How to Dispose of Hazardous Waste: A Complete Step-by-Step Guide for Businesses
How to Dispose of Hazardous Waste: A Complete Step-by-Step Guide for Businesses
Last Updated: October 2025
Improper hazardous waste disposal can result in fines exceeding $70,000 per day, environmental damage, and even criminal charges. Yet many business owners don't know where to start when it comes to properly managing their hazardous waste. This comprehensive guide walks you through every step of the disposal process, ensuring your business stays compliant and protected.
In this guide, you'll learn:
How to identify hazardous waste
Proper storage requirements
How to choose a disposal company
The manifest process
Documentation requirements
Common mistakes to avoid
Step 1: Identify Your Hazardous Waste
Before you can dispose of waste properly, you need to know what's hazardous and what's not.
The Two Ways to Identify Hazardous Waste
Method 1: Listed Wastes
The EPA maintains lists of specific wastes that are always hazardous:
F-List (non-specific source wastes):
Spent halogenated solvents (F001-F005)
Spent non-halogenated solvents (F001-F005)
Electroplating wastes (F006-F012, F019)
Petroleum refining wastes (F037-F039)
K-List (source-specific wastes):
Industry-specific manufacturing wastes
Wood preservation wastes
Petroleum refining wastes
Pesticide manufacturing wastes
P-List (acute hazardous wastes):
Extremely toxic chemicals
Small quantities trigger regulations
Examples: certain pesticides, cyanides, some pharmaceuticals
U-List (toxic wastes):
Toxic commercial chemicals
Examples: acetone, benzene, many solvents and chemicals
If your waste appears on any EPA list, it's hazardous—period.
Method 2: Characteristic Wastes
If your waste isn't listed, it may still be hazardous if it exhibits any of these characteristics:
Ignitability (D001):
Liquids with flash point <140°F (60°C)
Examples: paint thinners, solvents, gasoline
Test: Flash point testing
Corrosivity (D002):
pH ≤2 or ≥12.5
Examples: battery acid, drain cleaners, rust removers
Test: pH measurement
Reactivity (D003):
Unstable, explosive, or reacts violently with water
Examples: peroxides, sodium metal, some cyanides
Test: Observation and chemical knowledge
Toxicity (D004-D043):
Contains toxic metals or organics above limits
Examples: lead paint, mercury items, certain pesticides
Test: TCLP (Toxicity Characteristic Leaching Procedure)
Where to Find Information
Safety Data Sheets (SDS): Check Section 13 (Disposal Considerations) and Section 14 (Transport Information) for hazard information.
EPA Waste Code Database: Search online for specific chemicals.
Professional Help: When in doubt, contact a hazardous waste professional for waste characterization.
Step 2: Determine Your Generator Category
Your regulatory requirements depend on how much hazardous waste you generate monthly.
Very Small Quantity Generator (VSQG)
If you generate:
Less than 100 kg (220 lbs) per month of hazardous waste
Less than 1 kg (2.2 lbs) per month of acute hazardous waste (P-listed)
Requirements:
Identify waste properly
Don't accumulate more than 1,000 kg (2,200 lbs) on-site
Ensure waste goes to approved facilities
No EPA ID number required (in most states)
Small Quantity Generator (SQG)
If you generate:
Between 100-1,000 kg (220-2,200 lbs) per month
Less than 1 kg of acute hazardous waste
Requirements:
Obtain EPA ID number
Store waste properly with labels and dates
Remove waste within 180 days (or 270 days if disposal site >200 miles)
Use hazardous waste manifest
Basic emergency preparedness
Basic employee training
Large Quantity Generator (LQG)
If you generate:
More than 1,000 kg (2,200 lbs) per month
More than 1 kg of acute hazardous waste
Requirements:
EPA ID number mandatory
Remove waste within 90 days
Comprehensive emergency response plan
Formal employee training program
Weekly inspections documented
Contingency plan
Biennial reporting
Full manifest system
Track your generation carefully—exceeding limits even once can change your category.
Step 3: Set Up Proper Storage
Improper storage is one of the most common violations. Here's how to do it right.
