All of our restoration waste can just be tossed into a dumpster, right?

Well, unfortunately no. Our industry has job scopes that vary greatly from the usual construction or demolition jobsites and our wastes vary just as much!

In my article, How Restoration Companies Can Properly and Safely Extract Wastewater, I mentioned one of the ways to get inspected and cited by regulators was putting hazardous waste in a dumpster or have a dumpster flagged at a landfill. For this article, I’m going to expand on that topic, explain the variety of restoration jobsite wastes and give recommendations on how to manage those wastes. 

For simplicity’s sake, I’m going to break restoration jobsite waste into 5 basic categories:

• General Construction Waste
• Recyclables
• Universal Waste
• Hazardous Waste
• Medical Waste 

Note: Like many OSHA and EPA topics, state-by-state differences exist due to the differences in Federal and State programs. I recommend you check with the environmental department in your state for waste disposal guidance in your specific location. Another good guidance resource is a local licensed waste transport and disposal company.

General Construction Waste

The EPA uses the term Construction and Demolition Waste for this category. None of the materials in this category pose a hazard to humans or the environment. Common materials include the following. ⁽¹⁾

• Wood
• Drywall and Plaster
• Flooring/Carpet
• Furniture
• Steel and other Metals
• Plastic
• Brick and Tile
• Concrete

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To be clear, the assumption with these materials is that a local Asbestos Inspector has already evaluated and sampled the materials, had them analyzed for asbestos and results have cleared the materials for asbestos content. Examples of suspect materials in this category include mastics on wood or flooring, drywall ‘mud’, wall/ceiling surfacing and plaster.

Once clear for asbestos, these materials can go into a general construction dumpster that goes to a local landfill.

Recyclables

This category is constantly changing since technologies are constantly evolving that allow recycling of materials that previously went to a landfill or were specially processed. Your specific work location may not have many recycling options, while others may have reduced cost for disposal/recycling or some materials may even have some value (e.g. salvage value for metals). Finally, some of these materials may not be allowed into a landfill. Let me provide some examples.

Steel and other Metals: most areas of the country will have an option for recycling metal and pay a salvage value. You will need to find a vendor who specializes in this.

Concrete: like metal, most areas of the country have an option for recycling concrete. Depending on the job scope, the recycled concrete could even be used by a contractor for reconstruction (e.g. crushing and reuse as a base or in a new concrete pour). Look for recyclers in your area to see what your options are. 

Oil & Oil Filters: Occasionally Restorers will have a need to dispose of oil and/or oil filters. Examples include severely damaged automotive dealerships, parts stores, and repair facilities. The EPA has specific federal regulations for oil ⁽²⁾ and your state may have additional requirements. However, depending on the volumes and types of oil, there may be a value to the oil.

Start by separating oil and oil filters from the general waste at the jobsite and check to see what local services are available. Do not dispose of these materials in a dumpster with general construction wastes! 

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Batteries Most areas of the country allow disposal of small alkaline batteries into general waste; however, you will need to verify that with your State/County/City environmental department. Most other batteries – including rechargeable, lithium and automotive batteries – will not be allowed in a dumpster. I have provided a link to the State of Florida’s Battery Main Page in the References section of this article to give an example of how some states break down the management of batteries. ⁽³⁾ Additionally, most recycling companies will have a program for battery disposal; check for a local company that can handle these materials.

Universal Waste

This is a specialty category that most people are not familiar with. However, these items are an easy target for an inspector looking in a dumpster. The EPA describes universal waste as certain categories of hazardous waste with regulations that are less burdensome to dispose of and reduce the quantities of these materials going into landfills. Five types of universal waste and information about them are included below. ⁽⁴⁾

• Batteries: as previously mentioned, some batteries are allowed in general waste, some can be recycled and others will be considered universal waste. Contact your local environmental department or waste disposal contractor to understand the specifics for your area.
• Pesticides: contact your local environmental department or waste disposal contractor to understand the specifics for your area.
• Mercury-containing items: the most common example of these items are the older thermostats (i.e. not electronic or digital) that have a mercury switch inside them. Contact your local waste disposal contractor for containers and disposal options.
• Lamps/Bulbs: common examples of these include fluorescent, HID, neon, mercury vapor, high pressure sodium and metal halide. Contact your local waste disposal contractor for containers and disposal options.
• Aerosol Cans: different options exist for aerosol cans, depending on whether they are still pressurized or meet the EPA definition of empty. Contact your local waste disposal contractor for containers and disposal options. 

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Relaxed regulations for universal waste, as compared to hazardous waste, allow longer storage periods prior to disposal and shipment without a manifest. Generally speaking, you should contact a local vendor who can dispose of universal waste; they can provide you with storage containers and specific information on management and disposal.

