iNFOCUS
United States Solid Waste and EPA530-K-00-002
Environmental Protection Emergency Response September 2000
Agency (5305W) www.i
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FOR MORE INFORMATION CALL:
RCRA Hotline
U.S. Environmental Protection Agency
800 424-9346 or TDD 800 553-7672.
In the Washington, DC, area: 703 412-9810
or TDD 703 412-3323.
@ Printed on paper that contains at least 30 percent postconsumer fiber.
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CONTENTS
Foreword 2
Frequently Asked Questions About RCRA 3
The Life Cycle of a Typical Leather Manufacturing Waste 6
Requirements for Regulated Leather Manufacturers 8
Reduce or Minimize the Hazardous Wastes You Generate 10
Other Environmental Laws Affecting the Leather
Manufacturing Industry 14
Contacts and Resources 16
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FOREWORD
Some processes conducted in your leather manufacturing
facility probably generate hazardous waste. That means you
are regulated by the U.S. Environmental Protection Agency
(EPA) under a federal law called the Resource Conservation and
Recovery Act (RCRA). Under RCRA, you are required to follow
certain procedures when generating, storing, transporting, treating, or
disposing of hazardous waste. RCRA in Focus provides an overview of
the federal regulations you are required to follow and the wastes that are
likely to be hazardous in your business. It also provides recycling and
pollution prevention options to help you decrease the amount of
hazardous waste you generate.
RCRA IN FOCUS
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FREQUENTLY ASKED QUESTIONS
ABOUT RCRA
What Is RCRA?
RCRA is a federal law that encourages environmentally sound methods for managing
commercial and industrial waste as well as household and municipal waste. It regulates facilities that
generate, transport, treat, store, or dispose of hazardous waste. The vast majority of leather
manufacturing facilities are considered hazardous waste generators, rather than treatment, storage,
and disposal facilities (TSDFs), which are subject to more rigorous regulations.
The term "RCRA" is often used interchangeably to refer to the law, the regulations, and EPA
policy and guidance. The law describes the waste management program mandated by Congress that
gave EPA authority to develop the RCRA program. EPA regulations carry out the Congressional
intent by providing explicit, legally enforceable requirements for waste management. EPAguidance
documents and policy directives clarify issues related to the implementation of the regulations.
All of the RCRA hazardous waste regulations can be found in the Code of Federal Regulations
(CFR), Title 40, Parts 260 to 279. The CFR can be purchased through the U.S. Government
Printing Office (GPO).
Who Is Regulated?
Any leather manufacturing facility that generates hazardous waste is potentially subject to RCRA.
You must conduct tests required by the regulations or use your knowledge of and familiarity with
the waste you generate to determine whether it is hazardous waste (as opposed to other types of
waste). You might be subject to substantial civil and criminal penalties if you fail to properly or
completely identify hazardous waste generated by your business.
What Is Hazardous Waste?
To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines
solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids,
liquids, and contained gaseous materials). If your waste is considered solid waste, you must then
determine if it is hazardous waste. Wastes are defined as hazardous by EPA if they are specifically
named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four
characteristics (characteristic wastes). Each type of RCRA hazardous waste is given a unique
hazardous waste code using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039).
See pages 8 to 11 for additional information on leather manufacturing waste codes.
Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human
health and the environment when not managed properly, regardless of their concentrations. The
lists include the following three types of waste:
• Non-Specific Source Wastes. These are material-specific wastes, such as solvents, generated
by several different industries. Waste codes range from F001 to F039. Examples include toluene,
xylene or methyl ethyl ketones.
• Specific Source Wastes. These are wastes from specifically identified industries. Waste codes
range from K001 to K161. Leather manufacturing facilities typically do not generate specific
source wastes
• Discarded Commercial Chemical Products. These are off-specification products, container
residuals, spill residue runoff, or active ingredients that have spilled or are unused and that have
been, or are intended to be, discarded. Waste codes for acutely hazardous chemicals range from
P001 to P205 and U001 to U411. An example is U220, unused toluene.
STATE
REQUIREMENTS
may be regu-
lated both by your
state hazardous waste
agency and EPA. RCRA
allows states to receive
legal permission, known
as authorization, to
implement the RCRA
hazardous waste pro-
gram. You must always
contact your state
authority to determine
which state require-
ments apply to your
business.