Container Requirements
Use Appropriate Containers:
Compatible with waste type (acids in acid-resistant containers)
In good condition (no rust, leaks, or damage)
Properly sized for the waste
Closed except when adding/removing waste
Common Options:
5-gallon plastic pails (small quantities)
15-30 gallon drums (moderate quantities)
55-gallon steel or poly drums (standard)
275-330 gallon totes (large quantities)
Labeling Requirements
All containers must be labeled with:
"HAZARDOUS WASTE" (required text)
Contents: Specific waste description (not just "waste" or "chemicals")
Good: "Spent Acetone"
Bad: "Solvent"
Accumulation Start Date: Date when first waste was added
Format: MM/DD/YYYY
Must be visible and legible
Hazard Warnings: Based on characteristics
Examples: "Flammable," "Corrosive," "Toxic"
EPA Waste Codes: If you're an SQG or LQG
Examples: "D001," "F003," "U002"
Storage Location Requirements
Choose storage areas that:
Are away from drains and waterways
Have impermeable flooring
Include secondary containment (for liquids)
Are protected from weather (if outdoors)
Have adequate ventilation (especially for vapors)
Are accessible for inspections and pickups
Are separate from production areas
Have clear aisle space
Secondary Containment:
Must hold 110% of largest container's volume
Can be berms, pallets, containment systems
Required for liquid hazardous waste
Incompatible Waste Separation
Never store together:
Acids and bases (can react violently)
Oxidizers and flammables (fire/explosion risk)
Cyanides and acids (generates toxic gas)
Water-reactive materials and water
Any incompatible chemicals per SDS
Use separate storage areas or spacing for incompatible wastes.
Accumulation Time Limits
VSQGs: No specific time limit, but limited to 1,000 kg on-site
SQGs: 180 days maximum (270 if disposal >200 miles away)
LQGs: 90 days maximum
Exceeding these limits requires a permit—removing waste on time is crucial.
Step 4: Register with the EPA (If Required)
SQGs and LQGs must obtain an EPA Identification Number.
How to Register
Step 1: Determine Your State's Process Some states manage their own programs and have specific registration procedures. Check your state environmental agency website.
Step 2: Complete EPA Form 8700-12 "Notification of Regulated Waste Activity"
Information needed:
Business name and address
Business contact information
Waste description and codes
Generator category
Waste management activities
Step 3: Submit Your Application
Submit to your state environmental agency or EPA regional office
Some states have online systems
Processing typically takes 2-6 weeks
Step 4: Receive Your EPA ID Number
12-character identifier (e.g., CAD000000000)
First 2 letters = state
Required on all manifests and shipping papers
Update Your Registration If:
You move locations
Your generation rates change categories
Your waste types change significantly
Business ownership changes
Step 5: Choose a Licensed Hazardous Waste Disposal Company
Not all waste companies handle hazardous materials. Here's how to select the right one.
What to Look For
Proper Licensing:
EPA ID number (verify at EPA website)
State hazardous waste transporter license
DOT hazardous materials registration
Required insurance coverage
Experience:
Years in business (look for 5+ years minimum)
Experience with your waste types
Experience with your industry
References from similar businesses
Services Offered:
Waste types they handle
Service area coverage
Container supply
Pickup frequency options
Emergency service availability
Documentation provided
Pricing Transparency:
Detailed quotes
All fees explained
No hidden charges
Volume discounts available
Disposal Facility Network:
Uses EPA-approved facilities only
Provides certificates of disposal
Explains disposal methods
Multiple facility options
Questions to Ask Potential Companies
"Are you licensed to transport hazardous waste in our state?"
"What's your EPA ID number?" (Verify it online)
"Which disposal facilities do you use?" (Check if EPA-permitted)
"What documentation do you provide?" (Should include manifests and certificates)
"How quickly can you respond to our needs?" (Important for emergencies)
"Have you handled [your specific waste type] before?"
"What happens if our waste can't be disposed of as profiled?"
"Do you carry adequate insurance?" (Request certificate of insurance)
"What's included in your pricing?" (Avoid surprises)
"Can you provide references?" (Talk to current clients)
Red Flags to Avoid
Don't work with companies that:
Offer prices dramatically lower than competitors (may be illegal dumping)
Can't provide proof of licensing
Don't ask questions about your waste
Promise to dispose of anything with no questions
Don't provide proper documentation
Have no insurance
Won't provide references
Use non-permitted disposal sites
Remember: You remain liable if your waste is improperly disposed of, even if you hired someone else.
