SOP 3.7: Business Waste Management

SOP 3.7: Minimal Quantity Business Generated Waste

1. Introduction 1

2. Regulatory and contractual requirements 1

3. Staff qualifications 1

4. Health and safety precautions 2

5. Prior to accepting MQG waste 3

6. MQG waste acceptance 4

1. Introduction

A Minimal Quantity Generator (MQG) is a business that generates 100 pounds (or 10 gallons) or less of hazardous waste (HW) per year. Minnesota HW rules allow for MQG businesses to dispose of HW at a HHW Facility for consolidation. However, acceptance of this waste type is optional for individual HHW Programs. A state-issued Very Small Quantity Generator (VSQG) license is required if a HHW Program chooses to accept MQG waste. Accepting MQG waste is taking a very important step in helping businesses properly dispose of HW in a cost-effective and environmentally responsible way.

2. Regulatory and contractual requirements

Acceptance of MQG waste is governed by Minn. Rules Chapter 7045.0221, 7045.0310, Department of Transportation (DOT) requirements (49 Code of Federal Regulation 173.24); and the requirements established in the HHW program/state agency contract (Exhibit A). To verify the current status of a business HW generator, see www.pca.state.mn.us/waste/epaID . To obtain an HW ID Number, see www.pca.state.mn.us/publications/w-hw1-02.pdf and www.pca.state.mn.us/publications/w-hw0-11.pdf . For an optional business waste acceptance form, see www.pca.state.mn.us/publications/w-hw7-15.doc.

3. Staff qualifications

3.1 Training

3.1.1 Thorough knowledge and training in proper waste processing is required. This Facility shall have a written training program that describes the management of wastes relevant to job duties and shall include function-specific training, safety, regulatory, and emergency procedures.

3.1.2 Staff shall be trained within six months of hire or starting a new position at the facility, or be supervised by trained staff until that time. Refresher training shall be conducted annually and properly documented.

4. Health and safety precautions

4.1 Safety requirements

Staff shall also take precautions to prevent impacts to the environment and follow the safety requirements as listed in Facility Emergency Contingency Plan. See SOP 2.10 HW Contingency Plan.

4.1.1 No smoking, eating, or drinking is allowed in waste processing areas of Facility.

4.1.2 Routinely look for immediate dangers to nearby staff and property. Keep alert for suspicious activities or behaviors in accordance with the program’s DOT Security Plan. See SOP 4.14 Security Issues.

4.1.3 Proper ergonomic techniques shall be utilized while managing wastes. See SOP 2.11 Ergonomics.

4.2 Health and personal protective equipment (PPE) requirements

This Program may choose to implement a more restrictive PPE policy as engineered solutions to environmental conditions and experienced staff judgment shall be used for unique conditions and situations. PPE shall be utilized if the potential for exposure remains after the institution of work practice controls. See SOP 2.4 Personal Protective Equipment.

The following PPE shall be used:

· Safety glasses with side shields, goggles, or equivalent eye protection

· Footwear with reinforced toe or toe caps or equivalent foot protection

· Nitrile gloves or equivalent hand protection

· Chemical splash apron, Tyvek coveralls, or equivalent body protection

· Respiratory protection according to respiratory protection plan

4.3 Emergency response

The Program shall not respond or attempt to control situations requiring assistance beyond the capabilities of Facility staff. This Program shall make prior agreements with response teams to use in emergency situations.

5. Prior to accepting MQG wastes

5.1 Tour other HHW collection programs currently accepting MQG waste.

Programs may choose to manage MQG waste using the VSQG waste acceptance protocol (e.g., providing the business with shipping paper, labels, etc.). Prior to accepting MQG waste, Facility staff may wish to copy established protocol of HHW programs currently accepting business HW, including:

· to charge a fee or not

· disposal price lists

· promotional or educational flyers

· computer programs for tracking HW

5.2 Determining generator status

5.2.1 Verify generator size. Determine business generator size prior to accepting HW. Only businesses generating up to 100 pounds or 10 gallons per year of non-acute HW qualify as a MQG. Licensure from the MPCA is required prior to OTG or VSQG waste acceptance. See SOP 3.8 VSQG and OTG Waste Acceptance. The MQG shall contact this Program prior to waste delivery to find out specific requirements. Prior to waste acceptance, staff shall verify the current generator status of the business.

5.2.2 Prohibited generator sizes. This Program shall not accept business HW unless licensed by the MPCA as a VSQG consolidation site. If not licensed, this Program shall not accept HW from any business generator qualifying as:

· MQG

· OTG

· VSQG

· Small Quantity Generators (SQG)—this generator size must hire other HW disposal contractor for HW disposal

· Large Quantity Generators (LQG)—this generator size must hire other HW disposal contractor for HW disposal

5.3 Notify the MPCA if SQG or LQG HW inadvertently arrives at the Facility. This waste shall not be managed or commingled at this Facility.

5.4 Determine if waste type is acceptable. The table below is a brief summary of acceptable/unacceptable waste types. See SOP 4.2.Waste Sorting.

Acceptable materials from MQGs / Unacceptable materials from MQGs
*latex / ammunition
oil base paints / explosives
acceptable lab pack materials / radioactive materials
fuels / acute HW
*fluorescent light bulbs
*pesticides
*batteries
*used oil
*used oil filters
*antifreeze / any HW quantity over 100 lbs. (or 10 gallons) per year
*Does not count toward generator waste status.

6. MQG waste acceptance

6.1 HW Generator Identification numbers

If an HW ID number is not already assigned, this Program shall assist the business to obtain a state-issued number prior to waste acceptance.

6.2 Materials of Trade DOT exemptions

MQGs generally meet all of the conditions qualifying the business HW and shall be provided with the necessary information for a DOT MOT shipment. See SOP 1.3 DOT. DOT exemptions do not require the MQG to:

· use shipping papers

· use placarding

· use DOT labels

· provide hazardous materials transportation training

6.3 Shipper/generator responsibilities for packaging

MQG waste shall be transported to the Facility in sturdy, non-leaking containers. The responsibility for safe and legal transportation of HW lies with the generator. Additional requirements may apply if the materials being transported are:

· hazardous substances (reportable quantities or RQs)

· not otherwise specified (NOS) constituents

· toxic constituents

· poison by inhalation hazard

· acute or P-listed (must be shipped by a licensed transporter)

· in quantities above 100 pounds

6.4 MQG waste processing

MQG waste can be commingled with HHW and is subject to indemnification provided the HW is transported for disposal from the Facility using the licensed state agency’s authorized transporter.

6.5 Recordkeeping

This Program is required to submit data to the State on an annual basis for MQG waste quantities processed. This record shall include:

· total annual number of businesses utilizing the Facility

· quantity of waste accepted

· type of waste collected

6.6 Product exchange display

Minimal Generator hazardous materials deemed reusable may be placed on product exchange shelves for reuse.

SOP 3.07 Minimal Quantity Business Generated Waste Effective date 9/26/2008 2