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Alternate Waste Container Types for CAAs and SAAs


Alternate Waste Container Types for CAAs and SAAsIn talking about closed container guidelines in central and satellite accumulation areas we have been sticking with drums as the primary container type.  Since drums are not the only option though, today we will cover some other container types you could use in CAAs or SAAs and what constitutes them as closed. 

Other container types applicable to storage in CAAs and SAAs include “bags, durable sacks made of woven synthetic material (polysacks), boxes, twenty cubic yard roll-off boxes or containers, one cube yard heavy duty cardboard boxes with a plastic liner (Gaylord boxes), semi-trailers used to manage solid and semi-solid hazardous wastes, and stainless steel and plastic totes in wire cages to handle liquid hazardous wastes.”  Each option has a different method for closing. 

Generally speaking, the EPA considers these types of containers “closed” when they are sealed to the extent that hazardous wastes and emissions will be kept inside the container.  They use the example of wet paint filters accumulated in bags.  “A bag containing dry paint filters may be considered closed when the neck of the bag is tightly bound. However, a bag containing solvent laden wet paint filters would generally not be an acceptable container unless the bag was double lined and the bag could be sealed sufficiently to prevent leaks and emissions.”

Roll-off containers may also be used to hold waste in accumulation areas.  According to the EPA, “Large roll-off containers, such as 10 by 20 foot containers, are often used for the accumulation of large volume waste streams, such as F006 sludges from electroplating operations and inorganic wastes where volatility is not an issue.”  There are some roll-off containers that are made with lids that open and close.  In the case of such containers it would be considered closed when the lid is shut and has a good seal around the rim.

The EPA notes that, “From an operational and practical standpoint, these types of containers are generally located inside the facility where a roof or ceiling and walls protect the container from outside elements. Once the containers are completely full, [they] may be covered with tarps and moved outside to a staging area for subsequent management…EPA generally views these situations as both practical and sufficient to meet compliance with 40 CFR 265.173(a).”

If, however, a roll-off container is kept outdoors while receiving waste it is important that generators keep tarps closed when not adding or removing waste to ensure no condensation can enter the container.  The EPA warns that even a small amount of water can be enough to leach hazardous constituents from the waste that could leak out of the roll off.

Roll-off containers holding wastes that contain volatile organic compounds (VOCs) are subject to even stricter requirements.  The EPA dictates that, “if a roll-off container is not in light material service then use of a tarp with no visible holes or gaps or open spaces (e.g., a cover and closure device that forms a continuous barrier over the container) is an example of a suitable Level 1 control device. However, use of tarps in this instance is also subject to 40 CFR 264.1086(c)(2) for permitted units and 40 CFR 165.1087(c)(2) for LQGs, which requires closure suitable to weather conditions, including exposure to wind, moisture and sunlight.

If the roll-off container is in light material service, then Level 2 controls are required under Subpart CC. Examples of container loading procedures that meet Level 2 controls include using a submerged-fill pipe or other submerged-fill method to load liquids into the container or a vapor-balancing system or a vapor­ recovery system to collect and control the vapors displaced from the container during filling operations.  The use of a tarp would not be an acceptable Level 2 control device.”


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.  

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RCRA Comparable Fuels Exclusion

Written by: Angie Martin, PE CHMM & Jim Brossman, Senior Consultant

RCRA Comparable Fuels ExclusionAccording to the EPA, “"On June 27, 2014, the United States Court of Appeals vacated the ‘Comparable Fuels Rule’, which provided an exclusion from RCRA hazardous waste regulations for certain fuels derived from hazardous waste. EPA, recognizing the potential impact of this decision, has filed a motion with the court requesting a 30-day delay in the effective date of the decision (currently scheduled for August 11, 2014, absent petitions for appeal or rehearing) in order to gather information to help plan for orderly transition consistent with the opinion. At the end of that time, EPA may seek a further stay of the mandate if it determines that additional time is necessary for facilities to come into compliance with the applicable requirements." 

Update: On August 7, 2014, the court granted a stay of the mandate through September 17, 2014.

