Hazardous Waste Reporting: Preparation Essentials
If your facilities generate hazardous waste, the period between January 1 and March 1 can be a very stressful time. Numerous state governments, and biennially the Federal government, all want summary reports of each facilities’ hazardous waste activities: How much did you generate? What kinds did you generate? Where did it all go? What happened to it once it got there?
While many states are beginning to unify in their approach to reporting thanks to the US EPA’s Central Data Exchange website (commonly called RCRA Info), there are many states who have had long standing reporting processes or state-specific reporting tools that prevent them from easily switching. And because these were developed independent of other states, they all tend to require different information. If you are going into the reporting season unprepared, you might not have all the information you need. APTIM recommends you start as early in the prior year as possible to assess what you will need and how you can prepare for it. Our team has assisted many companies around the country meet their reporting obligations and can help you develop a strategy for success. Here are some areas to consider.
1. KNOW YOUR STATES’ REPORTING TRIGGER(S)
For some states, such as Arizona and Alabama, a report is required if the facility has an active EPA ID Number. Indiana, on the other hand, only requires reporting if the facility actually generated at the Small Quantity Generator (SQG) level or above. Similarly, New York only requires Large Quantity Generators (LQGs) to report. Texas has two reports with the full report (Annual Waste Summary) required if the facility generates above 2,640 pounds for the year (acutely hazardous waste notwithstanding). Knowing these types of requirements may allow you to emphasize strategies throughout the year to minimize, if not eliminate, the reporting requirements. Questions to consider:
- Can I utilize the Hazardous Waste Generator Improvement Rule (HWGIR) episodic generation option to maintain a lower generator status?
- Do I have specific waste streams that consistently represent a larger portion of my totals on which I can focus my waste reduction/recycling?
- For example, the Universal Waste – Aerosols Rule may allow for significant decreases.
2. KNOW WHAT INFORMATION YOUR STATES REQUIRE
While most states generally ask for the same information regarding the wastes and their disposition, some use the opportunity of reporting to update their records on extraneous information at the same time. Other states may want data on additional waste streams as well. Knowing what information you will need and where (and when) you can acquire it will help you avoid last minute scrambling. Here are some examples:
- Idaho wants universal waste (all types combined) on their reports. Additionally, they use the collected reporting data to generate an internal report that itself has a March 1 deadline, so they require facilities to report by January 31.
- Minnesota’s metropolitan counties not only have varying deadlines from each other, but also can:
- Require additional waste stream data such as waste batteries and used oil,
- Require final disposal methods, and
- Require information from your Workers Compensation Policy.
- Oregon and Tennessee request facility employee counts. Tennessee also wants the status of your waste reduction.
- Numerous states, like Kentucky and Montana, require the names and addresses of the legal owners of the property.
3. KNOW THE ONLINE SYSTEMS AND THEIR REQUIREMENTS
There has been a steady trend for states to utilize on-line systems or electronic filing for reporting in the past few years. However, some states maintain their paper reporting, such as Tennessee and Montana. And further, some have a combination of on-line submittal and signed paper reports, such as Idaho.
Electronic submittals can make reporting simpler in many ways, however, it can be more time consuming and technology and the nuances of the reporting systems themselves can create unintentional obstacles for the unprepared. Here are some examples of things to consider:
- Do you already have one or more accounts in the applicable systems?
- Most states’ systems require a designated person to have an account who is authorized by the company to submit the reports. Changes in personnel or unexpected absences may prevent the completion of these reports.
- Some states, such as Washington, have an additional approval process to allow for electronic signatures.
- Are all the required facilities in the system? Is the information accurate?
- Texas’ process for adding a newly eligible facility requires a paper application, during which a state identification number is assigned, followed by a second paper request to add the facility to the account.
- Arizona allows for updates to be made on-line directly but limits some updates to once a calendar month essentially locking the record.
- Virtually all on-line systems have a submittal/approval process which can delay reporting if changes are required before reports can be submitted.
Looking for opportunities to minimize reporting throughout the year coupled with knowing what information you need and can acquire ahead of time can alleviate much of the stress that comes with preparing and submitting reports each year. APTIM has extensive experience in preparing and submitting hazardous waste reports across the country. We work regularly with agency regulators and are closely monitoring the changing regulatory landscape for our customers, making us an ideal partner on your hazardous waste reporting needs.
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