Paints & Coatings Resource Center

Plain Language Guide to Regulations
Solid/Hazardous Waste Management


DO Measure:
All quantities of listed and characteristic hazardous wastes that are:
  • Accumulated on the property for any period of time before disposal or recycling. (Dry cleaners, for example, must count any residue removed from machines, as well as spent cartridge filters.)
  • Packaged and transported away from your business.
  • Placed directly in a regulated treatment or disposal unit at your place of business.
  • Generated as still bottoms or sludges and removed from product storage tanks.
DO NOT Measure:
Wastes that:
  • Are specifically exempted from counting. Examples include lead-acid batteries that will be reclaimed, scrap metal that will be recycled, used oil managed under the used oil provisions of 40 CFR 279, and universal wastes (e.g., batteries, pesticides, and thermostats) managed under 40 CFR 273.
  • Might be left in the bottom of containers that have been thoroughly emptied through conventional means such as pouring or pumping.
  • Are left as residue in the bottom of tanks storing products, if the residue is not removed from the product tank.
  • Are reclaimed continuously on site without storing prior to reclamation, such as drycleaning solvents.
  • Are managed in an "elementary neutralization unit," a "totally enclosed treatment unit," or a "wastewater treatment unit," without being stored first. (See definitions at the end of this document for an explanation of these types of units.)
  • Are discharged directly to publicly owned treatment works (POTWs) without being stored or accumulated first. This discharge to a POTW must comply with the Clean Water Act. POTWs are public utilities, usually owned by the city, county, or state, that treat industrial and domestic sewage for disposal.
  • Have already been counted once during the calendar month, and are treated on site or reclaimed in some manner, and used again.
  • Are regulated under the universal waste rule or have other special requirements. The federal regulations contain special, limited requirements for managing certain commonly generated wastes. These wastes can be managed following the less burdensome requirements listed below instead of the usual hazardous waste requirements. Check with your state agency to determine if your state has similar regulations.

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