Frequently Asked Questions
This page contains answers to commonly asked questions. The answers are generalized and are not applicable in all circumstances. If you are seeking an answer to a question requiring more specific information, please contact the Hazardous Waste Division directly at 717-787-6239.
Where can I get help to reduce my hazardous waste?
The Hazardous Waste Minimization Program offers services to companies that generate waste. These services include free Waste Minimization/Pollution Prevention Site Visits, Source Reduction Strategy development, as well as recognition programs for companies who voluntarily reduce hazardous waste. For more information on the services available to you please click on the following link:
Hazardous Waste Minimization
Does PA have universal wastes different than the Federal program?
Pennsylvania incorporates the federal regulations by reference, thus the universal waste program is part of PA regulation. PA recognizes the wastes termed as universal wastes under the federal program along with mercury-containing devices. Other wastes are presently under consideration to be included as universal wastes.
What do I do with a spent fluorescent light bulb from my house?
Spent fluorescent lamps should be recycled by taking them to a household hazardous waste collection event, or by shipping them to a mercury recycler. They can be put out with other household trash as hazardous waste from a household is exempt from hazardous waste regulation in PA and most other states.
Fluorescent Lamp Recycling
Does PA allow the use of commercial drum-top bulb crushers for spent fluorescent lamps?
Not at this time. The federal regulations prohibit the use of bulb crushers without a permit and PA incorporates those regulations. Fluorescent lamps contain mercury that is very pervasive throughout the environment. If the drum-top crushers receive federal approval, PA will consider their use.
Do I have to submit a new EPA 8700-12 hazardous waste notification form and change my generator status if I generate an increased amount of hazardous waste for one month and exceed the quantity limits for either VSQGs or SQGs?
Pennsylvania's hazardous waste management regulations allow for "episodic" generation events. Episodic event means an activity or activities, either planned or unplanned, that does not normally occur during generator operations, resulting in an increase in the generation of hazardous wastes that exceeds the calendar month quantity limits for the generator's usual category. 40 CFR 262.232, as incorporated by reference, states that VSQGs and SQGs may maintain their existing generator category for hazardous waste generated during an episodic event provided certain conditions are met.
planned episodic event, a generator must notify the Department thirty (30) calendar days prior to initiating the planned episodic event using the EPA Form 8700-12. For an
unplanned episodic event, the generator must notify DEP within 72 hours of the unplanned event via phone, email, or fax and subsequently submit EPA Form 8700-12.
The generator must have an EPA ID number to take advantage of the episodic generator provision. Generators are limited to claiming one episodic event per calendar year, unless a petition to manage one additional episodic event is granted by DEP under 40 CFR 262.233. Any notifications of episodic generation events that are not within the time limits noted above, or claims made within one year of a previous episodic event without Department approval, may result in an enforcement action.
Does an episodic event impact a generator's requirement to submit a biennial report?
A VSQG or a SQG that generates more than their normal category amount as part of an episodic event does not become a large quantity generator and does not need to complete a Biennial Report. The episodic generator provision allows a VSQG or an SQG to generate additional quantities of hazardous waste — temporarily exceeding its normal generator category limits — and still maintain its existing generator category, provided the generator complies with the specified conditions. Episodic hazardous wastes generated during an episodic generation event do not apply to the generator's category determination.
If I move my facility to a different location can I still use my same EPA ID number?
No, EPA ID numbers are site (location) specific. When a facility relocates they should notify DEP so that the old number can be inactivated. If the facility moves to a location that has an existing identification number, the regulations require the facility to notify the DEP so that the existing number can be reactivated. If the new location does not have an EPA ID number, the facility must renotify (complete form 8700-12) for the new location. Very small quantity generators (VSQGs) are not required to notify.
If I own a facility which has an EPA ID number for that address, and I sell, rent or lease part of it to another generator, do they use the same number?
The regulations don't specifically prohibit that from happening. It is generally not advantageous for a person or facility to be responsible for the hazardous waste someone else generates at that location. In this case, the facility should differentiate the address for the leased (or sold) space from the rest of the facility, and a different ID number obtained for the leased portion of the facility.
Does PA allow 'satellite accumulation'?
Yes. PA follows the federal guidelines for satellite accumulation. The satellite accumulation point must be at or near the point of generation and must be under control of the operator.
Can I accumulate more than one waste at a satellite location and what is the maximum amount that I can accumulate?
Yes, more than one waste may be accumulated at a satellite location. A total of 55 gallons of hazardous waste may be accumulated at a satellite location, not 55 gallons of each waste. In no instance may more than 55 gallons be accumulated at a satellite location. E.G. if three wastes are accumulated at a location, the total volume of the three wastes accumulated at the satellite location cannot exceed 55 gallons.