To operate a haz-
ardous waste program, a
state's regulations must
be consistent with, and
at least as stringent as,
the federal program.
Some states adopt more
stringent requirements
for facilities handling
hazardous waste, which
are considered part of
the authorized program.
MORE
QUESTIONS?
Call the RCRA
Hotline at
800 424-9346 or TDD
800 553-7672 for addi-
tional information about
RCRA rules and regula-
tions. In the Washington,
DC, area, call 703 412-
9810 or TDD 703 412-
3323.
LEATHER MANUFACTURING
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AM I REGULATED
BY RCRA OR
SUPERFUND?
RCRA regulates the
treatment, storage,
and disposal of hazardous
waste being generated
now and in the future.
Superfund was created to
pay for the identification,
inspection, investigation,
ranking, and cleanup of
abandoned or uncon-
trolled hazardous waste
sites that people respon-
sible for contamination
are unable or unwilling
to clean up. Call the
RCRA Hotline for more
information.
Characteristic Wastes. Even if your waste does not appear on one of the hazardous waste lists, it still
might be regulated as hazardous waste if it exhibits one or more of the following characteristics:
• Ignitability. Ignitable wastes create fires under certain conditions or are spontaneously
combustible, and have a flash point less than 60 °C (140 °F). An example is spent solvents from
retanning and dyeing operations. The waste code for these materials is D001.
• Corrosivity. Corrosive wastes are acids or bases that are capable of corroding metal containers,
such as storage tanks, drums, and barrels. Tanning waste is a good example. The waste code for
these materials is D002.
• Reactivity. Reactive wastes are unstable under "normal" conditions. They can cause explosions,
toxic fumes, gases, or vapors when mixed with water. Examples include lithium-sulfur batteries
and explosives. The waste code for these materials is D003.
• Toxicity. Toxic wastes are harmful or fatal when ingested or absorbed. When toxic wastes are
disposed of on land, contaminated liquid might drain (leach) from the waste and pollute ground
water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic
Leaching Procedure (TCLP). Certain chemical wastes and heavy metals generated from dyeing
leathers are examples of potential toxic wastes. The waste codes for these materials range from
D004 to D039.
How Are Generators Regulated?
If your leather manufacturing business generates hazardous waste, you must manage it according
to regulations for your specific generator type. Hazardous waste generators are divided into three
categories, according to how much they generate in a calendar month:
• Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg
(approximately 2,200 Ib) of hazardous waste per month or greater than 1 kg (approximately 2.2
Ib) of acutely hazardous waste per month.
• Small Quantity Generators (SQGs). SQGs generate greater than 100 kg (approximately 220
Ib) but less than 1,000 kg (approximately 2,200 Ib) of hazardous waste per month.
• Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less than
or equal to 100 kg (aproximately 220 Ib) of hazardous waste per month and less than or equal to
1 kg (approximately 2.2 Lb) of acutely hazardous waste per month.
Some states do not recognize the CESQG class. Contact your state environmental agency to find
out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA
Hotline at 800 424-9346.
Under the federal RCRA requirements, your generator status might change from one month to
the next as the quantity of waste you generate changes. State requirements vary widely. You must
comply with whichever standard is applicable for a given month. In many cases, small businesses
that fall into different generator categories at different times choose to always satisfy the more
stringent requirements (usually state requirements) to simplify compliance. Generators must
"count" the amount of waste generated, which involves adding up the total weight of all quantities
of characteristic and listed waste generated at a particular facility. Certain wastes, such as those that
are reclaimed or recycled continuously on site, are not counted under the federal regulations.
RCRA IN FOCUS
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Do Exclusions Exist?
The RCRA regulations contain many exclusions for wastes and waste management practices that
are not considered to be hazardous. Several exclusions and exemptions pertain specifically to the
leather manufacturing industry. Some states, however, do not recognize the federal exclusions.
Exclusions and Exemptions Description
Domestic Sewage Exclusion
Wastewater Treatment Unit
Exemption
Trivalent-Chromium
Exclusion
Elementary Neutralization
Unit Exemption
De Minimis Exclusion
Mixtures of domestic sewage and other wastes that pass
through a sewer system to a publicly owned treatment works
(POTW) for treatment are excluded from the definition of
solid waste. Generators are encouraged to contact their local
POTW for prior approval.
