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Insights

The Forgotten Class, Class 2 Industrial Waste

By Braun Intertec | April 1, 2015

Correct use of the Class 2 non-hazardous waste code is one of the best tools to minimize your risk of burdensome reporting requirements and higher regulatory costs, yet it is often overlooked by waste generators.

The TCEQ requires that all industrial waste be classified and assigned a waste code by the waste generator.  Hazardous wastes are defined by the EPA, and those definitions remain the same for all 50 states.  However, once a waste is determined to be non-hazardous, each state has different regulations that apply.  Texas has one of the most detailed breakdowns of non-hazardous wastes, using a 3-tiered “class” system:  Class 1, Class 2, and Class 3.  Class 1 wastes are those wastes that are not hazardous, but pose enough risk to the environment that Texas does not want them disposed of in a standard municipal landfill.

Class 1 waste requirements include:

  •  If landfilled, must be managed in landfill cell that contains extra safeguards to protect the environment (higher disposal cost)
  • Must be shipped on an EPA Hazardous Waste manifest (which are subject to audit by EPA, TCEQ, and DOT).
  • Class 1 waste must be reported on an Annual Waste Summary Report (depending on monthly volumes)
  • Class 1 waste generators must register with the TCEQ (depending on monthly volumes)
  • Class 1 waste must pay special state fees both at the time of disposal and again when reported on the Annual Waste Summary report.

Many industrial waste generators overlook the potential to classify their non-hazardous waste into either of the other tiers available – Class 2 and Class 3.  While Class 3 is reserved for inert and usually naturally occurring material, Class 2 is often the most accurate classification for non-hazardous industrial waste.

Compared to Class 1 wastes, Class 2 waste offers the following advantages:

  •  Less expensive, more disposal options
  • Does not require an EPA Hazardous Waste manifest
  • Does not require reporting an Annual Waste Summary report
  • Does not require a generator to register with the TCEQ

With its many advantages, why don’t more generators use the Class 2 waste code?  While some may argue that the documentation needed to justify the classification is more onerous, in reality the same documentation that is required to prove a waste is Class 1 non-hazardous will also demonstrate the waste meets the criteria for Class 2.  The real reason for its scarcity is often a simple lack of knowledge that Class 2 is even an option.  Once a generator understands the definition and applicability of the Class 2 waste code, though, they will find it to be the useful tool that the TCEQ originally intended it to be.

W&M appreciates this guest article from Russell Ide at Valley Solvents and welcomes other articles on environmental topics from our readings from time to time.  For more information, contact Lance French at W&M Environmental at Lance French and for more information on waste handling or Valley Solvents, contact Russell Ide at [email protected].

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