Waste Compliance Fundamentals for Data Centers

Data Centers are hardware-intensive, fast-evolving operations with regulated materials moving through them every day. Some of the more common compliance risks arise from the wastes they generate: electronic waste (including printed circuit boards); batteries; coolants and oils, such as propylene glycol and transformer oil; and contractor-managed materials. Organizations can mitigate risk through comprehensive physical asset management, robust contractor work-plan evaluations, and vendor alignment with federal and state regulatory frameworks.

Electronic Waste (E-Waste):

Rapid refreshes (e.g., servers, cooling gear, printed circuit boards) generate waste streams that can pose a hazard to the public or the environment if not managed appropriately. Federal regulations allow for many exemptions from the solid waste requirements, such that the generator manages the material properly. As an example, 40 CFR 261.4(a)(14) classifies shredded printed circuit boards sent for recycling as excluded from the solid waste definition, provided they are stored to prevent releases and all mercury-containing components and nickel-cadmium (Ni-Cd) or lithium batteries are removed for separate recycling or disposal, and that removal is documented before shredding.

States can manage waste more strictly than what Federal rules require, creating variability in requirements for data centers. California classifies numerous e-waste items as a special classification subject to particular handling obligations. The state oversees the disposal of “covered electronic devices” pursuant to the Electronic Waste Recycling Act (EWRA). The program, enacted in 2003, is administered by CalRecycle and mandates compliance with specific procedures for notifications, waste management, and reporting. New York’s Department of Conservation (NYSDEC) modernized its Electronic Equipment Recycling and Reuse rules in 2022, strengthening manufacturer take-back responsibilities. These state-specific programs shape what facilities can store and ship and often restrict landfill disposal while encouraging proper management of materials through recycling.

Batteries:

Federally, most batteries can be managed as Universal Waste (40 CFR Part 273), simplifying labeling and accumulation, as long as the batteries remain intact. Although batteries can be shipped and disposed of as Universal Waste, they are still considered hazardous. Universal wastes are considered hazardous because they can harm human health and the environment if not handled properly. The universal waste category was established to simplify the collection, management, and recycling of these waste materials for businesses and households.

The handling of hazardous materials is regulated under the Pipeline and Hazardous Materials Safety Administration (PHMSA)’s Department of Transportation (DOT) Hazardous Materials Regulations (49 CFR 171 through 180). These regulations provide handlers with a guide for safe packaging requirements for hazardous materials. As the amount of materials increase along with their hazardous properties, the packaging requirements also become stricter. The packaging for damaged, defective, or recalled (DDR) lithium batteries can be found under 173.185(f), as well as guidance from recent PHMSA interpretations. In California, AB 2440 (Responsible Battery Recycling Act of 2022) on battery stewardship and SB 1215 (Covered Battery-Embedded Products) are phasing in producer programs and fees. As states roll out battery extended producer responsibility (EPR), facilities can expect evolving take-back options through original equipment manufacturers (OEM) and state programs. These programs aim to lower disposal costs but require enrollment with approved vendors and maintain the strict shipping and packaging requirements by DOT.

Propylene Glycol Coolants/Antifreeze:

Data Centers that generate waste spent propylene glycol (PG) or dielectric fluids are responsible for properly characterizing these waste streams under federal and local hazardous waste regulations, often using U.S. Environmental Protection Agency (U.S. EPA)-approved methods such as the toxicity characteristic leaching procedure (TCLP) to determine if they exhibit toxicity. Effective waste characterization through the review of analytical results, Safety Data Sheets (SDS), or process knowledge is key in maintaining a safe, clean work environment and preventing unnecessary accumulation of materials and waste. Mischaracterizing the waste can lead to U.S. EPA violations and while transport, disposal, and recycling companies may perform their own analyses, the generator of the waste retains primary responsibility for accurate waste characterization.

Coolants and antifreeze, typically used in engines, often contain metals and additives that may push them into the “hazardous waste” category under the Resource Conservation and Recovery Act (RCRA). Even if a waste stream determination shows non-hazardous, it is important to maintain the waste analysis results and re-test after chemical or process changes.

State nuances include: California frequently treats used antifreeze and coolants as state-hazardous; Washington regulates spent antifreeze as dangerous waste unless properly recycled, which can reduce generator counts; Massachusetts requires generator determinations and encourages recycling with periodic checks. Oregon, Colorado, and New York’s aggressive e-waste frameworks often coincide with closer scrutiny of coolants during decommissions.

Generator Responsibility:

Under RCRA’s cradle-to-grave system, the generator (by site) is responsible, even when contractors create waste on facility property. Tighten contracts to assign removal and manifest authority and manage any contractor-left drums within on-site accumulation standards according to your facility’s hazardous waste generator category.

Compliance Recommendations:

• Use universal waste rules where allowed;
• Remove batteries and mercury components before printed circuit board shredding;
• Maintain current lab-backed profiles for PG and other coolant fluids, using closed-loop recycling when available;
• Vet transporters and recyclers for permits and financial assurance; and
• For lithium shipments, follow 40 CFR 173.185, treating DDR units as a distinct risk operationally.

If you have any questions about waste-related requirements at your data center or the actions your facility should take next, please contact me at ccodington@all4inc.com. ALL4 is available to assist with waste evaluations, program enhancements, and any other environmental compliance needs your facility may have.