Step 6: Prepare Your Waste for Pickup
Proper preparation ensures smooth pickup and compliance.
Before Pickup Day
Organize Your Waste:
Group similar waste types together
Separate incompatible materials
Have all containers properly labeled
Verify accumulation dates are visible
Ensure containers are in good condition
Prepare Access:
Clear pathways to waste storage
Ensure loading dock or pickup area is accessible
Have forklift available if needed
Notify security/reception of scheduled pickup
Gather Documentation:
Safety Data Sheets for all wastes
Previous disposal records
Any lab analysis results
Generator profile information
The Waste Profile
Your disposal company will need a "waste profile" containing:
Waste description and origin
EPA waste codes
Physical state (solid, liquid, sludge)
Hazard characteristics
Chemical composition
How the waste was generated
Any special handling requirements
This information helps determine proper disposal method and pricing.
Step 7: The Manifest Process
The hazardous waste manifest tracks waste from cradle to grave.
Understanding the Uniform Hazardous Waste Manifest
The manifest is a multi-part form that:
Documents waste from generator to disposal
Tracks quantity and type
Identifies all parties involved
Proves proper disposal occurred
Manifest Completion Steps
Section 1: Generator Information
Your company name and EPA ID number
Site address where waste was generated
Emergency response phone number
Section 2: Transporter Information
Transporter company name and EPA ID
Usually completed by disposal company
Section 3: Disposal Facility Information
Facility name and EPA ID
Facility address
Disposal method code
Section 4: Waste Description
EPA waste codes
DOT shipping name
Quantity (weight or volume)
Container type and number
Special handling instructions
Signatures Required:
Generator signature (you)
Transporter signature (pickup driver)
Disposal facility signature (when received)
Electronic Manifests (e-Manifest)
EPA's e-Manifest system allows electronic tracking:
Faster processing
Reduced paperwork
Better tracking
Required by some states
Your disposal company should handle e-manifest submission.
What You Receive
After disposal, you should receive:
Signed copy of manifest (proof of delivery)
Certificate of disposal/destruction
Final processing documentation
Keep these records for at least 3 years (EPA requirement)
Step 8: Record Keeping & Documentation
Proper records protect you during inspections and audits.
Required Records
Manifests:
Retain all manifest copies for 3+ years
File chronologically or by waste type
Include e-manifest confirmations
Disposal Certificates:
Keep all certificates of disposal
Match to corresponding manifests
3+ year retention minimum
Waste Analysis:
Lab test results
TCLP reports
Waste characterizations
Process knowledge documentation
Training Records:
Employee training dates
Topics covered
Instructor information
Attendee signatures
Inspection Logs:
Weekly storage area inspections (for LQGs)
Container condition checks
Any corrective actions taken
Quantity Records:
Monthly waste generation amounts
Accumulation dates
Disposal dates and quantities
Organization Tips
Create a Compliance Binder:
Section 1: Current manifests (pending disposal)
Section 2: Completed manifests (past 3 years)
Section 3: Disposal certificates
Section 4: Waste profiles and analyses
Section 5: Training records
Section 6: Inspection logs
Section 7: EPA correspondence
Digital Backup:
Scan all documents
Store securely in cloud or server
Organize by date and waste type
Backup regularly
Step 9: Employee Training
Everyone who handles hazardous waste must be trained.
