Insightful Counsel, Sustainable Solutions SCHEDULE A MEETING

Navigating Hazardous Waste Disposal in Oregon

Frank Hammond June 23, 2023

In an era where environmental protection is of utmost importance, it is crucial for individuals and businesses to understand the intricacies of hazardous waste disposal. For those residing or operating in Oregon, it’s essential to be well-versed in the state’s regulations surrounding this matter. As a lawyer, I aim to shed light on the basics of hazardous waste disposal in Oregon, providing an overview of key guidelines and practices that will help you navigate this complex landscape.

Understanding Hazardous Waste

Hazardous waste refers to any discarded material that possesses properties, either directly or indirectly, which make it dangerous or potentially harmful to human health or the environment. Examples of hazardous waste include certain chemicals, solvents, heavy metals, and pharmaceuticals. It is imperative to handle such waste with care to prevent adverse impacts on public health and the environment.

The Oregon Department of Environmental Quality (DEQ)

In Oregon, the DEQ plays a central role in overseeing hazardous waste management. The DEQ’s primary objective is to protect human health and the environment by regulating the generation, storage, transport, treatment, and disposal of hazardous waste. To ensure compliance, the DEQ has established specific rules and requirements for generators of hazardous waste.

Classification of Generators

Oregon classifies hazardous waste generators into three categories: Small Quantity Generators (SQGs), Large Quantity Generators (LQGs), and Conditionally Exempt Small Quantity Generators (CESQGs). Each category has its own set of requirements and limitations.

Small Quantity Generators (SQGs)

SQGs generate between 220 pounds and 2,200 pounds of hazardous waste per month. Key considerations for SQGs include:

  1. Manifesting: SQGs must use a hazardous waste manifest when shipping hazardous waste off-site.

  2. Accumulation Time: SQGs can accumulate hazardous waste on-site for up to 180 days without obtaining a permit.

  3. Employee Training: SQGs must provide their employees with appropriate hazardous waste management training.

Large Quantity Generators (LQGs)

LQGs generate more than 2,200 pounds of hazardous waste per month. LQGs face more stringent requirements, including:

  1. Permit Requirement: LQGs must obtain a hazardous waste permit from the DEQ.

  2. Manifesting: LQGs must use a hazardous waste manifest when shipping hazardous waste off-site.

  3. Reporting: LQGs are required to submit annual reports to the DEQ regarding their hazardous waste generation and management activities.

Conditionally Exempt Small Quantity Generators (CESQGs)

CESQGs generate less than 220 pounds of hazardous waste per month and are subject to reduced regulations. CESQGs enjoy certain exemptions, but they still need to manage their hazardous waste properly.

Best Practices for Hazardous Waste Disposal

Regardless of the generator category, responsible hazardous waste disposal should always be a priority. Here are some general best practices to keep in mind:

  • Identify and Segregate: Properly identify and segregate hazardous waste from non-hazardous waste to prevent contamination.

  • Labeling and Packaging: Ensure that hazardous waste containers are properly labeled, sealed, and compatible with the waste they hold.

  • Storage and Handling: Store hazardous waste in a designated area with appropriate containment measures to prevent spills or leaks.

  • Transportation: When shipping hazardous waste off-site, comply with the DEQ’s manifesting requirements and use licensed transporters.

  • Training and Education: Provide adequate training to employees handling hazardous waste to minimize risks and ensure compliance.

As a lawyer, I emphasize the significance of understanding and adhering to the regulations surrounding hazardous waste disposal in Oregon. Compliance with the DEQ’s guidelines not only protects public health and the environment but also safeguards your business from potential legal and financial consequences. By familiarizing yourself with the classification of generators and following best practices for waste management, you can navigate the hazardous waste disposal landscape with confidence, contributing to a cleaner and safer Oregon for all.

With more than three decades of experience, we have a deep understanding of how regulations can intersect with land use issues and development projects. For a consultation with our Portland office, call or email us directly.