We expect to see a notice in the Federal Register very soon withdrawing the rule (40 CFR 261.4(a)(16) and 261.38).  States are expected to follow so as not to be less stringent than the federal government.  Generators using this exemption will need to do a proper waste determination on wastes and possibly will need to ship wastes that were being burned onsite to an off-site Resource Conservation and Recovery Act (RCRA) permitted facility (TSD) -- presumably incinerator or supplemental fuel/cement kiln.


What was the Comparable Fuels Exemption?

The comparable fuels exclusion was an exemption only available for liquids that met the comparable fuels specifications for BTU value, viscosity and maximum hazardous constituent concentration. Materials that met the specifications would not be solid wastes (and therefore not hazardous wastes) if burned in an industrial furnace, utility boiler or hazardous waste incinerator.

The types of materials EPA thought would meet the terms of the exclusion included alcohols, oils and other organic liquid wastes. In addition to BTU and viscosity requirements, there were hazardous constituent concentration limits for over 200 compounds included in the exclusion. The standard for most of these constituents was non-detection.

Due to the low specifications, and restrictions on blending to meet most specifications, the types of facilities that claimed the exemption were usually pharmaceutical manufacturers or other facilities that generated large volumes of lightly contaminated spent solvents which they typically wanted to burn in an on-site boiler.  Although it was self-implementing, general market knowledge indicated that few facilities attempted to qualify for this exclusion due to the low constituent standards and the analytical burden required to demonstrate compliance. 


Does this affect other fuel type exclusions?

No.  Fuel-for-fuel and Used Oil exclusions are still in effect as before.

This decision does not appear to impact the reclamation and re-use of off-specification fuels since those materials are not solid wastes (or hazardous wastes) when destined for recovery and re-use as fuel.


What does this mean for generators? 

If you are a generator who has been using this exemption, it may be time to consider performing a new proper waste determination and a review of your disposal arrangements.  Be sure to include a review of compliance concerns regarding tanks that were product tanks becoming waste accumulation tanks.  Don’t hesitate to seek environmental compliance help if you are unsure of the specific implications for your materials and facilities.  


For further information on this subject visit the EPA's webpage on the Comparable Fuels Rule


If you believe that you may be using this exemption, Heritage can assist you in making a proper waste determination, disposal arrangements, as well as compliance consulting regarding a potential change in generator status or tanks that were product tanks becoming waste accumulation tanks.  Contact a Heritage Representative today

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Closed Container Guidelines in SAAs: Part 2


Closed Container Guidelines in SAAs Part 2Last week we covered closed container guidelines for containers holding liquid hazardous waste in satellite accumulation areas.  To remind you, satellite accumulation areas (SAAs) differ from central accumulation areas (CAAs) because they are an area in a facility where waste is generated and accumulated in a container as opposed to an area where waste is stored after being generated. 

40 CFR 262.34(c)(1) and (c)(2) set forth the requirements for generators that accumulate hazardous waste in an SAA, including the requirement that the generator must accumulate the waste in a container that is “closed” except when adding or removing waste.

For a reminder on the guidelines for containers holding liquid hazardous wastes please see last week’s post here.  Today we will be covering the recommendations for keeping closed containers collecting solid and semi-solid hazardous wastes in satellite accumulation areas.  This can include wastes such as filters, used PPE, and “dewatered metal-bearing wastes or sludges.” 

In the case of containers collecting these types of waste, the EPA considers a container closed “as long as there is complete contact between the lid and the rim all around the top of the container.”  Ensuring this contact between lid and rim minimizes the risk of air emissions being released into the environment.  

According to the EPA, “when [a] container is full, or…must be moved or transported, the lid can be secured by bolting the band that seals the lid to the container or with a band that is tightened with a lever.”

Some SAA containers, for example those under a baghouse or filter press, which are continuously or sporadically receiving hazardous waste often stay open while connected to the device.  According to the EPA, “in these situations, the containers should be capable of catching and retaining all of the material during transfer from a device to the container in order to avoid spills or releases.”