What Training Should Cover
Waste Identification:
How to recognize hazardous waste
Understanding waste codes
Using SDSs for information
Proper Handling:
Container selection and use
Labeling requirements
Accumulation time limits
Incompatibility concerns
Storage Requirements:
Where waste can be stored
Container management
Inspection procedures
Security measures
Emergency Response:
Spill response procedures
Emergency contacts
Evacuation procedures
Reporting requirements
Regulatory Compliance:
Generator category requirements
Manifest process
Documentation needs
Consequences of violations
Training Frequency
Initial Training: Before employees handle waste
Refresher Training: Annually minimum
Additional Training: When:
Procedures change
New waste types are generated
Violations or incidents occur
Job responsibilities change
Document all training with: Date, topics, duration, trainer name, and attendee signatures
Step 10: Common Mistakes to Avoid
Learn from others' costly errors:
Mistake #1: Mixing Incompatible Wastes
The Problem: Creates dangerous reactions, makes disposal impossible, increases costs dramatically
The Solution: Keep acids, bases, oxidizers, and flammables separated
Mistake #2: Improper Labeling
The Problem: Most common EPA violation, leads to fines and safety hazards
The Solution: Use compliant labels with all required information from day one
Mistake #3: Exceeding Accumulation Time Limits
The Problem: Triggers permit requirements, major compliance violation
The Solution: Track accumulation dates carefully, schedule pickups with buffer time
Mistake #4: Using Unlicensed Haulers
The Problem: You remain liable forever if waste is illegally dumped
The Solution: Verify all licenses and EPA ID numbers before hiring
Mistake #5: Poor Record Keeping
The Problem: Can't prove compliance during inspections, results in citations
The Solution: Maintain organized files, keep everything for 3+ years minimum
Mistake #6: Drain Disposal
The Problem: Illegal, expensive cleanup, criminal charges possible
The Solution: Never put hazardous waste down drains, even diluted
Mistake #7: Treating Waste as Regular Trash
The Problem: Landfill rejection, EPA violations, environmental damage
The Solution: When in doubt, treat as hazardous and get professional help
Mistake #8: Ignoring Employee Training
The Problem: Improper handling, spills, violations, safety incidents
The Solution: Train all employees before they handle waste, document thoroughly
Mistake #9: Storing Waste Too Long
The Problem: Accumulation violations, increased liability, container deterioration
The Solution: Schedule regular pickups before time limits approach
Mistake #10: Choosing Based on Price Alone
The Problem: Low-cost providers may cut corners, leading to liability
The Solution: Evaluate licensing, experience, and reputation alongside pricing
Emergency Situations
If You Have a Spill
Immediate Actions:
Ensure personal safety first
Evacuate unnecessary personnel
Contain the spill if safe to do so
Prevent drain entry
Call for professional help if needed
Reporting Requirements:
Spills over "reportable quantities" must be reported to National Response Center (1-800-424-8802)
Notify state environmental agency
Document incident thoroughly
Cleanup:
Use appropriate PPE
Follow spill response procedures
Dispose of cleanup materials as hazardous waste
Review procedures to prevent recurrence
If EPA or State Inspectors Arrive
During Inspection:
Be cooperative
Don't sign anything without reading carefully
Take notes on inspector's comments
Photograph any areas of concern
After Inspection:
Document all findings
Address any violations immediately
Consult with environmental attorney if serious issues found
Respond to all agency requests promptly
Conclusion: Your Hazardous Waste Disposal Checklist
Follow this checklist for every disposal:
Before You Generate Waste: ☐ Identify if waste is hazardous ☐ Know your generator category ☐ Have proper containers ready ☐ Train all employees
During Waste Generation: ☐ Use appropriate containers ☐ Label immediately with all required info ☐ Mark accumulation start date ☐ Store in compliant location ☐ Keep incompatible wastes separated ☐ Track quantities generated
When Scheduling Disposal: ☐ Verify accumulation time limits ☐ Choose licensed disposal company ☐ Prepare waste profile information ☐ Schedule pickup with adequate time ☐ Prepare site access
During Pickup: ☐ Verify driver credentials ☐ Review and sign manifest ☐ Keep generator copy ☐ Document pickup date
After Disposal: ☐ Receive signed manifest copy ☐ Obtain certificate of disposal ☐ File all documentation ☐ Retain records for 3+ years ☐ Update your waste tracking
Get Expert Help with Hazardous Waste Disposal
Still have questions? Need professional assistance?
Call Hazardous Waste Disposal at (800) 582-4833
We provide:
Free waste identification assistance
Proper containers and labels
Complete manifest handling
Licensed nationwide service
All necessary documentation
Compliance guidance
Email: info@hazardouswastedisposal.com
Serving businesses in all 50 states since 1992
Let our 30+ years of experience keep your business compliant and protected.