Hazardous waste communication training

Hazardous waste communication training

Hazardous Waste Training Guide: Large Quantity Generators (LQG)

EPA #: COR000243287

Summary

This guide provides in-depth training for Milarc Cabinets employees to ensure proper identification, handling, storage, and disposal of hazardous waste in compliance with federal (RCRA) and Colorado (CDPHE) regulations. It is designed to minimize risk to health, safety, and the environment while ensuring legal compliance during the daily operations of our custom cabinet manufacturing facility. This training document is specific to our materials, processes, and designated waste management protocols

Training Map

Definitions of Hazardous Waste

Hazardous Waste Determinations

Classification & Requirements

Waste Codes + Waste at Milarc

Safety Data Sheets

Storage Requirements

Duties & Responsibility

RCRA Rule - Cradle-to-Grave

Spill Kits & Emergency Response

Personal Protection Equipment (PPE)

Training Map Cont.

Record Keeping & Inspections

Disposal & Manifests

Review

What is Hazardous Waste?

Hazardous waste refers to materials that can pose a significant risk to human health or the environment when improperly handled or disposed of. These materials are identified by the U.S. Environmental Protection Agency (EPA) based on specific characteristics or if they are listed as hazardous under RCRA regulations. At Milarc Cabinets, spent solvent waste and related materials are classified as hazardous and require strict handling protocols. This includes items such as used stains, cleaning solvents, and contaminated rags. Employees are expected to follow all waste storage, labeling, and disposal procedures to ensure compliance and safety. Hazardous waste is any solid, liquid, or contained gaseous material that is no longer usable and exhibits characteristics that may be harmful to human health or the environment. These characteristics include:

Easily catches fire (e.g., acetone, lacquer thinner, flammable stains)

Can corrode metals or damage skin (e.g., industrial cleaners, acids)

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Ignitability

Corrosivity

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May explode or release toxic gases (e.g., pressurized cylinders with incompatible chemicals)

Harmful when ingested or absorbed (e.g., lead-based products, MEK)

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Toxicity

Reactivity

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How to Determine if a Waste is Hazardous - 6 Key Questions

The U.S. Environmental Protection Agency (EPA) outlines a six-step method to assess whether a material should be classified as hazardous waste: 1. Is it Solid Waste?

• First, determine whether the material fits the legal definition of a solid waste under EPA rules.

2. Is it Exempt?

• Does the material qualify for any exclusions or exemptions under hazardous waste or solid waste regulations?

3. Is it on a Hazardous Waste List?

• Check if the waste appears on any of the EPA's published lists of hazardous wastes (F-list, K-list, P-list, U-list).

4. Does it Display Hazardous Properties?

• Even if it's not listed, does it have one or more hazardous characteristics such as ignitability, corrosivity, reactivity, or toxicity?

5. Is it Combined with Hazardous Waste?

• Was it mixed with another hazardous waste? If so, it may still be considered hazardous.

6. Is it a Byproduct of Hazardous Waste?

• Was the waste generated from treating, storing, or disposing of a hazardous waste?

View determination Flow Chart

Classification & Requirements

This section will review what our classificiation status is at Milarc Cabinets and what requirements are associated with that classification.

Classification

• Milarc Cabinets is classified as a Large Quantity Generator (LQG) of hazardous waste under the Resource Conservation and Recovery Act (RCRA).

• This status is determined by the amount of hazardous waste generated per calendar month:

• Large Quantity Generator (LQG) > 2,200 lbs (1,000 kg) OR >1 kg of acute hazardous waste Full regulatory requirements apply

• Because Milarc Cabinets generates more than 2,200 lbs of hazardous waste per month (primarily solvent waste, paint waste, and solvent-contaminated rags), we are an LQG facility.

Hazardous Waste Requirments

Click into each "+"

90-Day Accumulation Limit

Training Requirements

Weekly Inspections

Contingency Plan

Emergency Coordinator

Record Retention

Labeling

Waste Codes

An EPA waste code is a unique alphanumerical identifier assigned by the U.S. Environmental Protection Agency (EPA) to categorize hazardous wastes based on their specific chemical composition, source, or hazardous properties. An EPA waste code is a regulatory classification used under the Resource Conservation and Recovery Act (RCRA) to identify, track, and manage hazardous wastes in the United States. Why it matters?

• These codes indicate the type of hazard a waste presents (e.g., ignitable, corrosive & Toxic)

Where are waste codes used?

