Is This A Hazardous Waste?

hazardous wasteWhat seems like a pretty easy question to answer can end up being quite convoluted to get the final answer. If you have ever been fortunate enough to be through an Environmental Protection Agency (EPA) inspection for your hazardous waste management, one of many items they will request are profiles for all or select waste streams. The responsibility to properly identify each waste stream as hazardous or non-hazardous falls on the generator.

There are several steps in the profiling process which begins with determining whether the waste is a solid waste. A solid waste is no longer usable in its current state without any type of reclamation or specifically excluded from the solid waste definition. If it is a solid waste, the next step would be to determine if it possesses hazardous waste characteristics, including ignitability, corrossivity, reactivity and/or toxicity. Laboratory testing may need to be performed on the waste stream to determine whether it possess one or more of these characteristics. If the waste stream has significant variability, testing should be done more frequently to account for varying composition.

Even if the waste does not exhibit the stated characteristics above, it still may be a listed hazardous waste. The generator will need to review the non-specific source (40 CFR 261.31) and source specific (40 CFR 261.32) waste lists. For discarded chemicals, the generator will need to review the listed wastes in 40 CFR 261.33.

Generator knowledge will be essential in identifying all products and chemicals that enter into or are in contact with the waste stream. A Safety Data Sheet (SDS) for the virgin product(s) will be helpful in identifying the characteristics which may still be present in the waste stream. The generator must understand the limitations of relying solely on the SDS for several reasons, including the RCRA toxicity thresholds are many times lower than what is required to be listed on the SDS and that other products used in the process generating the waste may change the characteristics.

All documentation used for making this waste determination must be kept in your environmental files for each waste stream, both hazardous and nonhazardous. So next time the EPA or your State regulatory agency asks for waste profiles you will be able to answer without doubt whether or not the waste stream is a hazardous waste.  If you have any question please feel free to talk with one of Bay Environmental Strategies, Inc., experienced professionals at 800 576-2476 ( or for more information look us up at

Planning for Hazardous Materials Before Renovation or Demolition Projects

tylerDo you have an upcoming renovation or demolition project on your schedule? For building owners and contractors, it is important to remember that building materials may contain hazardous toxins that may require specific handling, removal and disposal methods. Construction materials that are commonly encountered on the job site that may require specific care and disposal are:




Asbestos can be a cancerous causing substance that can cause numerous diseases and health concerns. It is a fibrous material that is still used today in several building materials because of its superior strength and excellent insulating properties. It can be found in adhesives, caulks, electrical panels, drywall, fireproofing, flooring tiles, insulation, paints, plaster, and exterior roofing materials. A licensed asbestos inspector can help you sample and identify asbestos containing material (ACM) on your project site. It is recommended for a single family homes and multi-family units (2-4 units) and required for any building undergoing a controlled fire exercise, multi-family units (larger than 5 units), commercial, and industrial buildings that inspections and all friable ACM is removed before work starts.  


Chlorofluorocarbons and Halons (CFCs)


CFCs contribute towards a loss in ozone which increases our chances of exposure from the sun’s Ultraviolet rays (UV). This increase the chance for skin, eye, and immune system concerns. CFCs are commonly found in bubblers, cooling units, heat pumps, and refrigeration appliances. Halrons are used in fire extinguishing devices. A project site walkthrough before demolition or renovation can help you identify CFC and Halron containing units.




Lead is commonly found in pre 1978 residential, commercial, and industrial exterior and interior paints. Lead can also be found in emergency lighting units. If lead is ingested and inhaled, it cause serious neurological and internal organ concerns. A licensed inspector can help sample and identify lead containing substances on your project site. Remember many buildings contain several layers and coats of paint.




Mercury is contained in several pressure and temperature monitoring devices. It can also be found in agricultural, dental, and electrical devices.  When exposed to an outside environment, Mercury slowly vaporizes which releases dangerous vapors that can go unnoticed by building owners and contractors. The harmful vapors can lead to several neurological and birth defects.


Polychlorinated biphenyls (PCBs)


PCBs are a cancer causing substance that can be found in caulk, electrical equipment, oils, and specialty paints. An environmental consultant can help you sample and identify PCB containing material on your project site. Labeling PCB containing materials before renovation or demolition can help limit the chance of exposure and contamination.


Performing a site walk through with an environmental consultant can help identify and ensure proper disposal of any hazardous materials that may exist on your project site. Collecting an inventory and gaining an understanding of all building materials on your project site can  help ensure hazardous materials do not impact public safety and the environment during your renovation or demolition project.


More information on handling hazardous materials before your renovation and demolition project can be found at:

How to Properly Manage Potential Household Hazardous Materials

As the weather warms up and summer is right around the corner, many people are cleaning out garages, getting lawn equipment ready, and tending to landscaping. Generating waste from these activities can be difficult to dispose of if you don’t know how to properly manage them. For those living in Brown County and all of Northeast Wisconsin, Brown County Port & Solid Waste has a household hazardous waste management program. The information below is provided by Brown County Port & Solid Waste for residents.

There are a lot of household products that contain hazardous materials. Disposing of them incorrectly could cause damage to the environment and harm to humans. Below is a guide to help you identify hazardous materials in your home.


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Images courtesy of Household Hazardous Waste Management form.


For additional information please see the following PDF provided by Brown County Recycling.