Public Health and Environment
Business Hazardous Waste Generator Compliance Requirements
If your business generates hazardous waste, you are required to follow waste management practices to protect you, your workers, and the environment. Washington County and Minnesota Pollution Control Agency (MPCA) staff have identified
10 Steps to Compliance
for hazardous waste management. The
10 Steps to Compliance
are summarized below. The following general information is not meant to be conclusive.
For the complete set of regulations see
Washington County Hazardous Waste Ordinance #166
and
Minnesota Rules, Chapter 7045.
For more information:
Washington County Hazardous Waste Business Assisstance at 651-430-6655.
Minnesota Pollution Control Agency Small Business Assistance Program
(for companies with fewer than 100 employees) at
651-282-6143 or 800-657-3938.
Minnesota Pollution Control Agency
hazardous waste general assistance at
651-297-2274.
Minnesota Pollution Control Agency
hazardous waste publications for businesses.
Minnesota Rules - Hazardous Waste, Chapter 7045.
10 Steps to Compliance
Step 1 – Identify and Evaluate Your Wastes
Step 2 – Obtain Hazardous Waste Identification Number
Step 3 – Apply and Pay for Annual Hazardous Waste License
Step 4 – Waste Container Requirements
Step 5 – Waste Storage Requirements
Step 6 – Transport and Dispose of Waste Correctly
Step 7 – Manifest Shipments of Hazardous Waste
Step 8 – Plan for Emergencies
Step 9 – Train Personnel
Step 10 – Keep Records
For additional information on each of the Ten Steps to Compliance, see the
MPCA business factsheets.
Step 1 – Identify and Evaluate Your Wastes
(MN Rules 7045.0127 – 7045.0137)
Identify all wastes discarded by your business. Identify characteristics and elements of the wastes. Obtain information about your wastes from Material Safety Data Sheets (MSDS's) from materials used, knowledge of processes, and analyzed laboratory tests if necessary.
Include wastes from:
- Business refuse
- Sewered wastes
- Recycled wastes
- Off specification wastes
- Unusable products
Wastes that are listed, carry a characteristic, or contain a concentration of polychlorinated biphenyls (PCBs) at or more than 50 parts per million are hazardous.
Determine your generator size by quantity of hazardous waste generated:
- Very Small Quantity Generator – VSQG
- 220 pounds or approximately ½ drum liquid or less per month
Small Quantity Generator – SQG
- More than 220 pounds but less than 2,200 or ½ to 4 drums liquid per month
Large Quantity Generator – LQG
- 2,200 pounds or 4 drums liquid or more per month
Step 2 – Obtain Hazardous Waste Identification Number
(MN Rules 7045.221)
Within 75 days of first generating hazardous waste and prior to disposal of any hazardous waste, a generator must apply for an
MPCA Hazardous Waste Identification Number.
The identification number is specific to one location.
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Step 3 – Apply and Pay for Annual Hazardous Waste License
(MN Rules 7045.0225)
Complete a
Washington County Hazardous Waste Generator License Application.
Hazardous waste generator license fees vary with the amount of hazardous waste generated. A
Minnesota Tax Identification Number Information
sheet must be completed and returned with your license application.
Step 4 – Waste Container Requirements
(MN Rules 7045.0292)
Waste must be stored in containers clearly labeled with:
· the words "Hazardous Waste;"
· a clear description of the waste; and
· accumulation start date (the date waste is first put into the container).
Step 5 – Waste Storage Requirements
(MN Rules 7045.00626)
Containers used to store waste must be:
- of sturdy leakproof construction;
- closed and able to contain waste in container in the event of being dropped or overturned;
- compatible with waste so that ability to contain waste is not impaired.
Additional waste storage requirements include:
- provide aisle space for easy access and visibility;
- protect waste from inadvertent damage;
- store containers on impermeable surfaces and without floor drains;
- restrict access to only people responsible for the waste;
- outdoor storage must include a curbed surface;
- outdoor storage must include protection from the elements.
In addition to Minnesota hazardous waste rules, hazardous waste storage is often regulated by fire and building codes.
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Step 6 – Transport and Dispose of Waste Correctly
(MN Rules 7045.0292)
Generators may be required to transport and dispose of hazardous waste within time and quantity limits to meet the conditions of their license.
- Accumulation Limit: 2,200 pounds or 220 gallons
- Storage Time Limit (ship waste within): 180 days of the date of 2,200 pounds accumulated.
SQG
-
Accumulation Limit: 6,600 pounds or 660 gallons
-
Storage Time Limit (ship waste within): 180 days of accumulation start date.
LQG
- Accumulation Limit: No Limit
- Storage Time Limit (ship waste within): 90 days of the accumulation start date.
Generators are responsible for the hazardous waste through proper treatment and disposal. Choose a transporter, and waste management facility that maintain specific requirements and qualifications.
Step 7 – Manifest Shipments of Hazardous Waste
(MN Rules 7045.0265)
A manifest, a multi-copy shipping paper, must accompany shipped waste from the generator site to the disposal facility site. Your transporter may provide the manifest upon pick-up of the waste.
The manifest must be completed correctly, including proper signatures. Copies must be routed to correct sites and within specific time limits.
For more information see our
Manifest Distribution
page.
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Step 8 – Plan for Emergencies
(MN Rules 7045.0292, 7045.0566 - 7045.0574)
Maintain appropriate emergency response and spill equipment for your waste and facility, and in an accessible area. Communication or emergency alarm system and fire equipment are required of all generators.
Additional preparedness and prevention requirements for SQGs and LQGs include:
- emergency plans and procedures;
- notify local authorities of the hazardous waste properties and amounts stored on-site;
- designate an emergency coordinator;
- post emergency information by employee accessible telephone;
- provide and document adequate training for personnel handling hazardous waste.
Step 9 – Train Personnel
(MN Rules 7045.0292)
SQGs and LQGs are required to provide hazardous waste training specific to job duties and waste management.
Training subjects required may include:
- ignitable and reactive wastes;
- incompatible wastes;
- preparedness and prevention;
- contingency planning;
- restricted waste management.
VSQGs have no required training. However, Washington County and the MPCA strongly recommend that personnel handling hazardous waste become knowledgeable about the hazards associated with the waste and with appropriate safety procedures.
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Step 10 – Keep Records
(MN Rules 7045.0294, 7045 .0125, 7045 .0675)
Maintain the following records for at least three years:
- manifests and manifest exception reports;
- oil, special, and some reclaimed waste records;
- feedstock records;
- management of waste through reuse, recycling, or reclamation documentation;
- very small quantity generator collection receipts;
- license applications and renewals;
- container inspection reports;
- test results and waste analyses;
- Land Disposal Restrictions (SQG's and LQG's);
- training records on former personnel (SQG's and LQG's). Training records on current personnel must be kept until closure of the facility.
It is recommended to keep additional records such as MSDSs, related correspondence, and any business records demonstrating good environmental management. It is also recommended to keep all referenced documents for the life of the business.
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