• Hazardous waste manifests
• Waste profiles & labels
• EPA ID number registrations
• Disposal Facility Documentation

Waste Codes used at Milarc Cabinets

D035

D001

F003

F005

Safety Data Sheets

Safety Data Sheets (SDS) SDS binders are located in the Finish Department, near the stain storage area and the oven, and are accessible to all employees. A Safety Data Sheet is available for every hazardous chemical used in the facility. These documents provide detailed information on the hazards, safe handling, and emergency procedures related to each product.

Haz Waste Storage Requirements

Central Accumulation Area (CAA)

Satellite Accumulation Area (SAA)

Regulation Requirements

Labeling Requirements

Photo Examples

Duties & Responsibilities

Finish Department

• Responsible for all hazardous waste generation within the finishing area, including solvents, coatings, and contaminated rags.
• Ensure proper segregation of flammable waste (D001) and solvent waste (F003/F005).
• Perform weekly inspections of the Central Accumulation Area (CAA) and Satellite Accumulation Areas (SAA).
• Maintain current labels showing “Hazardous Waste,” the full chemical name(s), and the accumulation start date.
• Notify the ECC when a drum approaches the 55-gallon limit or requires pickup/disposal.
• Verify spill kits, fire extinguishers, and secondary containment are in place and in good condition.

Assembly, Woodshop, and Panel Processing

• Generate and manage rag-related waste from stains, adhesives, and cleaning materials.
• Deposit used rags only into the designated SAA rag containers with tight-fitting lids.
• Complete weekly SAA inspection checklists and submit them to the ECC.
• Report any container issues or missing labels immediately.
• Maintain a clean, organized work area to prevent cross-contamination and fire hazards.

Delivery & Logistics Staff

• No direct hazardous waste handling duties.
• Must recognize and respond appropriately to spill or notify ECC

Office & Administrative Staff

• No hazardous waste handling duties.
• Support compliance through proper documentation, recordkeeping, and communication with the ECC as needed.

Duties & Responsibilities Cont.

Environmental Compliance Coordinator (ECC) / Program Administrator

• Oversee the facility’s compliance with all EPA and CDPHE LQG requirements.
• Maintain training records, manifests, inspection logs, contingency plans, and SDS documentation.
• Conduct and document weekly CAA inspections and verify completion of SAA checklists.
• Coordinate with licensed transporters and treatment facilities for off-site disposal.
• Update contingency plans, ensure emergency equipment is functional, and schedule annual training.
• Serve as the primary contact for regulatory inspections or environmental inquiries.

Supervisor / Department Lead Responsibilities

• Ensure all employees in their department have completed required training.
• Verify daily compliance with container management, labeling, and housekeeping standards.
• Immediately report non-compliance or unsafe conditions to the ECC.
• Support emergency response and spill cleanup coordination within their department.

Summary Each employee plays a vital role in maintaining compliance as an LQG facility. Consistent attention to labeling, storage, and inspection requirements ensures regulatory adherence, protects employee safety, and prevents environmental contamination.

Cradle-To-Grave

Under the Resource Conservation and Recovery Act (RCRA), all hazardous waste generated by Milarc Cabinets is managed under a “cradle-to-grave” system. This means the company retains legal responsibility for its hazardous waste from the moment it is generated until its final treatment, recycling, or disposal — even after it leaves the facility. As a Large Quantity Generator (LQG), Milarc must ensure that every step in the waste management process is conducted safely, accurately, and in full regulatory compliance. This includes:

• Proper identification and labeling of all hazardous waste at the point of generation.
• Safe accumulation and storage within designated Satellite and Central Accumulation Areas.
• Use of licensed transporters and permitted Treatment, Storage, and Disposal Facilities (TSDFs).
• Retention of manifests and disposal documentation verifying proper off-site management.

All employees share responsibility in this process by following established handling, labeling, and inspection procedures. Improper management at any stage can result in regulatory violations, environmental damage, and safety hazards. The cradle-to-grave principle reinforces that Milarc’s accountability does not end when waste leaves the site — it continues until the material has been properly and lawfully disposed of at an approved facility.

