ECAR Fact Sheet for Arizona
Hazardous Wastes

Numerous automotive repair facilities routinely removers, waste acid, alkaline cleaning fluids, and generate a variety of waste materials that may be waste battery acid. Corrosive wastes are considered to be RCRA hazardous wastes. These waste materials include used motor oil, solvents, parts washer solutions, paints, antifreeze, used batteries, automotive fluids and a host of others. If these waste materials are not handled correctly, they can harm people and the environment when thrown away. Improper handling of hazardous waste is against the law and can result in fines and expensive cleanup work. This fact sheet has been developed to assist the auto recycling industry in proper handling of hazardous wastes, as required by federal hazardous waste management regulations (40 CFR) and Arizona's Rules for Hazardous Waste Management, Arizona Administrative Code 18-8-260 through 18-8-280.

Regulations

Hazardous Waste Determination. It is the responsibility of all solid waste generators to determine whether their waste is hazardous. The procedure for this is called a "hazardous waste determination." Wastes can be hazardous if they are either "listed" or "characteristic," or if they are a mixture of a listed hazardous waste and other wastes.

A. Listed wastes. Your waste is automatically classified as a listed hazardous waste if it appears on any one of the four lists of hazardous wastes found in the hazardous waste regulations. These wastes have been listed because they practically always exhibit one of the hazardous waste characteristics described previously or contain any number of toxic chemicals that have been shown to be harmful to human health and the environment. The regulations list over 400 hazardous wastes, including wastes derived from manufacturing processes and chemicals which are thrown away.

B. Characteristic wastes. Once a facility has reviewed the four lists, and determined whether generated wastes are found on any of the lists, a determination will need to be made to see if these wastes are "characteristic" hazardous wastes. There are four different characteristics: ignitability, corrosivity, reactivity, and toxicity.

C. Mixtures of listed wastes and other wastes. A mixture containing a non-hazardous solid waste and any amount of a listed hazardous waste is considered a hazardous waste. For example, if a pint of spent solvent such a toluene or benzene (an F005 listed hazardous waste) is mixed with a 55 gallon drum of waste antifreeze, the entire mixture (e.g., 55 gallons plus one pint) is considered a hazardous waste (as opposed to only one pint being a hazardous waste had the two wastes not been mixed). Hence, it is very important to keep wastes segregated. Not only is it better for the environment, but it will reduce disposal costs (it's more expensive to dispose of hazardous waste than it is solid waste).

D.  Universal Wastes. Universal wastes include nickel cadmium and small sealed lead-acid batteries, agricultural pesticides, thermostats and lights/lamps (e.g., fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium and metal halide lamps). Universal wastes have fewer waste management rules that apply to them.

Generator Rules. If you manage hazardous waste, you must determine your generator status. Your facility will fall under one of these three classifications.

• Conditionally Exempt Small Quantity Generator (CESQG). You are considered a CESQG in a calendar month if you generate no more than 100 kilograms (220 pounds) of hazardous waste in that month.

• Small Quantity Generator (SQG). You are considered an SQG if you generate greater than 100 kilograms (220 pounds) but less than 1,000 kilograms (2,200 pounds) of hazardous waste in a calendar month.

• Large Quantity Generator (LQG). You are considered an LQG if you generate 1,000 kilograms (2,200 pounds) or more of hazardous waste in a calendar month. You also are considered an LQG if you generate during a calendar month, or accumulate at any time, more than one kilogram of acutely hazardous waste, or more than a total of 100 kilograms (220 pounds) of any residue, contaminated soil, waste, or debris from cleaning up a spill of any acutely hazardous waste onto land or into water.

*One full 55-gallon drum = 459 pounds of hazardous waste. This representation assumes the waste is water based (weighs 8.34 pounds per gallon). Your waste could weigh more or less depending on its weight per gallon.

Complying with Hazardous Waste Rules. Once you have determined your generator status, you must comply with the applicable hazardous waste requirements. Arizona has adopted the federal RCRA requirements, but also has several more stringent requirements, particularly for SQGs and LQGs.

Record Keeping.As part of the cradle-to-grave manifest system, you will have certain record keeping requirements depending on your generator status.

For more information, visit ECAR's RCRA/Hazardous Waste Resource Locator.

Links to Regulations.

Hazardous Waste Listings

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