Composites manufacturing operations routinely generate and dispose of waste materials. Because this is a routine operation, manufacturers can find the actual handling of waste materials has drifted from the company’s standard procedures, placing the plant at risk of safety incidents and compliance problems.
Federal regulations define all “garbage, refuse and sludge” as solid waste. Also, any “solid, liquid, semi-solid or contained gaseous material,” which is “discarded, served its intended purpose or is a manufacturing byproduct” is a solid waste. Composite manufacturers typically find that their scrap resins, overspray, discarded molding compound and other similar materials are solid wastes.
To determine if a solid waste also is a hazardous waste, under federal regulations the waste generator asks the following: Does the solid waste exhibit the characteristics of ignitability, corrosivity, reactivity or toxicity? Is it a listed waste? Is it a mixture that contains a listed waste?
A solid waste that is a liquid exhibits the characteristic of ignitability if it has a flash point below 60 C. Scrap resins are captured under this definition and are therefore considered hazardous waste under federal regulations. Scrap molding composites are typically not considered hazardous waste because under federal regulations, they are not considered liquids. Few industry wastes are listed wastes, contain listed wastes or exhibit characteristics other than ignitability.
As soon as a generator forms an intent to discard a material, it becomes a solid waste subject to federal regulation. If the waste is or contains a listed waste, or if it exhibits the characteristics of ignitability, corrosivity, reactivity or toxicity, then it also becomes a hazardous waste, and the generator is subject to the applicable requirements for hazardous waste generators.
Federal regulations contain several requirements that apply to generators of hazardous waste, including requirements for obtaining Environmental Protection Agency ID numbers, manifests, packaging and labeling; limits on accumulation time; and record keeping and reporting. However, a conditionally exempt small quantity generator – defined as generating no more than 100 kilograms of hazardous waste in a month – is generally exempt from the requirements for hazardous waste generators.
Further, generators who accumulate waste on site for 90 days or less prior to treatment or transport off-site are not required to have permits as treatment, storage and disposal facilities. Ninety-day generators, however, are required to store the waste in containers, tanks, containment buildings or on drip pads that meet certain standards. They also must comply with certain requirements for labeling tanks and containers, for testing and maintenance of equipment, and for contingency planning and emergency procedures.