Spill Kits & Emergency Response

In the event of a chemical or hazardous material spill, spill kits are readily available in two primary locations: the Finishing Department and the Outdoor 90-Day Central Accumulation Area (CAA). Finishing Department Spill Kit Includes:

• Flash Dry Absorbent
• Absorbent Socks
• Absorbent Pads
• Latex Gloves
• Outdoor 90-Day CAA Spill Kit Includes:
• 4-Drum Ultra-Spill Containment Pallet
• Absorbent Socks

SPILL RESPONSE & CONTAINMENT PROCEDURE: PIG-brand spill kits are located at both Satellite Accumulation Areas (SAA) and Central Accumulation Areas (CAA). Each kit typically includes:

• Absorbent socks, mats, and pillows
• Nitrile gloves and chemical splash goggles
• Heavy-duty disposal bags with twist ties

Emergency Evacuation Plan & Location of Fire Extinguishers

The following apply during fires and other workplace emergencies requiring evacuation: • The fire alarm will be activated, and personnel will calmly evacuate using designated escape routes giving vocal alarms of “FIRE”, etc. • Personnel will look into rooms as they leave the suite and notify personnel to exit; do not delay your evacuation for this purpose. • Personnel will assemble and remain in the evacuation assembly area. Leaving the group or failing to report to the evacuation assembly area can cause unnecessary effort locating personnel believed to be missing. • Immediately notify your floor captain or the emergency coordinator of missing or unaccounted for personnel. • Stay alert and listen to instructions. • Await guidance to disperse, return to the building or take additional measures. • In the event of a medical or other emergency that does NOT require evacuation, CALL 911 to alert Police and notify the emergency coordinator.

Assembly Area

Personal Protection Equipment (PPE)

PPE protects employees from exposure to hazardous waste, chemicals, dust, and noise. Always wear the required PPE for your task and work area.

• Gloves – Protect hands from solvents, coatings, adhesives, and contaminated materials.

• Respirators – Used during coating, solvent handling, or waste transfer; must be fit-tested and maintained.

• Safety Glasses – Required in all production and waste-handling areas to prevent splashes or debris injuries.

• Tyvek Pants – Protect against chemical splashes or contaminated materials during finishing and cleanup.

• Dust Masks – For light dust or sanding; not for vapors or solvent protection.

• Ear Plugs – Required in high-noise areas (panel processing, assembly, machinery).

Employees are responsible for inspect PPE before each use; replace damaged or dirty items.

• Store PPE in clean, dry areas when not in use.

• Follow all posted PPE signage and safety rules.

• Report shortages, fit issues, or damaged PPE to your supervisor.

Key ReminderPPE is your first line of defense against chemical exposure and injury. Always wear the proper protection — no exceptions.

Record Keeping & Inspeciton

Training records, manifests, inspection logs, contingency plans, and waste determinations must be kept for at least 3 years (some until facility closure).

Inspection Checklist

Compliance Checklist

Records hardcopies are stored in the office, we also have digital records

Disposal & Manifests

Milarc partners with Barton Solvents to handle pickup, transportation, and final disposal. Our manifest documents include:

• Generator EPA ID: CO000243287
• Manifest Tracking Number
• TSDF Facility Information
• Waste codes and quantities
• Generator certification signature

After pickup, Barton returns a signed copy showing the final disposal. These must be filed and retained for at least 3 years. These are stored in the front office in a filing cabinet under the back counter.

Are you responsible for signing hazardous Waste Manifests? If so, please see the: “Expanded Hazardous Waste Training Module: Manifests & Transportation Requirements (EPA RCRA + Colorado 6 CCR 1007-3)”

Training Summary

This training provided an overview of Milarc’s Hazardous Waste Management Program as a Large Quantity Generator (LQG). Employees received instruction on the proper identification, accumulation, labeling, and disposal of hazardous waste generated at the facility. Training covered waste code classifications (including D001, D035, F003, and F005), safe handling procedures, emergency response protocols, and documentation requirements under 40 CFR Part 262 Subpart H and CDPHE LQG regulations. Specific responsibilities were outlined by department — including the Finish Department, Assembly, Woodshop, and Panel Processing — with emphasis on maintaining closed and labeled containers, performing weekly inspections, completing SAA/CAA checklists, and preventing spills or releases. The importance of emergency preparedness, contingency planning, and communication with the Environmental Compliance Coordinator was reinforced. By completing this training, participants demonstrated an understanding of their role in maintaining regulatory compliance and protecting employee health and environmental safety in accordance with federal and state LQG standards. If you have any additional questions regarding this training or your responsibilities outlined within this training, please contact Sarah Horton.

Thank you!

Satellite Accumulation Areas (SAA) - INSIDE

• Located at or near the point of waste generation, such as the Finish department, panel processing, assembly & woodshop.
• Maximum 55 gallons of hazardous waste or 1 quart of acute waste.
• Must be under the operator control at all times (within the line of sight).

