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Biennial Hazardous Waste Reporting

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Biennial Hazardous Waste Reporting

Hazardous waste generators in California are required by federal and state regulations to submit a Biennial Hazardous Waste Report detailing waste streams and quantities handled at their facility. This comprehensive report must be submitted to Environmental Protection Agency (EPA) every two years.

Meeting biennial reporting obligations can be an arduous process (the EPA estimates an average of 17 hours is needed for businesses to accurately prepare these complex hazardous waste reports), but it doesn’t have to be. Let CDMS Consulting’s experienced team prepare and submit your Biennial Hazardous Waste Reports for you. With CDMS, you can have your hazardous waste biennial reports prepared for less cost than it would take your team to complete them in-house, saving your staff time and ensuring regulatory compliance.

Regulatory bodies
  • EPA (Environmental Protection Agency)
  • DTSC (Dept. of Toxic Substances Control)
  • CalEPA (California Environmental Protection Agency)
Who needs it

Facilities that generated Resource Conservation and Recovery Act (RCRA) waste exceeding 1000kg (2200 lbs.) in any calendar month of he qualifying year. These facilities are considered “Large Quantity Generators” (LQGs) There are some smaller thresholds for acutely (extremely) hazardous materials.

LQGs are defined as follows:

Generated in any single calendar month 1000 kg (2,200 lbs.) or more of RCRA hazardous waste;

Generated in any single calendar month, or accumulated at any time, more than 1 kg (2.2 lbs.) of RCRA acute hazardous waste; and/or

Generated in any single calendar month, or accumulated at any time, more than 100 kg (220 lbs.) of spill cleanup material contaminated with acute hazardous waste.

Regulation reference
  • 40 CFR 262.41
  • 22 CCR 66262.41
  • 40 CFR 264-265
  • 22 CCR Div 4.5
  • EPA Form 8700-13 A/B
What our service provides:

CDMS will prepare and submit your Biennial Hazardous Waste Reports for you, which will include:

 

  • Report Year: The reporting period, which covers two years, is specified to indicate the time frame under consideration.
  • Hazardous Waste Generator Status: The report indicates the generator status of the company (e.g., small quantity generator, large quantity generator) based on the amount of hazardous waste generated during the reporting period. The generator status determines regulatory requirements.
  • Waste Streams: A detailed list of all hazardous waste streams generated by the company during the reporting period, including their chemical composition, volume, and proper classification codes (EPA hazardous waste codes).
  • Waste Generation and Management: Information on how hazardous waste was generated, stored, treated, and disposed of or recycled during the reporting period. This includes details about storage locations, containers, and handling procedures.
  • Waste Minimization: Some reports may include information on the company’s efforts to minimize hazardous waste generation, such as pollution prevention practices and recycling initiatives.
  • Accumulation Timeframes: Specific information on how long hazardous waste was stored on-site before being shipped off-site for treatment, disposal, or recycling. Different waste types may have varying accumulation timeframes.
  • Manifests and Shipments: Records of all hazardous waste shipments made during the reporting period, including the names of waste transporters, dates of shipments, and destination facilities.
  • Treatment and Disposal Facilities: Details of the treatment, recycling, or disposal facilities used by the company for managing hazardous waste, including the names and addresses of these facilities.
  • Certification: The report typically requires a certification statement signed by an authorized representative of the company, confirming the accuracy and completeness of the information provided in the report.
  • Record keeping: Companies are required to maintain records related to hazardous waste generation and management for a specific period. The report may include information on recordkeeping practices.
  • Submission: Instructions for submitting the report to the appropriate regulatory agency, along with deadlines and contact information.

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What is the biennial hazardous waste report?
A report submitted by hazardous waste generators every 2 years detailing waste streams & quantities.

Who must submit a biennial hazardous waste report?
Generators producing over 1000 kg (2,200 lbs.) of hazardous waste per month or over 1 kg of acute hazardous waste.

What reporting period does the biennial report cover?
It covers waste activity for the previous odd-numbered year (e.g. 2021 for the 2023 report).

What information must be included in the report?
EPA ID number, generator status, waste streams, quantities, management methods, etc.

When is the report due to EPA and the state?
March 1st on even-numbered years (e.g. March 1, 2024 for the 2023 report).

Can I submit the report electronically or on paper?
The report must be submitted electronically through EPA’s RCRAInfo system.

What if I did not generate any hazardous waste during the reporting period?
You must still check the non-generator box on the report and submit it.

What if I miss the submission deadline?
There is a 60-day grace period with increased penalties. After 120 days, you are in violation.

What are the penalties for not submitting the report?
Violators can face steep fines up to $25,000 per day and permit restrictions.

Do I need to keep records related to the biennial report?
Yes, detailed generator records substantiating your report must be kept for 3 years.

What if there are errors on my submitted report?
You must submit a revised report if you identify any omissions or errors.

What changes require a new biennial report amendment?
Changes in generator status, additions of hazardous waste streams, etc.

Are small quantity generators exempt from submitting the report?
No, the requirement applies regardless of generator status.

Can someone prepare and submit the report on my company’s behalf?
Yes, you can have a consultant or third party prepare and submit the report for you. Please Contact Us to get support or request a Biennial Hazardous Waste Reporting. Our skilled team of EH&S specialists is ready to assist you.

Does each facility need to submit a separate biennial report?
Yes, each facility must submit a unique report covering that site’s waste activity.

Do I need to report on Conditionally Exempt Small Quantity Generator (CESQG) hazardous waste?
No, conditionally exempt small quantity generator waste is exempt.

Are training records required for personnel preparing the report?
There are no specific training requirements, but accuracy is mandatory.