Does PA require any special license to transport hazardous waste in the state?
Yes, a Hazardous Waste Transporter license must be obtained from the DEP if hazardous waste is picked up or delivered to PA. A PA hazardous waste permit is not required if only passing through the state.
How do I obtain a PA Hazardous Waste Transporter license?
An application may be downloaded from the Hazardous Waste Management web page at
Hazardous Waste Transporter License Application
When applying for a Hazardous Waste Transporter License, can I submit a surety bond?
No, surety bonds are not acceptable for Transporter license.
If I am a very small quantity generator can I transport my own hazardous waste in PA without a Hazardous Waste Transporter license?
A very small quantity generator (VSQG) may transport their own waste in PA for treatment storage or disposal without obtaining a formal PA Hazardous Waste Transporter license through a license by rule process found in the regulations. Large Quantity Generators (>2200 pounds of hazardous waste per month) and Small Quantity Generators (>220 but <2200 pounds of hazardous waste per month) must obtain their own hazardous waste transporter license or hire an already-licensed PA hazardous waste transporter.
I am a very small quantity generator, do I have to use a manifest to ship hazardous waste in PA?
The regulations do not require a VSQG to use a manifest, however, most treatment, storage or disposal facilities require a manifest before accepting hazardous waste for management.
What is permit-by-rule?
The term "permit-by-rule" refers to the mechanism whereby the owners or operators of certain types of facilities, which are required to have a permit from the Department, are deemed to have a permit without proceeding through the entire permitting process. In general, permit-by-rule facilities pose little or no threat to public health or the environment. Qualification for and retention of permit-by-rule status is contingent upon the operator's compliance with the applicable provisions of the regulations. The Department may require the owner or operator of a permit-by-rule facility to obtain a written permit when the facility is not in compliance with the applicable provisions of the regulations or is engaged in an activity that harms or presents a threat of harm to public health or the environment.
What types of hazardous waste facilities are eligible to operate under permit-by-rule?
Pennsylvania's hazardous waste regulations identify six general types of hazardous waste treatment facilities that are eligible to operate under permit-by-rule. They are: (1) "elementary neutralization units "; (2) "wastewater treatment units"; (3) treatment in generator accumulation units ("containers", "tanks", or " containment buildings"); (4) battery manufacturing facilities reclaiming spent, lead-acid batteries; (5) treatment onsite, at the site of generation, prior to reclamation at the same site; and (6) treatment of hazardous waste to make it suitable for recovery of economically significant amounts of certain precious metals. Provisions applicable to each of these permit-by-rule types are outlined in 25 Pa. Code § 270a.60 of Pennsylvania's hazardous waste regulations (note that it is also important to check the definitions of certain terms, incorporated by reference from the Federal hazardous waste regulations at 40 CFR § 260.10, such as those italicized and enclosed in quotation marks above).
What do I have to do to operate under a hazardous waste permit-by-rule?
A notification must be submitted to the appropriate DEP Regional Office on a form provided by the Department.
Click here to get a copy of the form. Compliance with the regulatory provisions applicable to the specific type of permit-by-rule is necessary to qualify and retain the permit-by-rule.
What type of treatment in hazardous waste generator accumulation units is eligible to be performed under permit-by-rule?
Generally, any treatment for which the regulatory standards applicable to the particular generator accumulation unit (container, tank, or containment building) are designed to protect human health and the environment may be performed under this permit-by-rule. Other types of treatment for which specific standards have otherwise been developed (i.e. thermal treatment, incineration, etc.) are not eligible to be performed in generator accumulation units. Permit-by-rule treatment must be performed within the applicable generator accumulation period (generally 90 or 180 days after the waste has been generated).
Has Pennsylvania adopted the Federal Solvent-Contaminated Wipes Rule?
The Federal Solvent-Contaminated Wipes Final Rule was published on July 31, 2013, and became effective January 30, 2014. Pennsylvania incorporates this rule by reference at 25 Pa. Code § 260a.3 (e ), so this rule is now effective in Pennsylvania.
Highlights of the solvent-contaminated wipe rule include:
- A definition of "wipe" at 40 CFR § 260.10 stating that the term means a woven or non-woven shop towel, rag, pad, or swab made of wood pulp, fabric, cotton, polyester blends, or other material.
