Hazardous Waste

Generators who have shipped hazardous waste off-site are required to submit an HWR (OAC Rule 3745-52-41). If they generated less than 1000 kg (2200 lbs) of non-acutely hazardous waste in each month of the calendar year, then the generator is exempt from reporting (OAC Rule 3745-52-44). In other words, if the site was a Large Quantity Generator (LQG) in any one month during the calendar year, they must file an HWR and list all the wastes they generated and/or shipped during the entire year. A LQG is defined as a site that generates 1000 kg (2200 lbs) or more of non-acutely hazardous waste or 1 kg (2.2 lb) or more of acute hazardous waste in one calendar month. There is no exemption from reporting for one-time or short-term LQG activities.

Facilities that have a permit to treat, store, or dispose (TSD) of hazardous waste must also file an HWR (OAC Rules 3745-54-75 or 3745-65-75). Commercial or limited commercial facilities that receive hazardous waste from off-site must identify their customers, what was received, and how it was managed. Facilities that conduct on-site management of their own wastes in permitted units report the quantity and the method(s) used.

In early June of 2012 Senate Bill 294 was signed by the Governor and became effective on September 5 of the same year. One component of that bill allowed the Director of Ohio EPA to report certain hazardous waste management data to the Governor biennially now instead of annually. Ohio EPA changed certain annual reporting requirements to biennial reporting requirements to correspond with the federal program.

Under that rule change the “Annual Hazardous Waste Report” simply became the “Hazardous Waste Report.” The first of those biennially due Hazardous Waste Reports was due March 1, 2014 and encompassed all of a facility’s hazardous waste activities for the 2013 reporting year.

For 2015, this report was due Tuesday, March 1 and included information on wastes generated, stored, treated or shipped during the 2015 calendar year.

If you normally submit other reports/data with your annual report that are not part of that report (for example, the ground water monitoring annual report required by OAC 3745-65-94) those other reports/data will maintain an annual reporting requirement.

eDRUMS is an electronic reporting service available to users through the agency’s eBusiness Center (“eBiz”). You may already be familiar with eBiz from filing reports with the air and water programs. To obtain general information about eBiz, go to https://ebiz.epa.ohio.gov and click on the words “Click here for online help”. eBiz Fact Sheets are available there as well as a link to the Answer Place. There is no charge for establishing an eBiz account. 

For an overview on how to get started in eBiz, go to the Training Resources tab of this web page to listen to recorded webinars or view a PDF of the slides. Webinar training and slides are also available for applying for the eDRUMS service and delegating access to other users as well as how to prepare a report using eDRUMS.

To get started with eBiz, the facility's Responsible Official (RO) or their duly authorized representative (i.e. Delegated Responsible Official, or DRO) must apply to use eDRUMS. The RO or DRO are the individuals who can sign a report, either electronically or on paper. The definition of who can be an RO or DRO for the RCRA program is in Ohio Administrative Code rule 3745-50-42. Once the RO or DRO has a PIN, they will submit an eDRUMS service request to associate them with a specific facility. Once the service request is approved the RO or DRO can start working on a report or may delegate report preparation duties for a facility to another eBiz user. 

Only the RO or DRO needs a PIN; report preparers simply need an eBiz account and the delegation of the preparer role. Consultants can be designated as preparers. The eBiz PIN uniquely identifies the individual it is assigned to and can be used for all regulatory programs that use eBiz for electronic submissions. If the RO or DRO already has a PIN for water or air data submissions, there is no need to obtain another. The PIN cannot be shared with other people and must be kept confidential.

If the RO wants to delegate annual report signatory authority to someone else pursuant to OAC rule 3745-50-42, this can be done in two ways:

• On paper: A letter or form authorizing a specific individual or a specific position of responsibility to sign the report can be sent to Ohio EPA, DERR, PO Box 1049, Columbus, OH, 43216-1049. This option can be used if the Responsible Official doesn't want to establish their own account in eBiz or obtain a PIN. The process is as follows:

  • The duly authorized representative (DRO) would obtain an eBiz account and PIN and then apply for the eDRUMS service by clicking the "Delegated Submitter" box in the HWAR Service Request screen.

  • After clicking Submit, the user must print the partially populated Delegation of Authority document that appears in PDF format on the acknowledgment screen.

  • The Responsible Official authorizing the user to electronically sign reports must complete the remainder of the form and send it to DERR via US mail.

  • Once the mailed form is received by DERR, the DRO's service request will be approved.

• Electronically: If the RO has a PIN, they can delegate the certify/submit role to the duly authorized representative (DRO) after the RO's eDRUMS service request has been approved. The DRO must have a PIN before they can certify/submit a report. Sending an authorization letter/form to DERR is not necessary for electronic delegations.
  

  From reporting cycle to reporting cycle, there may be a need to change who prepares the report or who certifies it as the RO. Ohio EPA has posted a file which details how to manage a Change in Roles within the eBusiness Center.

USPS Mailing Address
Ohio EPA – DERR
PO Box 1049
Columbus, OH 43216-1049

Courier Delivery Address:
Ohio EPA – DERR
Lazarus Government Center
50 W Town St, Suite 700
Columbus, OH 43215