🔹 Waste Code: F005 Chemical Category: Spent Non-halogenated Solvents EPA Reference: 40 CFR 261.31 RCRA Category: Listed Waste (F-list: Spent Solvents) ⚠️ Hazard Summary F005 applies to spent non-halogenated solvents that are both ignitable and toxic, commonly used for cleaning, coating, or degreasing. These solvents are typically stronger, slower-evaporating, and more hazardous than those under F003. 🧪 Constituents Identified Under F005 Toluene Methyl ethyl ketone (MEK), Methyl isobutyl ketone (MIBK), Carbon disulfide, Isobutanol (In their “spent” form or waste mixtures containing them) 🧴 Examples of Waste That May Be Coded F005

• Spent lacquer thinner containing MEK or toluene
• Paint booth cleaning solvent waste
• Rags, filters, or wipes contaminated with listed solvents Solvent-based adhesive or coating residues

🗑️ Proper Management

• Store in closed, labeled containers within your SAA or CAA
• Label: “Hazardous Waste – Spent Non-halogenated Solvent (F005, D001, D035)”
• Keep away from heat, sparks, and open flames
• Segregate from halogenated or incompatible wastes
• Maintain weekly inspection and proper secondary containment

• Never mix incompatible waste streams within the same waste drum. Ensure all wastes are compatible if they are being stored together.
• Adequate aisle space*, spill containment & emergency signage must be present in each of these areas.

*Aim fo 36" minimum isle space.

• Containers in the CAA & SAA need to be grounded & bonded.
• Containers need to be closed & sealed execpt when adding/removing waste.
• Both the CAA & SAA need to be inspected weekly.
• Material from the SAA needs to be transfered to the CAA every 90 days (unless the container is full earlier)
• Once a container in the SAA is full, it must be moved to the CAA within 3 calendar days.

🔹 Waste Code: D001

• Characteristic: Ignitable Waste
• EPA Reference: 40 CFR 261.21
• RCRA Category: Characteristic Waste

⚠️ Hazard Summary D001 applies to flammable or ignitable wastes — liquids, solids, or gases that can easily catch fire under normal conditions. Typical examples include solvents, thinners, alcohols, paints, and rags saturated with flammable liquids. 🔥 Ignitability Criteria

• Liquid: Flash point below 140°F (60°C)

• Non-liquid: Capable of causing fire through friction, absorption of moisture, or spontaneous chemical change

• Compressed gas: Meets DOT definition of “flammable gas”

• Oxidizer: Capable of intensifying combustion

🧴 Examples of Waste That May Be Coded D001

• Solvent mixtures (acetone, MEK, toluene, xylene)

• Paints, lacquers, stains, adhesives

• Cleaning rags or filters contaminated with flammable materials

• Aerosol cans or other pressurized flammables

🗑️ Proper Management

• Store in closed, labeled containers in the SAA or CAA

• Label: “Hazardous Waste – Ignitable (D001)”

• Keep away from heat, sparks, and open flames

Contingency Plan

A written, site-specific emergency contingency plan must be maintained, shared with local emergency responders, and kept up to date.

Record Retention

Training records, manifests, inspection logs, contingency plans, and waste determinations must be kept for at least 3 years (some until facility closure).

• Sarah Horton is responsible for Recordkeeping. Records are stored digitally & hard copies are kept in the front office.

🔹 Waste Code: F003 Chemical Category: Spent Non-halogenated Solvents EPA Reference: 40 CFR 261.31 RCRA Category: Listed Waste (F-list: Spent Solvents) ⚠️ Hazard Summary F003 covers spent non-halogenated solvents that are ignitable and non-toxic, typically used for degreasing, cleaning, or coating operations. These solvents have a flash point below 140°F (60°C) and often overlap with D001 ignitable classification. 🧪 Constituents Identified Under F003 Acetone, Ethyl acetate, Ethanol, Isopropyl alcohol, n-Butyl alcohol, Methanol, Methyl isobutyl ketone (MIBK), Xylene, n-Butyl acetate (All in their “spent” form or waste mixtures containing them) 🧴 Examples of Waste That May Be Coded F003

• Used paint thinners or solvent blends

• Cleaning rags or filters containing listed solvents

• Spray gun and equipment cleaning waste

• Residuals from coating or finishing operations

🗑️ Proper Management

• Store in closed, labeled containers in your SAA or CAA

• Label: “Hazardous Waste – Spent Non-halogenated Solvent (F003, D001)”

• Keep away from heat or ignition sources

• Segregate from halogenated wastes (e.g., F001/F002)

• Ensure weekly inspection and secondary containment

Every week, a trained staff member must complete an inspection of the CAA & all SAA. This checklist is located within ASANA & a paper copy must be filled out as well for dual record keeping purposes. Once the paper copy is completed, it must be turned into the office before you leave for the day. Each department is assigned a completion date that will be monitored by your safety coordinator. Upon completion of each item you will Initial with who has completed each task. This satisfies 6 ccr 1007-3 Hazardous Waste (iv) Inspections.

