Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Florida generally follows the federal rules for hazardous waste management and also has more stringent state requirements.
1. Do I need an EPA ID number to handle hazardous wastes
The Florida Notification of Regulated Waste Activity form (62-730.900(1)(b)) is used to notify the Florida Department of Environmental Protection (FDEP) of regulated waste activities. Place any EPA identification number that was previously assigned to your site in the box in the upper left hand corner of the notification form. In addition to these instructions, you can obtain further guidance in filling out this form by visiting http://www.dep.state.fl.us/waste/categories/hazardous/pages/publications.htm where you will find electronic versions of these documents and additional notification information; or by calling 850-245-8772 from 8 a.m. to 5:00 p.m. Monday through Friday. Forward this form and any related correspondence to: EPA ID Notification Coordinator, Hazardous Waste Regulation Section MS 4560, Department of Environmental Protection, 2600 Blair Stone Road, Tallahassee, Florida 32399-2400. You should receive a confirmation letter within two weeks. If you do not receive a confirmation letter within 30 days of sending it to us, please call us at (850) 245-8772.
2. How do I determine my generator status?
Florida generally follows the federal rules for defining generator status. Generators and persons that treat, store, transport, dispose of, or otherwise handle, handled or propose to handle hazardous waste must furnish, upon written request from DEP, specific information relating to waste or handling. This must be provided to DEP within 30 days of receipt of their request.LQGs and SQGs must have an EPA ID number before offering hazardous waste for transport off-site. LQGs and SQGs must complete specified sections of the federal Uniform Hazardous Waste Manifest form.
3. How can I tell if the waste materials I handle are considered
Florida follows the federal rules for defining hazardous wastes.
4. How long can I store hazardous wastes on site?
Florida generally follows the federal rules for storing hazardous wastes.SQGs are not allowed to accumulate hazardous waste for more than 180 days.LQGs and SQGs must maintain adequate aisle space between containers of hazardous waste to allow for inspection of the condition and labels of the individual containers.Storage facility owners and operators in Florida must pay annual construction, operating, and closure fees.
5. Who can transport and receive the wastes I ship off site?
Florida follows the federal rules for shipping hazardous wastes to a TSD.Transporters must meet the state's financial responsibility requirements, or they cannot transport material that requires either a manifest or a reclamation agreement between a generator and a recycler. This does not apply to the transport of on-site hazardous waste at a generator or TSDF facility.Universal waste transporters must register annually; and meet specific handling and labeling requirements.
6. What records do I have to keep?
Florida follows the federal rules for recordkeeping.CESQGs must document hazardous waste shipments sent off-site for disposal through written receipts and other records, and must be kept on file for at least three years.Generators that accumulate hazardous waste on-site must keep written documentation of container and tank inspections, and keep on file for at least three years.
7. Do I have to file reports?
Florida follows the federal rules for reporting.
8. What training requirements do I have to meet?
Florida follows the federal rules for training.Mercury recovery or reclamation facility employees must successfully complete a program of classroom or on-the-job training to ensure safe equipment operation, emergency response procedures and release prevention through facility inspections. Training records must be kept on file for at least three years.
9. What differences between states may exist with regard to use of the the new standardized manifest form?
As of September 5, 2006, the new standardized manifest form (EPA Form 8700-22) and its continuation sheet (EPA Form 8700-22A) must be used in every state to track hazardous waste shipments. There will be no state variations of the new federal form and states may not require information to be included on the form that is in addition to that required by federal rules. That said, some differences between states may exist with regard to use of the form. For Florida these differences include:
There are no State-specific waste codes for the State of Florida.
The State of Florida does not require that you submit manifest copies to the Florida Department of Environmental Protection. However, if your state requires that such copies be submitted, they should be submitted to: Hazardous Waste Manifest Coordinator, FDEP MS 4555, 2600 Blair Stone Road, Tallahassee, FL 32399-2400
Other Notes, Comments::
A list of vendors supplying the new manifest form and instructions can be obtained by contacting the Hazardous Waste Management Section, MS 4555, Division of Waste Management, Department of Environmental Protection, 2600 Blair Stone Road, Tallahassee, Florida 32399-2400.
10. What are some other differences between federal and state
CESQGs are not allowed to dispose of hazardous waste at any solid waste facility unless the facility has a permit to accept hazardous waste.
- Mary Jean Yon, Director, Waste Management, (850) 245-8705