What’s in a name? Did you know that, according to the Department of Ecology, anything you “designate as” a dangerous waste is regulated as a dangerous waste? It has long been the practice of generators of solid waste to label certain wastes as “dangerous” (or “hazardous”) and to dispose of those wastes as such simply because it is cheaper and easier than making a proper “determination” of whether the solid waste is “listed” or exhibits a “characteristic” of a dangerous waste. But the applicable regulations regarding storage, transport and disposal are so convoluted that the actual on-site management often does not fully comply with the regulations. In that circumstance, the fact that the waste never met the definition of a dangerous waste is no defense to substantial penalties, according to Ecology. Besides that, a generator’s failure to make a dangerous waste “determination” can lead to penalties in itself even if the generator has labeled and managed a waste as “dangerous waste.” Don’t get caught in this dangerous trap. Know whether your waste meets the definition of a dangerous waste. Environmental Compliance can help with that.