- A definition of "solvent-contaminated wipe" at 40 CFR § 260.10 establishing that the term refers to a wipe that, after use or after cleaning up a spill, either: 1) contains one or more F001 – F005 solvent or the corresponding P- or U-listed solvent; 2) exhibits a hazardous characteristic when that characteristic results from a listed solvent; or 3) exhibits only the hazardous characteristic of ignitability due to the presence of one or more non-listed solvents.
- A definition of "No free liquids" at 40 CFR § 260.10 establishing that, in the context of the solvent-contaminated wipe provisions, "no free liquids" means that wipes may not contain free liquids as determined by the SW-846 Paint Filters Liquids Test and that there is no free liquid in the container holding the wipes.
- Adds a conditional exclusion from classification as solid waste at 40 CFR § 261.4(a)(26) for solvent-contaminated wipes that are sent for cleaning and reuse (note that these wipes will not be further subject to Pennsylvania residual or municipal waste regulations since the only hazardous waste exclusions and exemptions subject to further solid waste regulation in Pennsylvania are those at 40 CFR § 260.2 [see 25 Pa. Code § 260a.2]). Conditions which must be met in order to be eligible for this solid waste exclusion include:
- When accumulated, stored, and transported, the wipes must be contained in non-leaking, closed containers that are labeled "Excluded Solvent-Contaminated Wipes" (more detail regarding the term "closed" is in the rule at 261.4(a)(26)(i));
- Wipes may be accumulated by the generator for up to 180 days from the accumulation start date prior to being sent for cleaning;
- At the point of being sent for cleaning on-site or at the point of being transported off-site for cleaning, the wipes must contain "no free liquids" as defined at 40 CFR § 260.10;
- Free liquids removed from the wipes or the container holding the wipes must be managed according to applicable regulations;
- Generators must maintain documentation regarding the receiving laundry or dry cleaner, documentation demonstrating that the 180 day accumulation time limit is being met, and documentation describing the process used to ensure the wipes contain no free liquids; and
- Wipes must be sent to a laundry or dry cleaner whose discharge, if any, is regulated under NPDES or pretreatment water program provisions.
- Adds a conditional exclusion from classification as hazardous waste at 40 CFR § 261.4(b)(18) for solvent-contaminated wipes that are sent for disposal (note that these wipes will be further subject to Pennsylvania residual or municipal waste regulations since the exclusion is only from classification as hazardous waste and not from classification as solid waste). This hazardous waste exclusion is NOT available for wipes that are hazardous due to the presence of trichloroethylene. Conditions which must be met in order to be eligible for this hazardous waste exclusion include:
- When accumulated, stored, and transported, the wipes must be contained in non-leaking, closed containers that are labeled "Excluded Solvent-Contaminated Wipes" (more detail regarding the term "closed" is in the rule at 261.4(b)(18)(i));
- Wipes may be accumulated by the generator for up to 180 days from the accumulation start date prior to being sent for disposal;
- At the point of being transported for disposal, the wipes the wipes must contain "no free liquids" as defined at 40 CFR § 260.10;
- Free liquids removed from the wipes or the container holding the wipes must be managed according to applicable regulations;
- Generators must maintain documentation regarding the receiving landfill or combustor, documentation demonstrating that the 180 day accumulation time limit is being met, and documentation describing the process used to ensure the wipes contain no free liquids; and
- Wipes must be sent for disposal at a regulated solid or hazardous waste landfill, to a regulated municipal waste or other combustion facility, to a regulated hazardous waste combustion facility, or to a regulated hazardous waste boiler or industrial furnace.
For additional information regarding the rule refer to the
US EPA Solvent-Contaminated Wipes Rulemaking web page.
When will the Final Rule: Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine go into effect in Pennsylvania, and who do these rules apply to?
The final rule will be found under
40 CFR Part 266, Subpart P, which Pennsylvania incorporates by reference under
Title 25 Pa. Code § 260a.3, will become effective on August 21, 2019, six months after the rule was published in the Federal Register.
Under the final rule,
health care facilities and
reverse distributors that generate and manage
hazardous waste pharmaceuticals will follow these sector-specific standards for managing hazardous waste pharmaceuticals, instead of the industry-oriented hazardous waste generator regulations.
Additionally, health care facilities and reverse distributors that generate or manage, FDA-approved over-the-counter nicotine replacement therapy (i.e., patches, gum and lozenges) waste will no longer be subject to the P075 listing for nicotine under this final rule.
(Note: The Final Rule includes a prohibition on sewering hazardous waste pharmaceuticals that will apply to all reverse distributors and all healthcare facilities, including VSQGs.)
Please refer to EPA's webpage titled "Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine", which includes an informative webinar, for further information and resources in managing hazardous waste pharmaceuticals.