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a solid or hazardous waste complaint to the DNR.
Contact information
For information about managing hazardous waste, contact:
Mike Ellenbecker
Hazardous waste program coordinator

Frequently asked questions about hazardous waste

How much waste may a facility accumulate in one satellite accumulation area (SAA)?

The satellite accumulation rules allow generators to accumulate up to 55 gallons of hazardous waste or 1 quart of acute hazardous waste in containers at or near any point of generation and under the control of the operator, provided the generator complies with the satellite accumulation requirements in s. NR 662.034(3) or 662.192(4) Wis. Adm. Code.

When the total volume of hazardous waste in the SAA exceeds the limit , the container must be labeled with the date the excess accumulation was reached. Within three days of that date, the container must be moved to a central hazardous waste storage area.

The satellite accumulation rules require containers to be in good condition, compatible with the waste, stored closed (unless adding or removing waste), and labeled as hazardous waste or with other words identifying the contents.

Can more than one type of waste be stored in a SAA?

Yes. The hazardous waste rules do not limit the number of hazardous wastes or the number of containers that may be placed in a SAA. However there are limits on the total volume of hazardous waste that may be stored in an SAA.

Can a facility have more than one satellite accumulation area (SAA)?

Yes. There are no limits on the number of SAAs allowed at a facility and no limit on the total amount of hazardous waste that may be accumulated across a facility. However, within each SAA there are limits.

If a facility has multiple SAAs, can hazardous waste be moved from one to another?

No, generators may not move hazardous wastes between SAAs. Once a hazardous waste leaves an SAA, it must be moved to a central hazardous waste storage area.

Can SAAs be located near one another?

Yes, as long as the SAAs are separate, are at or near the point of generation, and are under the operators' control. For example, a container of paint gun cleaner may be in one SAA and be located near a container of paint booth filters, which is in another SAA, as long as they are at or near the points of generation and under the control of the operators.

My company shrink-wraps multiple hazardous waste containers on one pallet for transportation. Does each container need to be labeled or will one label on the shrink-wrapped pallet suffice?

All containers must be labeled. According to federal Department of Transportation (DOT) rules in 49 CFR 173.25, a shrink-wrapped or stretch-wrapped pallet of containers is considered an over-pack container. Prior to shipping the shrink-wrapped pallet off-site, each container must be marked and labeled according to the applicable DOT requirements in 49 CFR Part 172. If individual container labels are clearly visible, then labeling the outside of the shrink-wrapped pallet is not required.

For more information on DOT hazardous material requirements, call the DOT Information Hotline at 1-800-467-4922.

My company punctures aerosol cans on-site. Is a hazardous waste facility license required for this activity?

If the aerosol can or residue inside is intended to be recycled or reclaimed, then puncturing the containers to collect the residue is considered a step in the recycling process and is not subject to hazardous waste treatment facility licensing requirements.

The drum or container used to collect the liquid residue from the cans is regulated as a satellite accumulation container and the requirements in s. NR 662.034(3), Wis. Adm. Code, apply. Refer to the questions above on satellite accumulation areas for more information.

Empty aerosol cans may be reclaimed as scrap metal. They are considered "empty" if no more than 3 percent of the original net weight of the can or not more than 1 inch of liquid residue remains in the can. (Shake the can. If it feels like 1 inch or less of liquid remains, it should meet this standard.) The residue collected from the drained cans may be recycled off-site for fuel blending or burned with energy recovery.

Aerosol Cans: Guide to Handling and Disposal (WA-1784) [PDF]

Is off-specification (off-spec) gasoline used as a fuel or burned for energy recovery in a fuel blending program regulated as hazardous waste?

In general, a material that is recycled by being used to produce a fuel or burned for energy recovery is regulated as solid waste, and has the potential to be hazardous waste. However, commercial chemical products that are themselves fuels are not regulated as waste. Therefore, off-spec gasoline used as a fuel or burned for legitimate energy recovery is not regulated as a hazardous waste.

Generally, fuel burned for legitimate energy recovery should have a heat value of at least 5,000 BTU per pound. Burning a material with a BTU value lower than 5,000 BTU per pound or burning a material without energy recovery may be considered disposal of hazardous waste, rather than legitimate energy recovery. When determining the regulatory status of fuel under s. NR 661.02(3)(b)2., Wis. Adm. Code [exit DNR], no distinction is made between different types of burning for energy recovery.

