RCRA 101 Part 8: Waste Profiles
Editor’s Note: Welcome to part 8 in our series about the Resource Conservation and Recovery Act (RCRA). During this series, we’ll guide you through proper hazardous waste handling so you stay compliant and safe.
Making solid and hazardous waste determinations is a critical step in managing waste streams properly. Not only does it help keep employees and the community safe, it is also important when the wastes are hauled offsite and when they reach their ultimate destination for treatment or disposal.
Both solid waste recycling and disposal facilities and hazardous waste Treatment, Storage and Disposal Facilities (TSDFs) need to make sure that they are able to accept the wastes that are being shipped to them, which is why many require waste generators to submit waste profiles.
Waste profiles describe a waste and provide the landfill, recycler or TSDF with the information that they need to handle the waste safely while it is in their possession. Because the facility receiving the waste is going to treat or dispose of it, an accurate profile is important to prevent improper treatment or disposal.
A thorough waste profile can sometimes resemble a Safety Data Sheet (SDS) because it contains a description of the waste including its state (solid, liquid or gas), color, smell and other features. Waste profiles must also contain waste codes and other information that is specific to the Environmental Protection Agency’s (EPA) Resource Conservation Recovery Act, such as listed hazardous waste codes (F, K, P or U codes) or characteristic waste codes (D codes).
There is no standardized look for a waste profile, although some TSDFs and solid waste disposal facilities have pre-prepared forms that they send to their customers to complete. Most disposal facilities will not accept wastes without a profile accompanying the manifest. In fact, some require the waste profile in advance so that they can determine if they will be able to accept the waste and what they will need to do to be prepared to receive it.
Waste generators also benefit from creating and maintaining waste profiles because all facilities that generate wastes are required to document how they made their waste determinations. Waste profiles are one way to demonstrate compliance with this requirement.
Up next in the RCRA 101 Series, we discuss cradle to grave liability.