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Hazardous Waste Minimization

Introduction

Waste minimization is a national policy specifically mandated by the U.S. Congress in a 1984 amendment to the national hazardous waste law, the Resources Conservation and Recovery Act (RCRA). Consistent with national and State policy, the University of Maryland Environmental, Safety and Health Management Policy states in principle that waste will be minimized through efficient and appropriate use of resources. The EPA has developed a decision hierarchy for waste management practices. This hierarchy includes the following elements in descending order in terms of desirability:

Pollution Prevention (i.e., source reduction)
Recycling
Treatment
Disposal

Waste minimization includes source reduction and environmentally sound recycling. Reducing the generation of hazardous wastes at the source, or recycling the wastes will benefit the University by reducing disposal costs and the environmental, health and safety liability associated with hazardous waste management. This fact sheet will provide University personnel with the elements of an effective waste minimization program.

Definitions

Source Reduction: Any practice which reduces the amount of any hazardous substance, pollutant or contaminant from entering any waste stream or otherwise be released to the environment prior to recycling, treatment or disposal.

Recycling: The use, reuse, or reclamation of waste.

Waste Minimization: Includes source reduction and environmentally sound recycling. It is preferable when possible to conduct recycling at on-site locations. Some recycling activities require a permit.

Applicable University Policy

• University of Maryland Environmental, Safety and Health Management Policy
• Hazardous and Regulated Procedures Manual.

Applicable Regulation

COMAR 26.13 - Disposal of Controlled Hazardous Substances

Summary of Requirements

The following provides an outline of the elements of an effective waste minimization program as defined by EPA guidance documents. The elements are general in nature and will need to be tailored to meet individual department needs.

• Organizational Support: Waste minimization is a process of continual improvement. All individuals should be encouraged to identify opportunities for waste minimization in their daily activities. Departments are encouraged to consider the adoption of explicit goals for reducing the volume and toxicity of their waste streams and to commit to the implementation of recommendations where feasible. The designation of a waste minimization coordinator at the department level may be considered as a means to facilitate effective implementation, monitoring and evaluation of the program.




• Characterization of Waste Generation, Cost Allocation and Waste Management Costs: One of the most effective and widely accepted methods for identifying opportunities for waste minimization is the "mass balance" approach. This approach utilizes purchasing and waste generation records to obtain rough approximation of chemical usage on the basis of an input-output model. Obviously, the more detailed the record (e.g., chemical by chemical balance on an individual process basis), the more useful this approach will be for identifying chemical consumption rates and waste generation data. This approach utilizes purchasing, inventory, usage, waste collection, waste packaging, waste shipment and billing data to develop a chemical life cycle model. This system promotes waste minimization by identifying chemical constituents and processes which represent high volume and high cost waste streams.




• Periodic Waste Minimization Assessments: Departments may consider using the waste generation assessment report to identify opportunities for waste minimization. Waste minimization techniques include material substitution of less toxic substances, process alterations and recycling of virgin and used chemicals from process to process.




• Training: Training in waste minimization procedures and techniques is a primary tool for the implementation of a waste minimization program. Personnel involved with hazardous waste generation activities are provided with waste minimization awareness training by the Department of Environmental Safety (DES) during hazardous waste training. Contact DES for additional training assistance.

Training

Training in waste minimization is recommended for all personnel who handle hazardous materials and generate hazardous waste. Training should include the benefits and techniques of implementing waste minimization.

Recordkeeping

Departments which generate hazardous waste are encouraged to document specific waste minimization activities and waste reductions. Waste tracking and inventory are the first steps in identifying waste minimization opportunities.

Written Program

It is recommended that departments develop and maintain a written waste minimization program tailored to each department's function and waste generation profiles.

University Resources

Written 2/00
Reviewed 4/05

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