Another appropriate container option for solid or semi-solid hazardous wastes would be a container with a foot pedal operated cover.  These come in several varieties including flip-top, self-closing swinging door, and spring loaded lid.  The EPA considers them closed when the cover makes complete contact between the rim and the lid all the way around the top.  The EPA cautions that “generators should be aware that the seals on containers can erode because of time and use, and should be checked periodically for wear and replaced if necessary.”


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

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Closed Container Guidelines in SAAs: Part 1


Closed Container Guidelines in SAAsEarlier this week we discussed the guidelines for closed containers in central accumulation areas (CAAs).  If you’ll remember, the purpose of these guidelines is to prevent spills and minimize emissions from volatile wastes.  Today we are going to talk about what guidelines exist for containers in satellite accumulation areas or SAAs.  In particular, we will be covering the closed container guidelines for containers accumulating liquid hazardous wastes in SAAs.  Containers containing solid and semi-solid wastes will be covered in a later post.

Unlike CAAs (where waste is often stored after the fact) SAAs are locations in a facility where waste is generated and accumulates in a container.  40 CFR 262.34(c)(1) and (c)(2) set forth the requirements for generators that accumulate hazardous waste in an SAA, including the requirement that the generator must accumulate the waste in a container that is “closed” except when adding or removing waste. 

The situation that raises the most questions about closed containers is management of liquid hazardous wastes or free liquids.  This includes items like spent organic solvents.  These waste accumulations bring up the most questions because so many generators use liquid solvents in their production or manufacturing processes.

The three primary risks associated with liquid hazardous wastes accumulated in containers are risks from inhalation, risk of potential buildup of vapors in the container, and risk of an accidental spill of material.  Since the purpose of the closed container guidelines is to minimize emissions and avoid spills, ignitions, or mixing of wastes it is imperative that generators have systems in place to keep containers closed and to prevent leaks or ruptures.

Generally, a container collecting liquid hazardous wastes in an SAA is “closed” when “all lids are properly and securely affixed to the container, except when wastes are actually being added to or removed from the container.”  The reasoning behind making sure the lid is totally covering the container is to prevent any volatile emissions from being released and to prevent a spill in the chance case that a container is tipped over. 

The EPA recognizes that the frequency with which materials may be added to or removed from a container makes securing lids with snap rings, securely capping bungholes, and / or fastening the lid on by other means inconvenient.  That said it is still important that the container is covered tightly.  They provide the following advice:

“We believe containers holding free liquids, or liquid hazardous waste, in the SAA would meet the regulatory definition of "closed" through a variety of approaches. For example, special funnels with manually or spring closed lids or other similar closing devices could be used for closed-head drums or closed-top drums (e.g., containers that have two bung holes with non-removable lids).

Similarly, funnels used to add or remove liquid hazardous wastes from these containers would be screwed tightly into the bunghole and fitted with a gasket, if necessary, to seal the funnel lid firmly closed. In some cases, the funnel lids for closed-head drums and closed­ top drums may be fitted with a locking mechanism. This keeps the lid in a closed position. All other openings on the drum lid should generally be properly closed or capped.

Another alternative is the use of a funnel with a one-way valve that allows hazardous waste to enter the container, but prohibits the waste or emissions from exiting the container… Liquid hazardous wastes also can be accumulated in open-head drums or open-top containers (e.g., where the entire lid is removable and typically secured with a ring and bolts or a snap ring) and meet the definition of "closed," provided the rings are clamped or bolted to the container. 

In some situations, the container could be considered closed if the lid covers the container top securely even though the rings are not clamped or bolted.   Several states take this approach, and EPA believes it reflects a reasonable interpretation of the regulations.” 


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

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Closed Container Guidelines in CAAs

CAA ContainersIf you remember, last week we gave a brief introduction to Closed Container Guidelines.  These guidelines were created in order to address continued confusion in the hazardous waste generator community concerning what constitutes a container as closed.  According to the EPA, “the existing federal RCRA Subtitle C container regulations do not define ‘closed container.’”  Because of this many states have promulgated their own regulations.  That being said, while this post will help you with the federal suggestions it is imperative that you check with your state government concerning any regulations. 

