Date:Mon, 05 Mar 2001 10:44:16
My response to your question: 1. If your printer is dealing with ink that is nonhazardous there is no need to worry about being bumped into the next generator status. You can haul out as much nonhazardous waste as you want. 2. If the ink is hazardous and the one time amount will bump them into a higher status, the company needs to fill out a Notification of Regulated Waste Form. This form is submitted to the IEPA and they in turn send it to the Feds. Also, if the company is going from a Conditionally Exempt Small Quantity Generator to Small Quantity Generator, they will need to fill for state and federal I.D.s. The Notification of Regulated Waste Form is not your one time pass card. IEPA and EPA does not provide for any exceptions for one time large waste disposal. But the company can, thereafter, notify IEPA via phone or more preferably certified letter, telling them that they no longer qualify at the higher generator status. Basically, you are going through filings to register from one status and then back to your original status. At least companies can go back to their generator status and are not forever be placed at a higher generator status. This we want to avoid because of the added regulatory burdens at a higher generator status. Someone talked about ink waste bring considered as Universal Waste. Here in Illinois, all industrial waste is under Special Waste. IEPA did list out ink cans under Universal Waste, as long as, you met certain conditions,but not the ink waste itself.