Who Needs A Hazardous Waste Permit?
Actually, only a few types of businesses need a hazardous waste “permit”, also referred to as a RCRA permit. These are sites that are regulated as treatment, storage, or disposal facilities, referred to as TSDFs. If not actually disposing of wastes on-site, some facilities can inadvertently become TSDFs if they handle wastes in a manner considered “treatment” or if they store hazardous wastes from more than 90-days. In most cases, facilities make sure their handling of wastes would be be considered treatment and store wastes for less than 90 days to avoid being regulated as a TSDF and therefore needing a permit.
If Not A Permit, What Do I Need?
There are other types of licences and authorizations that might be required; these are sometimes mistakenly referred to as a “permit”. Some of the common requirements are for:
- Registering for an EPA facility ID number
- Notification of hazardous waste activities
- Applying for hazardous waste licence with State or local agencies.
Whether any of these are required for an individual location will depend on a number of factors, including how much waste is generated, how often waste is generated, and specific requirements in State and local regulations.
Caltha LLP assists hazardous waste generators in applying for hazardous waste generator licence, developing hazardous waste management programs, providing employee hazardous waste training and waste reduction / waste minimization consulting.