, contact an Ohio EPA inspector in the district office and ask:
- Have past violations been corrected by the TSDF?
- Are there current enforcement actions against the facility?
- Have they been penalized for violations? and
- Does the facility have financial assurance in accordance with the regulations to ensure that it can properly close or clean up its hazardous waste units?
A history of violations may signal poor waste management practices (for example, many spills, emergency incidents, unauthorized treatment/storage/disposal activities). For facilities that are not located in Ohio, the environmental agency in the state where the facility is located should have compliance and permitting information available. There is no contact list for all other state environmental agencies, however, contact information is available on U.S. EPA’s Regional Office website.
It is also important you understand how your hazardous waste is going to be handled once it gets to the TDSF. For instance, your waste may be received by one facility for treatment and then shipped off to another site for disposal. In this situation, you should look at the compliance and operating status of both sites.
You may find Ohio EPA’s fact sheet Selecting a Treatment Storage and Disposal Facility to Manage Your Hazardous Waste helpful with this process. Ohio EPA maintains a list of Ohio facilities permitted to treat, store and/or dispose of hazardous wastes.
Additional help is available through Ohio EPA’s Office of Compliance Assistance and Pollution Prevention (OCAPP). They can help you determine if the facility has other Ohio EPA permits, regulatory obligations, its compliance status, answer questions you may have or help you understand Ohio EPA’s rules. OCAPP is a non-regulatory office within the Ohio EPA that helps businesses comply with environmental regulations and permitting requirements. For more information, contact OCAPP at (800) 329-7518, or visit our website.