California Hazardous Waste Generators: Complete Your Source Reduction Documents by September 1st, 2023

Did your facility generate more than 12,000 kilograms (kg) of hazardous waste or more than 12 kg of extremely hazardous waste in California during 2022? If so, then you might be required to prepare Hazardous Waste Source Reduction and Management Review Act of 1989 (SB 14) documents by September 1, 2023. A generator of hazardous or extremely hazardous waste is subject to a fine of $1,000 per day for failure to provide the required source reduction documents upon request.

WHAT IS SB 14?

SB 14 was passed to reduce the generation of hazardous waste at its source, reduce the release to the environment of chemicals that have adverse and serious health or environmental effects and document hazardous waste management information. SB 14 applies to a generator that routinely generates:

• More than 12,000 kg of hazardous waste in a reporting year
• More than 12 kg of extremely hazardous waste in a reporting year.

REQUIRED SB 14 DOCUMENTS

Since September 1, 1991, SB 14 has required generators to prepare documents every four years when the generation of hazardous waste exceeds the threshold during a reporting year. SB 14 requires the following:

• Preparation of three Hazardous Waste Source Reduction documents,
• Report Federal RCRA hazardous waste totals generated in the current reporting year, and
• Report non-RCRA California-only hazardous generated in current reporting year.

For generators subject to SB 14 the following documents must be prepared by September 1, 2023:

1. A source reduction evaluation review and plan (“Plan”),
2. A hazardous waste management performance report (“Performance Report”), and
3. A summary progress report (”Progress Report”).

The Plan is a forward-looking document. The Plan must include an estimate of the quantity of hazardous wastes generated, an evaluation of potential source reduction approaches, a timetable for implementing selected source reduction measures and a four-year numerical goal.

The Performance Report must include an assessment of the effect on waste generation of each waste management approach implemented since the base-line year. Base-line year is the prior reporting year and is the year which the generator compares the current Reporting Year’s hazardous waste generation to. This year, generators will compare the current Reporting Year’s hazardous waste generation to 2018 reporting year.

The Summary Progress Report summarizes the result of implementing the source reduction measures identified in the generator’s previous Plan and the amount of reduction that the generator anticipated will be achieved by the implementation of source reduction selected in the current Plan.

While qualifying generators must complete all three SB 14 documents, the law no longer requires generators to submit these documents to the Department of Toxic Substance Control (DTSC). The generator must retain copies of the Plan, Performance Report, and SPR on-site and have the documents readily available for on-site review by DTSC or the Certified Unified Program Agency (CUPA) during inspection.

For any questions regarding this information, please contact Peyton Rodgers at prodgers@all4inc.com. Additionally, contact Meredith Garrett at mgarrett@all4inc.com to find out how ALL4 can help you.