The individual state guidance combined with feedback from the Office of Enforcement and Compliance Assistance (OECA), EPA regions, and comments from the 2004 Advanced Notice of Proposed Rulemaking (ANPRM) were used to create these guidelines. 

These guidelines in combination with any state regulations aim to address the goal set forth in the original 1980 preamble, to prevent spills and minimize emissions from volatile wastes.  The guidance focuses on two separate parts; containers of waste in central accumulation areas (CAAs) and containers of waste in satellite accumulation areas (SAAs).  Today we will be covering the regulations for containers in CAA’s.    

Once a hazardous waste has been generated from plant processes (including the accumulated hazardous waste from SAA’s) they are sent to the CAA.  According to the EPA, “a CAA is a location where hazardous waste containers are kept according to the generator accumulation requirements at 40 CFR 262.34(a) and 40 CFR 262.34(d) without a facility having to obtain a RCRA storage permit or having interim status.”  CAAs are located either outdoors within a facility boundary or inside but away from production operations.  Regulations require that containers in CAA’s must be closed unless waste is being added to or removed from them.  Additionally, they must be stored and handled in a way that ensures they will not rupture or leak.

The EPA points out that containers storing wastes that are subject to Subpart CC regulations are significantly more detailed due to concerns about volatile organic compounds (VOCs) and their potential release into the atmosphere.  For standard 55 gallon drums, however, the EPA suggests the following: “a container [should] be properly secured with snap rings tightly bolted, bungholes capped, and, where appropriate, pressure-vacuum relief valves to maintain the containers internal pressure and avoid explosions.”

While these are only federal guidelines and not explicit rules it is still best to practice them.  Doing so can help you to ensure compliance and avoid a spill situation.  Keep checking the blog for further information on closed containers in SAAs, spill prevention, and more.


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.   

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10 Tips for Reusing Paper Bags


10 Tips for Reusing Paper BagsWhile it’s preferable to always use reusable shopping bags sometimes it’s not an option.  I know every so often I’m in the store doing my grocery shopping when I realize that my bags are still at home on the dining room table.  If you find yourself in this situation you’ll probably be given the option of paper or plastic when you get to the checkout.  If you choose paper, you could benefit from some of the ideas below. 

1. Cover your child’s schoolbooks.  I know when I was in high school many of our teachers required that our textbooks be covered to protect them.  Instead of spending money on a cover just use a paper bag.  Once you’ve got it covered your child can decorate their book with stamps, stickers, paint, or anything else that suits them.  If you’re unsure how to go about covering the book, check out this step-by-step tutorial from Instructables.   

2. Wrap gifts.  Much like covering school books, gifts can be wrapped in brown bags.  Just flatten out the bag and wrap with the non-printed side out.  You can then decorate with paint, ribbon, etc.

3. Remove spilled wax from a tablecloth.  ChasingGreen provides this brilliant idea.  “To clean up candle wax stains from your tablecloth or carpet, simply spread out an opened paper bag and move a warm iron quickly back and forth over the spot. This will effectively soak up the grease and lift out any trace of the stain.”

4. Keep your produce fresh.  Some items, mushrooms and onions in particular, can be kept fresher longer by putting them in a paper bag and storing them on the lowest shelf of your refrigerator. 

5. Ripen up your produce.  Interestingly enough, paper bags can also be used to help ripen some things.  Peaches, avocados, pears, or tomatoes can all be placed in a paper bag on your countertop to help them ripen faster.  The paper bag helps to hold in the ripening gasses and keeping them at room temperature ensures that you won’t stunt the ripening process. 

6. Separate trash and recycling in your vehicle.  If you’re like me you tend to accumulate a lot of trash in your car.  Since people tend to dispose of this trash at gas stations (where there is generally not a recycling option) use two separate paper bags to collect waste.  That way you can throw what you need to in the trash while saving bottles and cans for the recycling.