Every hazardous waste container must be labeled with:

• The phrase: “Hazardous Waste”,
• Description - The contents, including chemical names or product type
• The accumulation start date (when waste was first added), 1st thing you do BEFORE adding waste
• Applicable hazard codes (D001, F003, F005 or D035 - see sheet posted if you are unsure)
• Hazard Indication (e.g., flammable, toxic)

Labels must be printed or written in permanent ink and visible at all times. Do not allow labels to wear off or peel. Add Tape if necessary to ensure labels stick to drums

Hazardous waste cannot be stored in the Central Accumulation Area (CAA) for more than 90 days before being shipped to a treatment, storage, or disposal facility (TSDF). The CAA is located outside near the dust collector.

Central Accumulation Area (CAA) - OUTSIDE

• The main waste staging area located outside near the dust collection system.
• Material can only stay in this area for 90-days.
• This is the main area where Barton Solvents will pickup waste.
• Containers must be on spill containment - no exceptions. (Secondary Containment)
• Empty containers must be stored upside down and have the words “empty.

🔹 Waste Code: D035 Chemical Name: Methyl Ethyl Ketone (MEK)

• CAS Number: 78-93-3
• EPA Hazardous Waste Category: Characteristic Waste (Ignitability)
• RCRA Characteristic: Ignitable Waste (D001) often applies in combination with this code
• Regulatory Citation: 40 CFR 261.24, Table 1 — “Toxicity Characteristic”

⚠️ Hazard Summary

• MEK is a flammable liquid solvent used in paints, lacquers, and coatings.
• Waste containing MEK can exhibit the ignitability characteristic and sometimes toxicity if it exceeds regulatory thresholds (≥200 mg/L in the Toxicity Characteristic Leaching Procedure, or TCLP).
• It evaporates quickly and poses fire and inhalation hazards.

🧴 Examples of Waste That May Be Coded D035

• Used lacquer thinner or coating solvents containing MEK Paint booth cleaning rags saturated with MEK
• Spray gun cleaning waste
• Residual solvent waste from finishing operations

🗑️ Proper Management

• Store in closed, labeled containers in a Satellite Accumulation Area (SAA)
• Label: “Hazardous Waste – Methyl Ethyl Ketone (D035, D001)”
• Keep away from ignition sources
• Ensure containers are compatible and grounded

Documented weekly inspections of all Central & Satelite Accumulation Areas.

• The example checklist is above. We have 5 SAA's and 2 CAA at Milarc.
• Woodshop
• Panel Processing x2
• Assembly
• Finish
• CAA - Located outside

Emergency Coordinator

An emergency coordinator must be available at all times (on-site or on-call).

• Johnny Fassler is our on-site emergency coordinator

All containers must be labeled “Hazardous Waste”, with hazard warnings, EPA waste codes, and accumulation start dates. See "Labeling" for more in depth information.

Milarc’s Hazardous Waste Compliance Checklist

• Does Milarc maintain Hazardous Waste Profiles that document all hazardous waste generated and disposed of at the facility?
• Is Milarc following all regulations for pre-transportation documentation, including: Are proper hazardous waste labels applied to every 55-gallon drum?
• Are manifests accurate and free of errors?
• Are all manifests filed in the Hazardous Waste binder and retained for a minimum of 3 years?
• Are weekly hazardous waste area inspections being conducted and documented for compliance?
• Have all employees received proper training on hazardous waste procedures?
• Is hazardous waste training included in Milarc’s onboarding process for all new hires?
• Has Milarc submitted the required annual self-certification checklist, due each May?
• Has Milarc completed the required biennial report due ever even year?
• Is the contingency plan up to date?

Training Requirements

• Initial training for new employees within 6 months of starting work in a position involving hazardous waste. • Annual refresher training thereafter (documented, updated, and signed). • Employees may not handle hazardous waste until they’ve been trained.

Assembly Area – across the street on the southwest lawn of CMS.