Mixtures of fuel and other non-fuel materials are not eligible for the exclusion if the non-fuel materials (e.g., fuel-contaminated absorbents, soil or rags from a fuel spill cleanup) themselves do not have a heat value of at least 5, 000 BTUs.

Notes: For the purpose of defining a solid waste, the U.S. Environmental Protection Agency has expanded the definition of commercial chemical product to include chemicals that exhibit a hazardous characteristic as well as other unused commercial products that exhibit a characteristic of hazardous waste. See the discussion in section 2.2 of the Resource Conservation Recovery Act Training Module, Definition of Solid and Hazardous Waste Recycling for additional explanation. In this case, the DNR follows EPA guidance.

The Feb. 19, 1999, RCRA online document, Faxback 14503 [exit DNR], discusses the applicability of the exclusion to non-fuel materials.

If waste listed as universal waste is not recycled, may it still be managed as universal waste?

Yes, the universal waste rules in ch. NR 673, Wis. Adm. Code, and the August 2006 Wisconsin-Specific Universal Waste Guidance Memo allow reduced hazardous waste management standards for hazardous waste batteries, certain pesticides, mercury thermostats and mercury containing equipment, antifreeze and fluorescent lamps.

The universal waste rules and associated guidance are intended to facilitate collection and proper management of these items; however, they do not have to be recycled to qualify as universal waste.

How long can my recycling facility store universal waste from the time it is received?

Within 24 hours of receiving a shipment of universal waste, the shipment must either enter the recycling process or be moved to a licensed hazardous waste storage area.

An incoming shipment of hazardous waste or universal waste is being "stored" if the shipment has not entered the recycling process within 24 hours of receipt. Although the recycling process itself is conditionally exempt from hazardous waste regulation, universal waste destination facilities are subject to the same requirements as fully regulated hazardous waste Treatment, Storage and Disposal facilities (TSD). Therefore, facilities that store universal waste for longer than 24 hours must obtain a hazardous waste storage facility license.

Are hazardous waste generators allowed to keep electronic copies of manifests?

Yes, businesses and institutions that generate and ship hazardous waste off-site may keep copies of manifests in an electronic format to comply with the recordkeeping requirements in ss. NR 662.040, 662.193 or 662.220, Wis. Adm. Code. Manifest records must be kept on-site for at least three years and be easily accessible for review.

Is a company allowed to transport small amounts of used oil?

A generator may self transport used oil to an aggregation point [NR 679.01(13), Wis. Adm. Code] without having an EPA identification number, department solid waste transportation license, or otherwise complying with used oil transporter standards, only if the generator complies with the following conditions [NR 679.24(2)]:

  1. the generator transports the used oil in a vehicle owned by the generator, or an employee of the generator;
  2. the generator transports no more than 55 gallons of used oil at any time; and
  3. the generator transports the used oil to an aggregation point that is owned or operated by the owner or operator of the generator's site.

If a generator who self-transports used oil does not meet these conditions, the generator would be fully regulated as a used oil transporter per subchapter E of chapter NR 679.

Aggregation points must comply with the standards for used oil generators in subchapter C of NR 679. An aggregation point may be eligible for the reduced requirements for on-site burning in space heaters in NR 679.23. An aggregation point that does not meet the conditions in NR 679.23 may only burn on-specification used oil in a space heater, and would normally be subject to the used oil fuel marketer standards in subchapter H of NR 679. For more information, see our Burning Used Oil in a Space Heater (WA-1003) [PDF]publication.

What is pharmaceutical reverse distribution, and what materials can they accept?

The reverse distribution system is a means to facilitate the return of and credit for pharmaceutical products. Health care providers, such as pharmacies, clinics, hospitals and veterinary clinics, can send unused products to a reverse distributor in order to receive credit from the manufacturer. Because the product is considered to have value, it is not regulated as a waste. Reverse distributors can also accept Drug Enforcement Agency (DEA) controlled substances, as long they have not been distributed to the end user.