7.  Make large drawing canvasses for your kids.  There is nothing better than having a giant piece of paper to draw on.  Make one for your kids by cutting down the seams on a paper bag and flattening it out.  They’ll have a huge drawing space and you’ll have at least 10 minutes of them being distracted!

8. Collect your paper recycling in it.  This will make recycling your paper that much easier since you’ll be able to toss the whole thing in the bin. 

9. Peel potatoes into a bag.  Once you’ve got all your peels collected into the bag you can take the whole thing to your compost pile. 

10.  Cut paper bags into strips and use them for packing.  Instead of using something like foam peanuts or plastic bubble wrap just cut paper bags into long strips that can be stuffed around fragile items in your boxes.  Once you’ve moved you can use the strips for composting or recycling. 


What do you think?  Do you have other ways that you reuse paper bags?  We’d love to hear them!  

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An Introduction to Closed Container Guidance


An Introduction to Closed Container GuidanceIn December of 2009 the EPA issued guidance for both Large Quantity and Small Quantity Generators concerning how to decide when a container is “closed.”  The guidance is pertinent whether waste is being accumulated in central accumulation areas (CAA) or satellite accumulation areas (SAA) or at RCRA permitted interim facilities.  Today we will be providing an overview of this EPA guidance but keep reading in coming weeks for more in-depth looks at guidelines for specific storage areas and container types. 

To begin we need to understand that the EPA defines a container as “any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.”  The regulations in 40 CFR 265 require containers that are holding hazardous waste to be closed during storage and open only when adding or removing waste.  Additionally, it stipulates that containers must not be opened, stored, or handled in a way that would cause the container to rupture or leak.

Typically, like in the case of 55 gallon drums, the EPA recommends that a container cover is, “properly secured with snap rings tightly bolted, bungholes capped, and, where appropriate, pressure-vacuum relief valves to maintain the containers internal pressure and avoid explosions.” 

A container accumulating free liquids or liquid hazardous waste is considered closed when all openings or lids are properly and securely affixed to the container unless waste is being added or removed from said container.  A container holding solid or semi-solid hazardous wastes is closed when, “there is complete contact between the lid and the rim all around the top of the container.”  Generally speaking, the EPA considers a container closed when it is, “sealed to the extent necessary to keep the hazardous waste and associated air emissions inside the container.”

The reasoning behind the closed container guidelines is explained in the preamble to the final rule created in 1980.  It states:

“…Its purpose is, as it was originally, to minimize emissions of volatile wastes, to help protect ignitable or reactive wastes from sources of ignition or reaction, to help prevent spills, and to reduce the potential for mixing of incompatible wastes and direct contact of facility personnel with waste.  While many commenters argued and the Agency agrees that storage may properly be conducted in open tanks and surface impoundments, requiring containers to be kept closed does not unnecessarily restrict storage options.  All containers have lids or some other closure device, and keeping containers closed whenever possible is simply a matter of good operating practice. It is not expected that containers of hazardous waste need be opened routinely to inspect the waste or the container for reasons other than to add or remove waste."

What this means is that you can view container regulations as akin to performance standards intended to minimize the risk for potential spills, leaks, or air emissions.  So remember to keep your containers closed.  If you have tips or strategies let us know in the comments!


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA Memorandum on Closed Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.   

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50 Ways to Go Green!


In looking back at responses to our previous posts, it bcame clear that what many readers find most helpful are lists of several ideas for how they can make a “green” impact.  We’ve done several posts that are “10 things you can do” or “8 tips you can try” but this time we’re going big with a list of 50 ways you can save energy, help the environment, and decrease your personal carbon footprint.  So without further ado we present our list of: 

