Are You Properly Managing Your Hotel's Hazardous Waste?

As hotels continue to focus on their sustainability efforts, the importance of proper hazardous waste management cannot be overlooked. The proper management of hazardous waste is crucial to maintaining a hotel's brand reputation, remaining compliant with government regulations and being a good steward to the environment.


By Maricha Ellis, VP of Marketing & Sales Operations, Stericycle Environmental Solutions

Hazardous waste comes in many different forms and appears in many different areas of a hotel's property. From toiletry items left behind in guest rooms to commonly-used cleaning products, there is no shortage of hazardous waste accumulated in a hotel. There are many best practices to follow when handling hazardous waste on your property, and a foundational understanding of the regulations defining what constitutes hazardous waste is key to laying the groundwork for a proper hazardous waste management program.

The Fundamentals of Hazardous Waste Management

Certain items commonly found in hotels have hazardous properties. Once an item containing these properties becomes no longer usable, it is deemed to be hazardous waste and must be disposed of in accordance with government-mandated guidelines. Because hotels are considered generators of hazardous waste, there are certain federal and state regulations that must be followed in order to avoid penalties and prevent environmental damage.
Passed by Congress in 1976, the Resource Conservation & Recovery Act (RCRA) states that the generator of hazardous waste is responsible for their waste from the time of generation to the final destruction of the waste. Because the waste is generated at your hotel, you are responsible for identifying and storing it correctly. To ensure hazardous waste management is handled in a safe, efficient and compliant manner, hotels typically employ a service provider to customize a program, training and disposal pick up schedule that best suits the unique needs of their property. Once a hazardous waste management service provider picks up the hazardous waste, that organization assumes the responsibility of the waste and transports it to a treatment facility.
What is Considered Hazardous Waste?
Hazardous waste is a chemical or product that no longer has intended use and possesses substantial or potential threats to public health or the environment. This waste comes in all forms and may be discarded chemical, expired or damaged product, or a spilled product. Some of the typical types of hazardous waste found in hotels include:

✓ cleaning and disinfecting products
✓ toiletries
✓ polishes
✓ office products
✓ universal waste (e.g., light bulbs, fluorescent lamps, batteries, electronic devices)
✓ pesticides and poisons
✓ pool, hot tub and spa chemicals
✓ solvents and aerosols (including air fresheners)
✓ latex and oil-based paints and varnishes
✓ cooling system chemicals
✓ flammables
✓ used oil and oil filters

To be considered hazardous waste, the item must exhibit ignitable, corrosive, reactive and/or toxic characteristics. Ignitable items easily catch fire and have a flash point of less than 140 degrees Fahrenheit or 60 degrees Celsius. This category of hazardous waste also includes items that actively support combustion, such as oxidizers. Some of the products commonly found in hotels containing these properties include:

✓ flammable aerosols
✓ disposable lighters
✓ alcoholic beverages with greater than 24 percent alcohol content
✓ glass cleaners and other cleaning sprays
✓ nail polish and remover
✓ alcohol and alcohol-based products
✓ perfumes and colognes
✓ products containing petroleum distillates (e.g., certain cosmetic, personal care and polish products)
✓ hair spray
✓ cooking spray

Corrosive items easily corrode materials or human tissue. There are two different types of corrosive materials: acidic or alkaline. Acidic materials have a pH of less than 2, while alkaline materials have a pH of greater than 12.5. Many cleaning items found in hotels have corrosive characteristics, and thus are considered hazardous waste.

Reactive waste is unstable under normal conditions and can cause explosion or release toxic fumes when heated or mixed with water. Items containing reactive characteristics are not typically found in a hotel setting.

Toxic items are harmful or fatal when ingested or absorbed. Products such as bug sprays with DEET and rat poison are considered hazardous to the environment, and therefore are considered hazardous waste by the EPA.

In addition to these four categories of federally regulated waste, there are other items that states regulate as hazardous. While not considered hazardous by the EPA, these items follow the same protocol due to state regulations being more stringent than federal regulations. These items can include soaps, shampoo and non-bleach detergents. In addition, items like batteries, light bulbs and electronics are considered universal waste and must be accumulated following the same standards. These items are considered EPA hazardous wastes. Although they have less stringent requirements for management and disposal, these items have regulations specific to universal waste and must not be thrown in the trash.

Identifying and Segregating Hazardous Waste

To determine if a product is considered hazardous waste, you can review a product's safety data sheet (SDS), manufacturer's information, label, ingredients or refer to a hazardous waste materials training poster or guide supplied by your hazardous waste management service provider.
Following proper item bagging guidelines and categorized accumulation bins are critical to safely segregating hazardous waste. Incompatible items must be kept separate when accumulating waste, so it is recommended that separate bins be used and designated for each of the following six hazardous waste categories: aerosols and flammables, toxics, corrosive acidic, corrosive basic, oxidizer and universal waste.
Before hazardous waste items can be stored in a bin, they should be individually placed in a sealed plastic bag. This keeps items from commingling and causing a reaction. Any leaking containers should be double bagged and absorbents should be added to avoid any issues.
As soon as the first item is placed inside an accumulation bin, the container must be labeled as "Hazardous Waste." Properly labeled storage is not only important from an organizational and compliance standpoint, but it prevents incompatibilities from mixing together and causing a reaction. On each label, you must write the accumulation start date, which is the date on which the first item is placed in that bin. If your property is ever inspected, proper labeling is one of the first things an inspector will examine in your storage area.
While not a regulatory requirement, maintaining an inventory log can help to ensure your hotel remains compliant with government regulations. Each time a product is determined to be hazardous waste and placed into an accumulation bin by an employee, it can be noted on an inventory log and kept in your records.

Proper Hazardous Waste Storage

Accumulation bins should be stored in a dedicated, permanent hazardous waste area. It's imperative to select a location that is away from traffic areas, electrical panels, perishable/consumable product storage and dock doors. Waste containers must always be easily accessible, and the labels on these containers must be filled in completely and remain clearly visible at all times. Containment bags, spill kit, absorbent and other supplies should be located within this area. To ensure all employees are equipped with the correct hazardous waste management knowledge, all instructional literature, training materials and program posters should be posted in plain sight. Emergency numbers should also be posted in the accumulation area. This area should remain very clean and neatly organized.
Weekly inspections of hazardous waste accumulation containers and storage areas are often required in each state, but it depends on your state's regulations concerning your generator size. The purpose of these inspections is to verify that hazardous materials are properly handled and the accumulation area is properly maintained. A copy of this completed checklist, which can be created for you by a service provider or completed by your own staff, must also be kept on hand for your records.
A hazardous waste management service provider can remove hazardous waste from your property, manage the disposal and provide paperwork in a compliant manner. At the time your waste is taken, you'll receive copies of important documents that must be kept in your files for three years. The manifest document lists the waste removed from your property, and the Land Disposal Restriction Form informs the treatment facility of the waste they are receiving from your property so that it can be treated correctly. Once the waste has been destroyed, you'll receive a final copy of the manifest, which also must be kept in your records for three years.

There are many guidelines and best practices to follow in order to operate a hazardous waste management program that complies with all federal and state regulations. As many hotels are now dedicating a considerable amount of effort and resources to become more environmentally friendly, it's important to make sure their hazardous waste management practices are aligned with their sustainability program goals.

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