March 1st is the due date for submittal of the 2011 Biennial Hazardous Waste Report (EPA Form 8700-12 A/B). Its purpose: reporting to the EPA about the generation, management and final disposition of hazardous waste regulated by the Resource Conservation and Recovery Act (RCRA). Though the US EPA requires the report be submitted every even-numbered year for the previous calendar year, some states have chosen to make it an annual requirement.
Each of the following regulated entities has a responsibility to submit the annual report:
- Treatment Storage and Disposal Facility’s (TSDF’s) that treat, store, or dispose of hazardous waste on-site during the reporting year must submit the entire report.
- Large Quantity Generators (LQG) of hazardous waste. You are required to submit the entire report if you were an LQG for any calendar month in the reporting year. If you wish, you need only report the waste you generated for the month you exceeded the LQG status threshold.
- Small Quantity Generator (SQG) of hazardous waste. An SQG may receive a notice to complete the report. In this case you need only indicate on the form that you were an SQG for the reporting year, sign, and submit the report.
If you are unaware of your hazardous waste generator status, this survey will assist you.
The US EPA allows states to manage the RCRA Hazardous Waste Program themselves as long as their program is authorized by the Federal Agency. To be authorized, state regulations must be at least as strict and as broad as the Federal regulations, they are allowed to be more strict and more broad. A perfect example of this is that while the US EPA requires a Biennial Hazardous Waste Report, many states have made it an annual requirement, due each and every March 1st for the previous calendar year. Another difference between the state and Federal level for this report is the requirement of some states, but not the US EPA, to submit the Off-Site Identification Form (Form OI). In addition some states require separate annual reports – sometimes with fees – from companies within their borders, some examples:
- Illinois has an annual Non-Hazardous Waste Report due February 1st.
- Iowa (a state without an authorized RCRA Hazardous Waste Program) has an annual Hazardous Waste Activities Form due April 15th for LQG’s and SQG’s.
- North Carolina has a Small Quantity Generator Waste Minimization Questionnaire due July 31st.
Check with your state environmental agency to determine what, if any, reporting requirements or fees they might have in addition to the US EPA.
There have been some changes to the report for 2011 in regards to definitions, source codes, form codes, and the instructions. Minor changes were also made to the Site ID Form and the Form GM. Read carefully the 2011 Hazardous Waste Report Instructions and Form for changes that may apply to you.
If you find yourself sitting at a desk with the report form and instructions and a stack of the previous year’s Uniform Hazardous Waste Manifests on February 29th, I urge you to consider a system to track your waste generation and off-site disposal. Maintaining records throughout the year pays off big dividends when the Biennial (Annual in some states) Hazardous Waste Report is due.
To learn more about other regulatory requirements for hazardous waste generators including the training requirements of 40 CFR 265.16, attend one of my open enrollment training events. This one day of training also meets the requirements of the PHMSA/US DOT for HazMat Employees involved in the transportation of hazardous materials.
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