Why You’re Legally Required to Generate Less Waste

Minimizing the amount of hazardous waste your site generates helps to protect our environment. But that’s only one of the reasons that generators put extensive effort into waste minimization.

It’s also required by law.

The Legal Requirement to Generate Less Waste

To ship hazardous waste offsite using the Uniform Hazardous Waste Manifest, the generator must read and sign their name to the “waste minimization certification statement” in Item 15 of the document. A signature is required to ship any hazardous waste, with rare exceptions.

The "GENERATOR'S/OFFEROR'S CERTIFICATION" on the Manifest references two versions of the waste minimization statement in 40 CFR 262.27—one for large quantity generators and one for small quantity generators.

Large Quantity Generators Waste Minimization Statement

“I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable, and I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment.”

40 CFR 262.27(a)

Small Quantity Generator Waste Minimization Statement

“I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”

40 CFR 262.27(b)

When you sign Item 15, you certify that your facility made an effort to minimize or reduce the amount of hazardous waste your activities generated. 

See also:
Do I need DOT hazmat training to sign the Hazardous Waste Manifest?

Waste Minimization Strategies

One major way that facilities comply with the waste minimization mandate is by recycling.

Taking advantage of the recycling reliefs for specific materials already built into the regulations can help generators to:

• Reduce the quantity of hazardous waste generated;
• Save on virgin material costs; and
• Limit their exposure to hazardous waste management regulations. 

Other commonly employed waste minimization strategies include:   

• Establishing a first-in/first-out (FIFO) policy for materials and chemical products
• Using a bar-coding system to improve inventory tracking and control
• Educating buyers to understand drawbacks of large bulk purchases

For more ideas for controlling chemical inventory and preventing unused chemicals from becoming regulated as hazardous waste, download the guide 3 Tips for Hazardous Waste Source Reduction.

RCRA Training for Generators

Lion offers a range of RCRA training courses for industry professionals at every stage of a career. For managers with overall responsibility for RCRA compliance, we recommend comprehensive RCRA Hazardous Waste Management training.

Browse all online and in-person RCRA training options at Lion.com/RCRA.

Tags: environmental compliance, hazardous waste, RCRA, recycling, waste minimization, zero waste