50 Ways to Go Green1.  Take public transportation.

2.  Stay away from chemical cleaners when you can.

3.  Buy local.

4.  Turn off the lights when you leave a room.

5.  Layer up in the winter.

6.  Wear loose airy clothes in the summer.

7.  Ditch the paper towels and use washable instead.

8.  Buy recycled paper.

9.  Separate your recyclables at home.

10.  Start an office recycling program at your work.

11. Avoid overly packaged foods.

12.  Buy in bulk to cut down on the packaging waste you incur.   

13.  Pass green knowledge on to the next generation; your kids, your neighbors kids, etc.

14.  Start a compost heap.

15.  Get involved in urban gardening if you live in a city.

16.  Plant your own garden if you have the space.

17.  Shorten your showers.

18.  Switch to LED or CFL light bulbs around your home or office.

19.  Participate in HHW days to make sure old chemicals are disposed of properly.

20.  Print on both sides of the paper.

21.  Reuse items whenever possible.

22.  Unplug appliances and chargers when you’re not using them.

23.  Invest in a reusable water bottle.

24.  Do you banking online to cut back on the paper you’re sent.

25.  Pack your lunch instead of buying from a fast food joint, you’ll save waste on the bag and the food wrappers.

26.  Reusable shopping bags; have them in your car at all times so you’ll never be without.

27.  Buy things used when you can.

28.  Plant a tree.

29.  Start upcycling.

30.  Invest in an office plant.

31.  If you’re able use a rake, not a leaf blower.

32.  Use a shovel, not a snow blower.

33.  Buy some solar panels for your home or business.

34.  Get a low-flow showerhead.

35.  Don’t preheat your oven.

36.  Wash your clothes in cold water.

37.  Participate in a work carpool.

38.  Buy upcycled items.

39.  Shop from eco-conscious companies.

40.  Buy a fuel efficient vehicle.

41.  Ride your bike instead of driving your car when you can.

42.  Use a carwash instead of washing your car yourself.  It can save about 50% of the water you use.

43.  Don’t let the water run while brushing your teeth.

44.  Wrap gifts in fabric or old newspaper.

45.  Install a programmable thermostat.

46.  Use your ceiling fans.

47.  Make sure your home is properly insulated.

48.  Stay away from Styrofoam.

49.  Check your air filters.

50.  Spread the word!


So, now that you are armed with a multitude of ideas what will you do to help the planet? 

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What is Waste Minimization?


Waste Minimization PyramidA couple of weeks ago we did a post on how the government is addressing waste minimization.  I have since realized, however, that we never really defined what waste minimization is.  According to the EPA, “Waste Minimization refers to the use of source reduction and/or environmentally sound recycling methods prior to energy recovery, treatment, or disposal of wastes.”  Ergo, treatment of a wastestream does not constitute waste minimization.  The EPA takes this further by clarifying that “compacting, neutralizing, diluting, and incineration are not typically considered waste minimization practices.”  So in the hierarchy of materials management source reduction and recycling come before energy recovery, treatment, or disposal.

What is Source Reduction?

Source reduction (which is also known as pollution prevention or P2) is a practice that reduces or eliminates the creation of wastes at the source.  Additionally, source reduction “refers to any practice that reduces the use of hazardous materials in production processes.”  The EPA lists the following examples of source reduction:

  • “Early retirement of equipment such as mercury-containing devices like switches and thermostats;
  • Reformulating or redesigning products, such as creating new PVC compounds without using lead;
  • Using less toxic feedstocks, such as switching to the use of lead-free solder in manufacturing;
  • Improving work practices, such as reorganizing paint batches in order to reduce cleaning operations.”

How is Recycling Utilized?

While most of us know about recycling from a personal standpoint we probably still can learn about recycling at the manufacturing level.  In most cases recycling is used when source reduction is not seen as practical economically.  In the manufacturing process, “Recycling includes the reuse or recovery of in-process materials or materials generated as by-products that can be processed further on-site or sent offsite to reclaim value. Recycling is a broad term that encompasses the reuse of materials in original or changed forms rather than discarding them as wastes. Recycling can also be thought of as the collection and reprocessing of a resource so it can be used again, though not necessarily for its original purpose.”  The EPA provides a few examples of the types of recycling that can be used for waste minimization:

  • “Direct use/reuse of a waste in a process to make a product, such as reusing a purge product used to clean paint lines rather than disposing of it by incineration.
  • Processing the waste to recover or regenerate a usable product, such as collecting vapor from dry cleaning operations, turning it back into liquid, and reusing the liquid to clean more clothes.
  • Using/reusing waste as a substitute for a commercial product. When mercury is recycled from old equipment like switches, it can be used in new products that still require mercury, such as fluorescent bulbs. Recycling of mercury has been so successful that there is now enough recycled mercury in the U.S. that manufacturers do not need to use new mercury from mines.”

