Hazardous Waste Storage And Disposal Compliance: Cleaning Up Without Creating New Problems

Waste is where good intentions get tested

Brands spend energy designing packaging, labeling products correctly, and planning safe shipments. Then a pallet tips, a carton leaks, or a return arrives in bad shape, and suddenly the conversation shifts from shipping to waste. Hazardous waste storage and disposal compliance determines whether that messy moment stays small or grows into a regulatory problem.

Under the Resource Conservation and Recovery Act, or RCRA, EPA regulates hazardous waste from cradle to grave. The rules live in 40 CFR Parts 260 through 273. They define when a material becomes a hazardous waste, how generators are categorized, how long waste can stay on site, and what records and labels must follow it. Once a product is no longer usable and is destined for disposal, the rules change dramatically.

When products become hazardous waste

A product becomes hazardous waste when you decide it cannot be sold or used and must be discarded. EPA's definitions in 40 CFR Part 261 classify wastes by lists and characteristics. Many everyday materials qualify once they spill, expire, or get contaminated. Paints, solvents, sealants, coatings, and damaged lithium batteries often meet ignitable, corrosive, reactive, or toxic criteria.

Director of Vendor Operations Kay Hillmann sees this shift constantly. "We are certified in all hazardous materials. We were looking at a matches company, that is a hazardous material. We ship concrete sealant, that is hazardous, a different classification. Paint, your everyday paint you get from a home center, that is hazardous material. Flammables, like gas power generators, that is hazardous material. Perfumes, alcohol." When those goods break or leak, they move from product to waste, pulling RCRA rules with them.

Generator categories matter more than most founders realize

EPA divides generators into tiers in 40 CFR Part 262: very small quantity generators, small quantity generators, and large quantity generators. Each category comes with different accumulation limits, container rules, inspection requirements, and contingency planning.

A warehouse may sit in a low category most of the year, then jump to a higher one during peak returns season or after a recall. That shift changes how long waste can stay on site and what documentation must follow it. Without monitoring, a 3PL can accidentally exceed limits and trigger enforcement actions.

What compliant hazardous waste storage looks like

Storage rules under 40 CFR Part 265 expect good containers, closed lids, visible labels, clear aisles, and secondary containment where needed. Containers must be marked with the words Hazardous Waste and the accumulation start date. Fire code and OSHA rules add expectations for ventilation, separation, and emergency access.

Director of Operations Holly Woods explains how planning prevents problems. "We have very intensive planning as we get close to a peak timeframe. We run forecast models, staffing models, and we audit inventory, equipment. All of these preparations happen ahead of season just to ensure that we can handle anything that comes our way." That same planning applies to waste. If a facility waits until the floor is messy to design waste areas, it is already too late.

Disposal and documentation: the last step carries big responsibility

Under RCRA's cradle to grave concept, generators retain responsibility until hazardous waste reaches a permitted treatment, storage, or disposal facility. Most generators use licensed hazardous waste transporters and the uniform hazardous waste manifest required under 40 CFR Part 262, Subpart B.

Director of Business Development Matt Bradbury notes that many logistics providers avoid waste entirely by refusing certain hazardous products. "Even our competition, they do not want to touch things that are over 40 or 45 watt hour batteries. Our largest competitor, where I come from, will not touch anything over 40 watt hours." G10 chose a different path, which means understanding how disposal, manifests, and vendor coordination fit into operations.

Why WMS design supports waste compliance

CTO and COO Bryan Wright explains the foundation. "A bad WMS system will not track inventory 100 percent, as it should. A good WMS tracks inventory through the warehouse at every point that you touch it." For hazardous waste, the WMS must capture when sellable product becomes waste, where waste is stored, and how much exists at any time. That data helps determine generator category and accumulation status.

Because Bryan's team built the WMS, they embed waste status changes into workflows: returns processing, spill cleanup, quality checks, and consolidation. Waste is not an afterthought; it is a tracked state that supports compliance.

Training for the messy moments

Hazardous waste appears during stressful situations: spills, breakage, and returns. Hazmat employee training under 49 CFR 172.700 through 172.704 and OSHA's HAZWOPER standard in 29 CFR 1910.120 set expectations for safe handling. Employees must know when waste requires special containment, when spills exceed routine response, and when to involve supervisors or outside responders.

Kay describes G10's approach. "We have been certified by the expert in the country on hazardous materials in all classifications." That level of training helps employees distinguish between recoverable goods and hazardous waste that must be containerized, labeled, and moved to a compliant area.

Why carriers and retailers care about waste

Carriers may not pick up hazardous waste, but they notice when waste practices are sloppy. Leaking cartons on the dock suggest deeper problems. Retailers care because waste violations can trigger shutdowns that interrupt fulfillment. VP of Customer Experience Joel Malmquist focuses on long term growth. "With an up and coming business, I am going to ask you questions. What channels are you trying to get into. How do you see your business growing. How can we help you get there." A waste program that cannot scale limits channel expansion.

Questions founders should ask

If your products generate hazardous waste when damaged or returned, ask your 3PL how waste is classified, labeled, stored, and tracked. Ask about generator category, manifest procedures, and vendor relationships. If answers sound ad hoc, waste risk is closer than it appears.

Turning waste compliance into a sign of operational discipline

Hazardous waste storage and disposal compliance is not glamorous, but it is one of the clearest indicators of a mature operation. Clean waste areas signal that the rest of the hazmat program is strong.

Kay summarizes the mindset. "We follow regulations and guidelines to a T because we want to make sure that we are doing it legally, correctly, and safely." Applied to hazardous waste, that mindset keeps small messes from becoming regulatory problems.

If your returns, spills, or damaged goods are growing, talk with G10 about how disciplined hazardous waste storage and disposal practices can protect your people, your facility, and your growth.