Hazardous Waste

The EPA’s simple definition for hazardous waste is a waste with properties that make is dangerous or capable of a harmful effect on humans or the environment. ⁽⁵⁾ This is a very, very broad category; however, for Restorers this generally includes:

• Cleaners: this category can vary from harmless to harmful. The ingredients are a key piece of information and many times the SDS provides that. If in doubt, have a waste disposal contractor review the SDS and advise you on disposal needs.
• Medications: strong medications getting into landfills or in the hands of the wrong people are an obvious concern. Again, given the potential harm of the medication, consult a waste disposal contractor for disposal needs. Better yet, if you can leave the medication with the owner, that is a better solution.
• Ammunition & Flares: these items have contents that can be a fire and/or explosion hazard. The handling and disposal are critical to avoid a dangerous reaction. Consult with a waste disposal contractor for handling precautions and disposal needs.
• Automotive products: just like cleaners, the ingredients of these products are key to how they should be handled and disposed of. The SDS will provide much of that information. Work with a local waste disposal contractor to determine the proper disposal.

Medical/Biohazard Waste

Restorers can encounter wastes that I generically describe as medical waste. Examples include:

• Bagged waste and materials encountered in doctor’s offices, dental offices and hospitals.
• Used medical instruments and tools in the above offices/buildings.
• Wastes generated while performing crime or trauma scene cleanup. 

These wastes all go into red waste bags; however, the similarity can end there. The Restorer should be aware of regulatory requirements for their state, county or city. Licensing and certification for labeling, handling, transport, and disposal of these wastes can vary. Generally speaking, contacting the Environmental or Health Department should get you specific information on managing the waste.

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Handling and Management Considerations

Finally, there are some additional considerations a Restorer should be aware of. A licensed and accredited waste disposal company can help you through the additional layers of details. Here are a few considerations:

• Quantities matter: companies that generate waste can be significantly impacted by a large disposal event after a disaster. Be sure to speak with the client or the local environmental regulator prior to arranging a large-scale disposal event of any wastes other than construction and demolition materials.
• Storage times matter: the EPA has rules on how long certain wastes can be stored. Prior to moving waste into an area for storage, talk to the client or local environmental regulator to see if there are limitations to how long the waste is stored.
• Containers and Labels matter: different wastes have different requirements for their storage container (e.g. plastic, steel, or cardboard drums) and their labeling requirements. This in one of the easiest ways to be cited for regulatory infractions; be sure to consult with a regulator or waste disposal contractor for the container and label requirements.
• Signatures matter: hazardous waste manifests have very specific requirements and liabilities for those signing the document. ⁽⁶⁾ For instance, training is required, you are certifying the accuracy of the information, and possibly the most important – the company whose employee signed the manifest may become liable for incorrect handling and disposal of the waste. (Even if the waste technically is not theirs!)

Summary

As you can see, the 5 basic waste categories I reviewed have clear applicability to restoration work. The requirements for handling and disposal of some of the waste is clear and straightforward. However, other wastes have complicated requirements and significant penalties for incorrect handling, management and disposal. I strongly recommend Restorers seek basic training and establish standard procedures to assure a clear understanding that all wastes do not go into the dumpster! 

Resources

United States Environmental Protection Agency, Frequent Questions About Universal Waste. https://www.epa.gov/hw/frequent-questions-about-universal-waste

United States Environmental Protection Agency, State Universal Waste Programs in the United States. https://www.epa.gov/hw/state-universal-waste-programs-united-states 

References

1. United States Environmental Protection Agency, Construction and Demolition Debris: Material-Specific Data. https://www.epa.gov/facts-and-figures-about-materials-waste-and-recycling/construction-and-demolition-debris-material
2. United States Environmental Protection Agency, Managing, Reusing, and Recycling Used Oil. https://www.epa.gov/recycle/managing-reusing-and-recycling-used-oil
3. Florida Department of Environmental Protection, Division of Waste disposal, Permitting and Compliance Assistance Program, Battery Main Page. https://floridadep.gov/waste/permitting-compliance-assistance/content/battery-main-page
4. United States Environmental Protection Agency, Universal Waste, Overview of Universal Waste Program. https://www.epa.gov/hw/universal-waste
5. United States Environmental Protection Agency, Hazardous Waste Home, Learn the Basics of Hazardous Waste. https://www.epa.gov/hw/learn-basics-hazardous-waste#:~:text=Simply%20defined%2C%20a%20hazardous%20waste,human%20health%20or%20the%20environment.
6. Stericycle, Hazardous Waste Manifest Guide, June 24, 2022. https://www.stericycle.com/en-us/resource-center/info-sheet/hazardous-waste-manifest-guide