How can Waste Minimization help companies? 

Aside from being good for the environment, waste minimization can help companies on an economic sense by eliminating wasted materials, improving production efficiency, and improving product quality.  Additionally, the EPA states that “reducing waste generation through waste minimization has helped some companies change their RCRA regulatory status from large quantity generator (1000 or more kilograms of hazardous waste generated per month) to small quantity generator (between 100 and 1000 kg of hazardous waste generated per month), or to conditionally exempt small quantity generator (up to 100 kg of hazardous waste generated per month). Some have managed to eliminate the generation of hazardous waste and avoid RCRA regulatory requirements altogether.” 

What do you think about waste minimization?  Does your company have plans and processes in place to achieve waste minimization goals?  Have you seen a good ROI on your efforts?  We’d love to hear about it in the comments section!


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the EPA FAQ Page on Waste Minimization.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

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10 Ways to Reuse Milk Cartons


Reuse Milk CartonsEven living in a single person household I find myself with at least one empty half gallon milk carton a week.  When I was growing up I’m sure my family went through two or three gallons!  So what happens to all those empty cartons?  For many of us they end up in the recycling bin (or worse in the garbage).  If you want to offset that a little you can try some of the ideas we’ve come up with below!

1.  Make a piggy bank.  All you’ll need is some pink paint, a pipe cleaner for the curly tail, construction paper for the ears, pieces of a toilet paper roll for the legs, and maybe some googley eyes and you will be in business!  The cap is your pig’s snout and you can work back from there.  If you have trouble figuring it out, check out this eHow article

2. Make an igloo.  This one will require saving a lot of milk jugs but it can be a really fun project with your kids!  Apartment Therapy has a tutorial over on their site if you’d like to try your hand at milk carton construction.

3. Store your kids craft supplies.  Cut off the tops of some milk cartons (gallon or half gallon) and they become great places to store crayons, pencils, scissors, and more.

4. Make a watering can.  I’ve actually used this idea already this summer.  Once you empty your milk rinse out the container.  Then use a hammer and nail to put holes in the lid.  Fill it with water and you’ve got an upcycled watering can.

5. Rope off part of the lake.  Do you live on a lake that has a steep drop off?  If so you can use some poles, yarn, and milk jugs to mark the line.  Just firmly plant the poles in the soil at the bottom of the lake and use the yarn and empty milk jugs to make a floating line between them.

6. Make a bird feeder.  Simply put a small hole in the cap to run a string through and cut some holes in the body for the birds to be able to access the food.  If you want to give them a place to perch while eating consider using old popsicle sticks.

7. Make a yarn dispenser.  To do this you’ll need to cut the top of the milk container off just enough so a ball of yarn and your hand can fit into the hole. Once the ball of yarn is in take the end of the yarn and bring it through the handle of the milk jug. This is a great way to keep the yarn from getting tangled together!

8. Make a quick lantern.  This can also be used as a Halloween craft idea.  By dropping a glow stick into an empty milk jug you can set the whole thing aglow.  Add spooky faces and different colored glow sticks to make a fun fall craft.

9. Irrigate your plants.  By poking small holes in the bottom of a milk jug and burying it in your garden you can create a little root irrigation system.  Just fill the top with water and it will trickle out as needed.  This can be a lifesaver for your plants if you go away for the weekend.

10.  Store odds and ends in the garage.  If you find yourself with an assortment of nails, nuts, and bolts with no home try storing them in the bottom half of an old milk carton.  This way it won’t matter if they are a little rusty or dusty.


Want more reuse ideas?  Check out some of our previous posts:

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