Any tank system used to store or treat wastewater that is part
of an onsite wastewater treatment facility with a National
Pollutant Discharge Elimination System (NPDES) permit or
that discharges to a POTW is exempt from the RCRA regu-
lations.
Many wastes from leather tanning and finishing operations
containing trivalent-chromium wastes are excluded from the
definition of hazardous waste. These excluded wastes are
listed in 40 CFR 261.4 (b)(6).
Tanks used for neutralizing waste that is hazardous solely
because of its corrosive characteristic are excluded from the
permitting requirements. Waste treated in these units is not
considered hazardous while in the units.
Small quantities of some solvents and other chemicals are
exempt from the regulations when they are mixed with
wastewater in a wastewater treatment system discharging
according to the Clean Water Act.
LEATHER MANUFACTURING
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THE LIFE CYCLE OF
A TYPICAL LEATHER
MANUFACTURING
WASTE
Yiu've just completed some leather finishing and
re left with solvent wastes that must be managed
ccording to RCRA. This example details one typi-
cal leather manufacturing waste life cycle and illustrates a
common scenario of activities you would conduct as an
environmental manager. This example shows an LQG
leather mill generating hazardous waste spent solvents and
sending them offsite for treatment. Other waste life cycles
could be different depending on the waste, the type of
waste management units used, and the facility generator
status.
IDENTIFY WASTE
First identify whether your
leather manufacturing waste
is hazardous by running tests
or using knowledge of the
waste. Based on these analy-
ses, determine if the appropri-
ate RCRA hazardous waste
codes for the spent solvents
generated by your leather
manufacturing process are
D001 or F001 through F005.
COUNT WASTE
Next, determine how much
spent solvents you have pro-
duced in a calendar month.
You do not need to count
wastes discharged in compli-
ance with the Clean Water
Act directly to a public sewer
leading to a PO'l'W or waste
recycled only in an onsite
process subject to regulation,
without first being stored or
accumulated.
PREPARE BIENNIAL
REPORT
You must submit a biennial
report of waste generation
and management activities,
as well as waste minimiza-
tion activities, by March 1 of
every even-numbered year.
SEND WASTE OFF
SITE FOR
TREATMENT,
STORAGE, OR
DISPOSAL
Using a registered haz-
ardous waste transporter,
send the waste to a RCRA
hazardous waste TSDF
accompanied by the appro-
priate manifest. You can
choose from any permitted
or interim status TSDF.
Options for solvents
include a hazardous waste
incinerator that will landfill
the incinerator ash, a haz-
ardous waste fuel blender
that will blend the solvents
with other wastes and then
burn them for energy
recovery in a boiler or
industrial furnace, or a
facility that will recycle
the solvents.
RCRA IN FOCUS
PREPARE
APPROPRIATE
NOTIFICATION AND
CERTIFICATION
Ensure that all hazardous
waste sent off site for treat-
ment, storage, and disposal is
accompanied by appropriate
notifications and certifica-
tions (initial shipments only).
PREPARE
HAZARDOUS WASTE
MANIFEST
Send a manifest along with all
hazardous waste sent off site
to a TSDF. Be sure to receive
a completed copy of the man-
ifest from the TSDF and keep
a copy on site for 3 years. The
manifest contains a certifica-
tion stating that you have a
program in place to reduce
the volume and toxicity of
waste generated to the degree
economically practicable, and
that you have selected a treat-
ment, storage, and disposal
method currently available
that minimizes current and
future threats from the waste.
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DETERMINE
GENERATOR STATUS
Add together all hazardous
wastes to determine your
generator status. In this
case, you have produced
more than 1,000 kg (2,200
Ib) in the past month,
which means you are a
LQG in this calendar
month. If the amount of
waste you generate fluctu-
ates from month to month,
you may wish to satisfy the
more stringent require-
ments each month to sim-
plify compliance.
OBTAIN EPA
IDENTIFICATION
NUMBER
To identify your business as a
hazardous waste generator,
obtain an EPA identification
number by submitting Form
8700-12 (Notification of
Regulated Waste Activity),
which is obtained from your
state hazardous waste agency.
