A great deal of discussion on the safe handling and management of hazardous waste focuses on the two extremes of its life cycle: generation, or how and where the waste is produced and who is responsible for dealing with it; and disposal, which includes treatment processes required to make the waste safe for handling during disposal, storage facilities where it is contained prior to disposal, and final disposal methods such as recycling, landfilling, or incineration. But in between these two ends of the hazardous waste spectrum lies a vital, yet often overlooked link: transportation, or how hazardous waste gets from the place where it’s generated to the place where it’s disposed of.
To help shed more light on this important step in hazardous waste management, the Environmental Protection Agency provides a helpful summary of what is involved in the transportation of hazardous waste. For an overview of the ins and outs of the process, read on.
What is hazardous waste transportation?
Hazardous waste transportation refers to the delivery of hazardous waste from its point of generation to wherever its final destination may be, such as a recycling or storage facility or a treatment or disposal site. Methods of moving the waste from one site to another include by truck and highway, rail, air, and water.
Who is allowed to transport hazardous waste and what are the associated requirements?
According to the Resource Conservation and Recovery Act of 1976 (RCRA), the public law that outlines the framework for proper management and handling of both hazardous and non-hazardous solid waste, a hazardous waste transporter is defined as a person or entity involved in transporting hazardous waste off-site within the US.
It’s important to note here that the law makes a distinction between off-site and on-site transportation. Off-site transportation generally means moving or shipping the waste from the property or facility where it was generated to another, separate site. On-site transportation, however, refers to the movement of the waste within a facility’s property or boundary.
So if a large hospital, for example, was collecting biomedical waste from different buildings that were all located next door to each other on the same property, that would be considered on-site transportation, but when the hospital engages a company to move that biomedical waste from hospital property to a facility in the next county that will treat and dispose of the biomedical waste, that constitutes off-site transportation.
It’s important to be clear about this distinction because only off-site transportation is subject to transporter regulations outlined by the EPA. This is due to the fact that off-site transportation involves hazardous waste being moved along public roads, rails, and waterways, and thus poses a risk of harm to the general public. The regulations outlined under the RCRA for hazardous waste transporters include:
Obtaining an EPA ID number—Each company involved in the transportation of hazardous waste must obtain an ID number from the EPA; this helps the agency keep better track of what waste cargoes are being transported by whom. These ID numbers are allocated to the company as a whole rather than to each individual transport vehicle.
Complying with the EPA’s hazardous waste manifest system—The hazardous waste manifest system developed by the EPA is intended to keep careful track of the movement of hazardous waste along all the stages of its physical journey. Compliance with this system means that transporters must only accept hazardous waste from a generator if a properly prepared manifest is presented upon receipt of the waste, and that a copy of the manifest must always accompany the waste shipment. In addition, after the waste is delivered to its destination, a copy of the manifest must be kept by the transporter for three years. Some exemptions or alterations to this regulation apply to rail or water transporters, or to transporters of waste generated by Small Quantity Generators (SQGs).
Handling hazardous waste discharges—There is always the possibility that hazardous waste may be spilled or discharged during its transportation. To protect human and environmental health, transporters must be prepared to handle such an event immediately through such steps as notifying local authorities or establishing dikes in the discharge area.
Obeying further regulations from the US Department of Transportation—In addition to the EPA regulations, the DOT also outlines a number of regulations connected to the safe transport of hazardous waste. Transporters must follow DOT requirements on such matters as what constitutes an acceptable hazardous waste transportation container, and how these containers should be labeled.
What are transfer facilities?
During the normal course of transportation, hazardous waste may need to be held temporarily along the way. These holding stations are known as “transfer facilities,” defined by the EPA as any transportation-related facility where hazardous waste shipments may be temporarily held, such as parking areas, loading docks, or storage areas. Hazardous waste may be held in its transportation containers at a transfer facility for up to 10 days without a permit.