The Resource Conservation and Recovery Act (RCRA) was an amendment to the Solid Waste Disposal Act and is now the main federal law governing the disposal of solid and hazardous waste in the interest of human health, conserving natural resources, reducing waste, and protecting the environment.
The RCRA controls hazardous waste disposal “cradle to grave”. That means that as a waste generator you are responsible for every part of the disposal process including tracking.
The RCRA regulates the generation, management, and disposal of solid waste and regulates and tracks the life of hazardous waste. Most of the specific laws and enforcement are handled at the state level. The three main programs of the RCRA that may apply to your facility are:
RCRA Subtitle C, Hazardous Waste: The hazardous waste program establishes a system for controlling hazardous waste from the time it is generated until its ultimate disposal — in effect, from “cradle to grave.”
RCRA Subtitle D Non-Hazardous Waste:The solid waste program encourages states to develop comprehensive plans to manage non-hazardous industrial solid waste and municipal solid waste, sets criteria for municipal solid waste landfills and other solid waste disposal facilities, and prohibits the open dumping of solid waste.
RCRA Subtitle I, Underground storage tank (UST) program: UST regulates underground storage tanks containing hazardous substances and petroleum products.
There are four characteristics that can make a waste material a hazardous waste:
Ignitability: a substance that is prone to combustion. Examples include gasoline, solvents.
Corrosivity: an extremely acidic or basic substance. Examples include cleaning solutions, battery acid, rust removers.
Reactivity: a substance that when it reacts with water, acidic or basic (alkaline) materials is capable of causing an explosion or generating toxic gas.
Toxicity: A waste is toxic if it is potentially damaging to human health but is defined by whether it could leach one of 40 chemical in amounts defined by the EPA. (The procedure for this determination is the Toxicity Characteristic Leaching Procedure.) Examples include oil filters, shop rags, floor drain sump sludge.
Any waste created at your facility can potentially negatively impact the environment. Common sources of golf course waste include everything from shop equipment to fertilizers to golfers' trash.
Reduction of waste, recycling, and composting are the best ways to handle non-hazardous waste at your facility. State and local governments often regulate how compost piles are managed to protect from runoff or airborn waste, but they're still generally a good practice.
RCRA encourages recycling of anything that can be recycled. Some common but potentially hazardous wastes such as batteries, pesticides, fluorescent light bulbs can be recycled and are considered "universal waste" in order to aid the ability to readily recycle them. Individual states also handle some additional items as universal wastes such as electronic wastes, or they might have additional limitations on what can be disposed of as universal waste. Reference the charts about your state. Used oil is also handled separately from hazardous waste, but usually has its own laws governing storage and disposal. There are businesses that will recycle used oil and used oil filters.
Waste pesticides or excess pesticides must be disposed of as either hazardous waste or universal waste.
Disposal as a universal waste is only possible if they are pesticides that are either:
Recalled pesticides that are stocks of a suspended and canceled pesticide that are a part of a voluntary or mandatory recall under FIFRA Section 19(b), or
Recalled pesticide that are stocks of suspended or canceled pesticides, or a pesticide that is not in compliance with FIFRA, that are part of a voluntary recall by the registrant.
Stocks of other unused pesticide products that are collected and managed as a part of a waste pesticide collection.
As with most federal regulations, your state may have stricter laws that narrow the definition of universal waste.
Electronic waste is generally not regulated nationally by the RCRA. However, some states do have laws preventing the disposal of e-waste in landfills. Those state – in addition to many other states – host electronics recycling programs which often consist of designated drop offs or specified collection days.
Since through the RCRA a business has liability for hazardous waste "cradle to grave," it's important to work with a reputable waste management company. Their improper disposal of hazardous materials could cause serious issues for you and your facility. Checking to make sure they have the proper EPA permits is a good first step.
Hazardous wastes are all listed on one of four lists:
F-list identifies common industrial wastes from non-specific sources. View the list in Title 40 section 261.31 of the Code of Federal regulations.
K-list identifies hazardous wastes from 13 specific industries (that generally would not apply on golf course. See Title 40 section 261.32 of the Code of Federal regulations.
P-list identifies acute hazardous waste from commercial chemical products. The P and U lists can be found in Title 40 section 261.33 of the Code of Federal regulations.
U-list identifies hazardous wastes from discarded commercial chemical products.
For both the P and U lists the chemical must be unused and in the form of a commercial chemical product.
The EPA has three categories of generators based on the amount of hazardous waste your facility creates.
The cradle-to-grave liability of the RCRA is mainly managed through the hazardous waste manifest system. The system mainly consists of the Uniform Hazardous Waste Manifest, a form required by EPA and the Department of Transportation for all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage or disposal. Currently, the manifest is a paper document containing multiple copies of a single form. When completed, the form contains information on the type and quantity of the waste being transported, instructions for handling the waste, and signature lines for all parties involved in the disposal process. Each party that handles the waste signs the manifest and retains a copy for themselves. This ensures critical accountability in the transportation and disposal processes. Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility.