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Frequently Asked Questions
About Hazardous Waste Regulations

How do I manage solvent contaminated wipers?

 When is a container considered "empty?"

 What regulations apply to Conditionally Exempt Small Quantity Generators?

 Can I burn used oil in a space heater?

 How can I reduce my cleaning solvent waste?

 What is a satellite accumulation area?

 How do I handle used antifreeze from my business?

 How can I prepare my business for a hazardous waste inspection?

 What are the most common hazardous waste violations?

Management of Solvent Contaminated Rags and Wipers

Various industries use both disposable and reusable cloths and rags for cleaning equipment and machinery. Often the solvents used for this cleaning would meet the definition of a listed or characteristic hazardous waste when disposed. The term "solvent wipers" is defined as both disposable and reusable rags and towels, that have become contaminated through use in normal industrial and commercial operations. The following determination does not apply to absorbents used in spill cleanup operations.

Rags and Wipers Intended for Disposal

Solvent wipers which are contaminated with a listed hazardous waste must be managed as a listed waste when disposed of regardless of how the solvent got on the wiper. Whether the solvent is applied to a surface or machinery (and used for its solvent properties), then cleaned off with wipers or applied directly to a wiper prior to use, the constituent makeup of the wiper would basically be identical and would pose similar hazards. Therefore, both types of wipers must be managed as hazardous wastes.

Any entity sending contaminated wipers for disposal must evaluate those wipers to determine whether they are a hazardous waste in accordance with Ohio Administrative Code (OAC) Rule 3745-52-11. If the wipers are a hazardous waste, the generator is subject to the generator requirements in OAC Chapter 3745-52.

Rags and Wipes Being Sent for Cleaning

Ohio EPA has determined that solvent wipers which will be cleaned and reused do not meet the definition of a waste in OAC Rule 3745-51-02 because they have not been "discarded." The generator is intending to have the wipers returned after cleaning. Solvent wipers contaminated with a listed solvent or displaying the characteristic of a hazardous waste are not regulated as a waste if:

  • the wipers contain no free liquids;
  • the wipers are being sent to a commercial laundry that is subject to regulation under the

Clean Water Act or a dry cleaner for cleaning and reuse.
The laundry or dry cleaning facility would not be required to obtain a hazardous waste permit since the wipers would not be hazardous waste. For more information on this subject, contact the Technical Assistance Section in the Division of Hazardous Waste Management at (614) 644-2956.

Source: Small Business Assistance Office Newsletter, July 1996.

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When is a Container "Empty"?

Questions are often raised about the measures that must be taken before a container which once held hazardous waste would be considered to be empty of its contents. The regulatory definition of an empty container is found in OAC Rule 3745-51-07.

A container is considered EMPTY if all wastes have been removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating; AND

  • no more than 2.5 centimeters (one inch) of residue remains on the bottom of the container, OR
  • no more than 3 percent by weight of the total capacity of the container remains in the container if the container is less than or equal to 110 gallons in size, OR
  • no more than 0.3 percent by weight of the total capacity of the container remains in the container if the container is greater than 110 gallons in size.

A container that has held a hazardous waste that is a compressed gas is empty when the pressure in the contain reaches atmospheric. A container which held an acutely hazardous waste must be triple rinsed before being considered empty.

Source:  Ohio EPA, Small Business Assistance Office newsletter, July 1996.

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Ohio CESQG Rules

Conditionally Exempt Small Quantity Generators (CESQGs) are those facilities which generate less than 100 kilograms (220 lbs. or 25 gallons) of hazardous waste in any calendar month. In Ohio, the rules regulating CESQGs are found in the Ohio Administrative Code (OAC) Rule 3745-51-05. There are two main requirements CESQGs in Ohio must follow. CESQGs are required to evaluate any waste they generate to determine whether it is a hazardous waste and they must deliver their hazardous wastes to a permitted hazardous waste treatment, storage and disposal facility for management. There is no time limit for how long a CESQG may accumulate hazardous waste; however, once a CESQG has accumulated more than 1000 kilograms (2,200 lbs.) of hazardous waste or one quart of acutely hazardous waste, the facility is considered a Small Quantity Generator (SQG) and must remove the waste off-site within 180 days. SQG regulations are found in OAC Chapter 3745-52.

While Ohio's environmental regulations are typically equivalent to U.S. EPA's environmental regulations, CESQG rules are one area where they differ. U.S. EPA's CESQG regulations are found in Title 40 of the Code of Federal Regulations (40 CFR) in Part 261.5, Part 261.5(F)(3)(iv) and 261.5(g)(3)(iv). They indicate that is permissible for a CESQG to dispose of hazardous waste at a facility permitted, licensed or registered by the State to manage municipal or industrial solid waste. The rules in place in Ohio regulating CESQGs differ, as they do not permit the disposal of hazardous waste in a municipal or industrial solid waste facility. While a CESQG may transport its hazardous waste if they desire, the waste must be disposed of in a permitted hazardous waste facility.

For more information on the regulations for CESQGs, contact the Technical Support Unit in the Division of Hazardous Waste Management at 614-644-2956.

Source: Ohio EPA, Small Business Assistance Office newsletter, October 1996.

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Burning Used Oil in Space Heaters

During colder months, service centers, car dealerships, and related businesses help heat their shops by burning used oil in space heaters. Businesses burning used oil in their space heaters must be aware of Ohio EPA's hazardous waste and air pollution requirements.

The hazardous waste requirements that cover used oil are Rules 3745-58-50 to 3745-58-54 of the Ohio Administrative Code (OAC). Rule 3745-58-51(C) states that used oil may be burned in space heaters if the following conditions are being met:

  • the space heater is only used to burn oil that is generated at the business or received from a do-it-yourself oil changer who generated it as a household waste;
  • the space heater does not exceed a capacity of 500,000 (.5 million) British Thermal Units (BTUs) per hour;
  • combustion gases from the unit must be vented to the outside;
  • the used oil must not be mixed with any hazardous waste.

Burning used oil in space heaters causes air pollution. The level of air pollution (or emissions) depends on the amount of oil burned. Space heaters having a burner rating of less than 500,000 BTUs per hour cause little air pollution and can qualify for the "de minimis exemption" under OAC Rule 3745-15-05.

Qualifying for the de minimis exemption means that the business does not have to get an EPA air permit to operate the space heater. If the space heater qualifies for this exemption, the business does not need to provide EPA's Division of Air Pollution Control with this information. However, any business burning waste oil should keep a monthly record of the amount burned (in gallons) and the origin of the waste oil (either generated on-site or received from a do-it-yourselfer). Records of any lab testing that has been done on the oil or information from the supplier should also be kept in file.

The burner rating (BTU capacity) is usually found on the space heater itself or in the manufacturer's literature. Most space heaters on the market are rated less than 500,000 BTU/hr. If the heater's rating is unknown, the manufacturer can be contacted for this information. Heaters that cannot burn more than 5 gallons of waste oil per hour are also likely to qualify for the de minimis exemption.

Acceptable waste oils for burning include: used crankcase oils from automobiles and trucks, used metal working and lubricating oils, 90 W. gear oil, automatic transmission fluid, hydraulic oil, and heat transfer fluids. Burning other types of waste oils may require approval from the EPA's Division of Air Pollution Control (DAPC).

Contact the Office of Compliance Assistance and Pollution Prevention at (614) 644-3469 or (800) 329-7518 to obtain a copy of the de minimis exemption or for additional information on the air pollution requirements for space heaters. For more information on the hazardous waste rule, contact the Technical Support Unit in the Division of Hazardous Waste Management at (614) 644-2956.

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Reducing Cleaning Solvent Waste

Parts-washing units are used by many small businesses for cleaning equipment. Like other tasks, cleaning procedures should be reviewed to ensure that best work practices are followed. Checking to see if your shop is using best work practices can reduce waste, free up labor and provide payback on your investment.

Equipment Management

  • Service Contracts: Negotiate your service contract so solvent changeouts fit your use schedule, especially if you have seasonal fluctuations in your shop's solvent needs. Remember, you incur costs and liability with each shipment of waste.
  • Cleaning demands: Segregate cleaning into two stages, each having a dedicated washing unit. Using two units extends the usefulness of the solvent.
  • Equipment Options: Use parts-washing units equipped with filters or other separation options that will keep the solvent cleaner longer. Add-on accessories are available from your equipment vendor.

Equipment Operation

  • Need: Think about when parts need cleaning and when they do not. Each use of a parts- washing unit increasingly contaminates the solvent and, over time, shortens then solvent's useful life. If only interior surfaces need to be cleaned, avoid cleaning exterior surfaces that can add dirt, grease, or paint and overburden your solvent. If extra surface cleaning is unavoidable, scrape or wipe off dirt before putting the part into the solvent.
  • Techniques: Splashing solvent and dragging out dripping parts depletes your solvent reservoir and makes a mess. Clean each part carefully and use drain racks to save solvent and avoid unnecessary cleanup.
  • Evaporation: Cover and turn off circulating sinks to conserve energy and to keep solvents from evaporating.
  • Evaluation: The appearance of used solvent may not be a good indicator of the solvent's ability to clean. Monitor the solvent to determine its maximum useful life then modify your changeout schedule to get the most out of your solvent.

Inventory Management

  • Supply: Limit access to solvent supplies. Keeping and displaying records on solvent use may be helpful for controlling waste, especially in an operation with a large workforce.
  • Convenience: Consider using a central cleaning station. When using individual workstations, weigh their potential for accidents, exposure and waste generation against their convenience and efficiency.

Source:  Small Business Assistance Office newsletter, March 1997.

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Hazardous Waste Satellite Accumulation

An area where hazardous waste is collected at or near the point of generation is called a "satellite accumulation area." Satellite accumulation areas are commonly located near a process line or in areas like a maintenance garage, paint shop, electrical shop, welding shop or laboratory. The satellite accumulation requirements apply to both small and large quantity hazardous waste generators and are found in Ohio Administrative Code (OAC) rule 3745-52-34(C). To stay in compliance with the satellite area regulations, your company must ensure that:

  1. The area is at or near the point where the waste is generated and is under the direct control of a person working in that area (e.g., the process operator);
  2. Each container is marked "Hazardous Waste" or with other words to identify the contents;
  3. Containers are always closed, unless adding or removing waste;
  4. Each container is in good condition and is compatible with the materials stored in it and with materials stored nearby;

The total quantity of waste in the satellite area does not exceed 55-gallons (or 1 quart of an acutely hazardous waste). The 55-gallon limit applies to the total volume of waste collected in the satellite area not to each individual waste stream. When wastes collected in the satellite area exceed 55 gallons, you must remove the excess wastes from the satellite area to a central accumulation area within three days. The date the drum is placed in the central storage area is marked on the drum as the accumulation start date.

Hazardous waste can be kept in the central accumulation area for up to 90 days (for large quantity generators) and up to 180 days (for small quantity generators). The size of the containers used to collect wastes is not limited. Your company can also have more than one satellite accumulation area. Additional questions about the satellite accumulation requirements can be directed to Ohio EPA's Division of Hazardous Waste Management (DHWM) at (614) 644-2956. You can also call DHWM to get a free copy of the division's "Guidance on the Location of Satellite Accumulation Areas."

Source: Small Business Assistance Office newsletter, August 1997.

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Antifreeze drained from automobiles, trucks or other engines is considered a waste. Ohio EPA does not regulate used antifreeze as hazardous waste unless it contains unacceptable levels of certain metals, such as lead or chromium. It can also be a hazardous waste if it has been mixed with gasoline, used oil or solvents. If you are generating antifreeze at your company, you must evaluate it to determine if it is a hazardous waste. You must also properly manage and dispose of spent antifreeze.

