Why You’re Legally Required to Generate Less Waste

Posted on 9/29/2021 by Roseanne Bottone

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)
hazardous waste source reduction strategies

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.

Last Live RCRA Refreshers for 2021 

Lion will present two final in-person RCRA workshops in 2021: The RCRA Hazardous Waste Management Refresher Workshop comes to Houston on November 1 and Dallas on November 4. 

The one-day RCRA refresher workshop will be delivered as part of a two-day program for hazardous waste professionals in Texas. Attend the RCRA Refresher and the Texas Hazardous & Industrial Waste Management Workshop to stay current on relevant Federal (US EPA) and State (TCEQ) requirements for professionals who manage hazardous waste in Texas. 

Houston & Dallas RCRA Workshops

Can't make it to Houston or Dallas? Join a Lion instructor for a RCRA hazardous waste webinar to knock out annually-required training before the year ends. 

RCRA Hazardous Waste Management Refresher (1 Day) 
October 12  |  November 9  |  November 30  |  December 14 

RCRA Hazardous Waste Management (2 Days) 
October 19–20  |  November 2–3  |  November 15–16  |  December 7–8



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

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