As Environmental, Health, and Safety (EHS) professionals, one of our primary responsibilities is to remain informed about ever-changing regulatory requirements. Moreover, the ramifications of failing to comply with these requirements cannot be overstated. One of the many requirements is to submit hazardous waste reports for each of the numerous facilities an EHS team is overseeing. Non-compliance with waste reporting could lead to legal actions, hefty financial penalties, and, most importantly, negative impacts on both environmental well-being and public health. These adverse outcomes highlight the necessity of a solid commitment to regulatory compliance. Therefore, in this blog article, we will review:
- The nuances of annual and biennial hazardous waste reporting, which hold particular significance in 2024
- The what, why, and how of necessary compliance
- Emerging trends and changes to lookout for in 2025
Understanding the Basics of Hazardous Waste Reporting
Hazardous waste reporting is a critical component of environmental compliance for many facilities. The U.S. Environmental Protection Agency (EPA) requires large quantity generators of hazardous waste to submit a report every two years, known as the Biennial Hazardous Waste Report. However, some states, like New York, require annual reporting.
Who Needs to Report Hazardous Waste?
Any organization that meets the definition of a Large Quantity Generator (LQG) of hazardous waste in a single calendar month during the reporting year must submit a hazardous waste report. They will also need to report if the facility treats, stores, or disposes of hazardous waste on-site. Finally, facilities may be required to submit reports according to applicable state regulations, such as annual reporting requirement or reporting of additional waste types not mandated by federal regulations.
What to Include in Your Hazardous Waste Report
The hazardous waste report should include the following:
- Details about the facility, including EPA ID number and location
- General information, including waste descriptions, EPA hazardous waste codes, quantity generated, source, form, and management codes
- Offsite waste shipment information, including transporter information, receiving facility information, quantity shipped, and management codes used at the receiving facility
- Waste minimization efforts that include the description of the effort and progress achieved
- Site map and facility description
- Any attachments or supplemental information
It’s important to note that the organization should include all hazardous waste generated throughout the entire calendar year, including waste from one-time cleanup activities.
Hazardous Waste Reporting Deadlines and Electronic Reporting
For biennial reports, the deadline is typically March 1st of every even-numbered year, covering activities from the previous odd-numbered year. For annual reports, the deadline is usually March 1st of the following year. It is advisable to always check with the state regulatory agency for specific deadlines, which may vary. Many states now require, or strongly encourage, electronic submission of hazardous waste reports. The EPA’s RCRAInfo system is widely used for this purpose. Before starting the online submission process, companies should familiarize themselves with their state’s specific requirements and user guides.
Best Practices for Efficient Waste Reporting
Improving the waste reporting process is crucial for maintaining accuracy and reducing the administrative burden on EHS teams. By establishing consistent data collection systems all year round, organizations can streamline the process, rather than acting under last minute pressure, increasing chances of error. The introduction of automated data collection and verification processes significantly minimizes errors and saves precious time and resources.
Staying up to date about EPA guidelines and state-specific requirements is important because it will ensure that your organization’s reporting remains compliant, even as regulations are updated. Furthermore, involving all relevant stakeholders in the data collection process is key to ensuring thorough and precise reporting. This collaborative approach will also nurture a culture of environmental responsibility throughout the organization.
Additionally, harnessing analytics to pinpoint waste management trends and improvement opportunities will elevate the organization’s hazardous waste reporting process from a mere compliance task to a valuable tool for enhancing waste management practices. By adopting these best practices, your organization can simplify its reporting process and gain invaluable insights that steer continuous improvement in overall environmental performance.
For more information on best practices, check out our blog, Best Practices for Biennial Hazardous Waste Reporting
Emerging Trends in Hazardous Waste Reporting
As we approach the end of 2024, it’s essential to be aware of potential changes on the horizon:
- The EPA has proposed changes that would clarify its authority to address releases of substances that meet the statutory definition of hazardous waste, even if they’re not currently listed in regulations. This could potentially impact future reporting requirements.
- While not explicitly addressed in current hazardous waste reporting, there’s increasing attention on per- and polyfluoroalkyl substances, or PFAS. EHS professionals should stay informed on potential requirements for these “forever chemicals”.
- Several states are advancing legislation to make producers more responsible for the waste they create, particularly for plastics and packaging. While not directly related to hazardous waste reporting, this trend could impact overall waste management practices.
In conclusion, staying proactive and informed about hazardous waste reporting is more crucial than ever in 2024. By understanding who needs to report, what to include, and adhering to deadlines, organizations will ensure their facilities meet all regulatory obligations. Implementing best practices, like consistent data collection and embracing technological solutions, will streamline the reporting process and reduce human error. As emerging trends indicate potential changes in regulations, particularly concerning substances like PFAS, staying ahead of the curve is essential.
Now is the time to reinforce the organization’s commitment to hazardous waste compliance by turning reporting obligations into opportunities for continuous improvement in environmental performance.