You cannot dispose of used antifreeze by pouring it into your septic system, onto the ground or in the trash. In most areas of Ohio you cannot dispose of it in the sanitary sewer. You can hire a disposal company to dispose of your used antifreeze, but this will usually be the most expensive option.

The best option for handling used antifreeze is to have it recycled. There are three ways you can recycle used antifreeze. You can purchase a small antifreeze recycling system to use at your facility. You can hire a company to bring mobile recycling equipment to your facility, recycle the antifreeze and leave the recycled product for you to reuse. You can hire a company to pick up your used antifreeze and recycle it at a central facility. If you recycle your own antifreeze on-site, you must make sure that any wastes from the recycling activity (e.g., sludge, filters) are also evaluated to see if they are hazardous waste.

If your used antifreeze is a hazardous waste and you do not have it recycled, you must dispose of it at a hazardous waste facility. In addition, prior to sending if off-site for recycling or disposal, the used antifreeze must be properly managed on-site as a hazardous waste (e.g., keeping closed containers, labeling, inspections, etc.).

If you would like more information about determining if used antifreeze is a hazardous waste or about used antifreeze recycling equipment or services, please call the OCAPP at (614) 644-3469 or (800) 329-7518.

Source:  Ohio EPA, Small Business Assistance Office newsletter, August 1999.

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Is Your Business Prepared?

Each year, Ohio EPA's Division of Hazardous Waste Management conducts hundreds of inspections at companies to see if they are complying with the hazardous waste rules. Many of these inspections are done at small businesses such as printers, manufacturing companies, electroplaters, dry cleaners, auto shops and others.

Although many companies are found in compliance with the regulations, several others are found in violation. This is particularly true at small businesses, where it can be difficult to understand what is required and to keep up with the regulations. Some common hazardous waste violations inspectors find include:

  • Failure to evaluate ALL wastes to see if they are hazardous, including: fluorescent lamps, solvent contaminated wipers, paint waste, process filters, aerosol cans and other wastes.
  • Having a drum(s) of unknown waste on-site.
  • Improper management of used oil.
  • Failure to keep hazardous waste containers closed and in good condition.
  • Failure to label containers with the words "Hazardous Waste."
  • Failure to have inspection logs for hazardous waste containers and emergency equipment.
  • Failure to post emergency information by the telephone.
  • Failure to have copies of hazardous waste manifests or shipping papers.
  • Failure to complete personnel training or keep training records.
  • Keeping hazardous waste on-site for longer than the regulations allow.
  • Keeping too much hazardous waste on-site.

If your business produces hazardous waste, you could be inspected next. Are you prepared for an inspection? Do you know if your company is in compliance with the regulations?

Knowing which hazardous waste regulations apply to your business is the first step toward compliance. If you have questions about the hazardous waste regulations, contact the Division of Hazardous Waste Management at 614-644-2917 or visit their web site at www.epa.state.oh.us/dhwm.

In addition, you can receive a free environmental compliance self-assessment guide from the Office of Compliance Assistance and Pollution Prevention (OCAPP). This resource will help you check on your compliance status with hazardous waste and other Ohio EPA regulations. The OCAPP is also holding workshops for small business owners who need to know more about the hazardous waste regulations. For a copy of the guide or for more information on the workshops, call the OCAPP at (800) 329-7518.

Source:  Ohio EPA, Small Business Assistance Office newsletter, May 1999.

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The Violations Most Frequently Cited by Hazardous Waste Inspectors

According to data collected from December 2002 through November 2004, the violations most frequently cited by Ohio EPA Division of Hazardous Waste Managementís inspectors include requirements concerning hazardous waste determination, annual reports, container management, emergency equipment inspections and used oil storage. These findings, tips, links to the rules and other tools that hazardous waste generators can use to avoid these common violations are summarized on divisionís Web site at www.epa.state.oh.us/dhwm/frequentviolations.html.

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