Only pharmaceuticals that are eligible for credit should be sent to the reverse distributor. Reverse distributors are not waste management facilities and are not allowed to accept waste or waste-like materials, such as partial packages, compounded IVs, broken or spilled materials, patient's personal medications or samples from pharmaceutical representatives. Review the returned drug and waste drug reports and discuss credit rejections with the reverse distributor. Products that are never eligible for credits must be properly managed as a waste, and not sent to a reverse distributor.

The DNR's Guidance for Safe Management of Household Pharmaceuticals (WA-1052) [PDF] allows reverse distributors to accept pharmaceutical waste from household collection events (Clean Sweeps). Under the terms of the guidance, reverse distributors may not accept controlled substances or any waste from businesses or institutions which may have brought their waste or unused pharmaceuticals to a collection event. All collected pharmaceuticals must be managed in accordance with the guidance memo.

Reverse distributors must properly manage any hazardous waste that is generated as part of their business activities or accepted from household collection events. For more information on the hazardous waste rule requirements, see the NR 600 series administrative rules [exit DNR]

For more information on collecting pharmaceuticals, visit the health care waste pages.

Can health care facilities use drug disposal units to dispose of unwanted medications?

Yes. The DNR allows health care facilities to use drug disposal units, such at the Drug Buster, to minimize drug diversion or unintended ingestion of medications.

The disposal units usually contain charcoal or other proprietary chemicals that render the drugs unusable but do not change the chemical structure of the drugs. Therefore, the units must be disposed of as hazardous waste if the drugs that are placed in the container are listed hazardous waste. If characteristic hazardous waste has been placed in the unit, the health care facility must determine if the drug disposal unit is a characteristic hazardous waste. Generators who treat characteristic hazardous waste by using these units are not subject to hazardous waste licensing requirements as long as the requirements in s. NR 670.001(3)(b)11, Wis. Adm. Code [exit DNR], are met.;

Drug disposal units that are hazardous waste must be managed by a licensed or permitted hazardous waste treatment, storage or disposal facility. It may be possible to dispose of the units with other hazardous waste generated at the health care facility.

If the drug disposal units are determined to be a nonhazardous waste, the DNR recommends they be disposed of by incineration.

Note that the management of certain medications is also regulated by the U.S. Drug Enforcement Administration [exit DNR].

What are Wisconsin's hazardous waste regulatory requirements for reclamation of precious metal-containing wastes?

Hazardous wastes that contain significant amounts of precious metals - gold, silver, platinum, palladium, iridium, osmium, rhodium or ruthenium - are subject to the hazardous waste requirements in NR 666 subch. F, Wis. Adm. Code [exit DNR], if they are reclaimed. An example of a precious metal-containing waste is photographic fixer solution, which contains silver.

Precious metals are valuable commodities, and businesses usually handle them carefully. In an effort to encourage legitimate recycling, the requirements for handling precious metal waste that are reclaimed are less stringent than for some other types of hazardous waste.

Under NR 666 subch. F, Wis. Adm. Code, businesses that generate or transport wastes containing precious metals for reclamation must:

Businesses that store precious metal-containing wastes must:

  • obtain an EPA ID number from the DNR using EPA Form 8700-12 [exit DNR];
  • comply with the manifest requirements in sections NR 665.0071 and NR 665.0072, Wis. Adm. Code [exit DNR];
  • comply with the import/export requirements in chapter NR 662, Wis. Adm. Code [exit DNR], if waste is exported to or imported from another country for reclamation; and
  • keep the following records to show that at least 75 percent of these wastes received or generated on-site each year are reclaimed within the year (and are not speculatively accumulated):
    • the amount of the materials stored at the beginning of the calendar year;
    • the amount of the materials generated or received during the calendar year; and
    • the total amount of materials remaining at the end of the calendar year.

Note: The quantity of precious metal containing waste generated counts towards the generator status since it is regulated as a hazardous waste. If the above reduced requirements are met, other requirements in chs. NR 662 to 665 and ch. NR 670, Wis. Adm. Code, do not apply. For example, containers of precious metal containing wastes destined for reclamation are not required to be labeled as hazardous waste, marked with the date of accumulation or inspected weekly. However, precious metal waste must be included in the hazardous waste annual report (only required for large quantity and small quantity generators). Transporters are not required to obtain a hazardous waste transportation license to transport precious metal-containing wastes that will be reclaimed.

Last revised: Wednesday May 04 2016