Remember, your state
requirements might be
different.
PLACE WASTE IN
ACCUMULATION
UNIT
When the waste is generated,
place it in an appropriate
accumulation unit (e.g., a
tank or container) that meets
the design and management
requirements for that type of
unit. Mark accumulation
containers with the date the
waste was placed in the unit;
mark accumulation tanks and
containers with the words
"Hazardous Waste." Do not
accumulate wastes onsite for
more than 90 days.
IMPLEMENT LQG
EMERGENCY
PROCEDURES
REQUIREMENTS
Check to be sure that emer-
gency preparedness and pre-
vention requirements are
met. These include identify-
ing an emergency response
coordinator and notifying
local emergency response
authorities.
FOLLOW U.S.
DEPARTMENT OF
TRANSPORTATION
(DOT) PACKAGING
STANDARDS
Before shipping waste off site
for treatment, storage, or dis-
posal, package, label, and
mark waste containers in
accordance with all applicable
DOT requirements. For
more information, call the
DOT Hotline at 800 467-
4922.
CONTRACT WITH
HAZARDOUS WASTE
TRANSPORTER
To send waste off site to a
TSDF, contract with a regis-
tered hazardous waste trans-
porter. To locate a reliable
transporter, contact a col-
league to obtain a reference.
IMPLEMENT
PERSONNEL
TRAINING
Train facility personnel in
accordance with standards
within 6 months of the
applicability of the hazardous
waste regulations. Training
teaches personnel about haz-
ardous waste management
procedures and emergency
response. You must under-
take an annual review of ini-
tial training and keep records
of personnel training until
facility closure.
PREPARE
CONTINGENCY PLAN
Ensure that a contingency
plan is prepared in accordance
with standards, to minimize
hazards from fire, explosions,
and unplanned releases. Keep
a copy of the contingency
plan on site.
LEATHER MANUFACTURING
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REQUIREMENTS FOR REGULATED LEATHER MANUFACTURERS
The following table presents an overview of the federal RCRA regulatory requirements for leather manufacturers that are either LQGs, SQGs, or CESQGs. As noted, your
state might have different or more stringent requirements.
REGULATORY
REQUIREMENT
EPA Identification
Number
Hazardous Waste
Identification
Used Oil Standards
Waste Counting
Accumulation Area
RCRA REGULATORY REQUIREMENTS
LQGS SQGS CESQGS IMPLEMENTATION EXPLANATION
Other Accumulation
Areas (Time and
Quantity Limits)
Storage Unit
Requirements
Air Emissions
Preparedness and
Prevention
Obtain an EPA identification number for each facility within your company. EPA and states use this 12-character identification number
to track hazardous waste activities.
Obtain an EPA identification number by submitting Form 8700-12 (Notification of Regulated Waste Activity), which is provided by your
state hazardous waste agency. This is a one-time notification. Contact your state regarding the need for renotification if circum-
stances at your facility change.
Identify whether you generate hazardous waste to determine if you are subject to the RCRA hazardous waste regulations. Test pro-
cedures are described in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, SW-846" or tests can be per-
formed by a local laboratory.
If you generate used oil, you are subject to a separate set of management standards from the hazardous waste management stan-
dards, if the used oil will be recycled. If the used oil is to be treated and disposed of, perform the hazardous waste identification step
listed above.
Determine how much hazardous waste you generate to determine your generator status.
You can accumulate waste in a "satellite accumulation area" with minimal regulatory burden. This area must be at or near the point of
generation and under the control of the operator of the process generating the waste.
There is no time limit on accumulation in the satellite accumulation area for waste under 55 gallons.
There is a 55-gallon accumulation limit in the satellite accumulation area. Excess waste beyond the 55-gallon limit must be moved
from the satellite accumulation area within 3 days.
You must accumulate the waste in containers.
Waste containers must be marked with the words "Hazardous Waste" or other words that identify their contents.
This waste is exempt from other accumulation provisions while in the satellite accumulation area.
If waste accumulation does not meet the requirements for satellite accumulation, it is subject to more stringent requirements. LQGs
can accumulate waste on site for up to 90 days without a permit. SQGs can accumulate waste for 180 days, or 270 days if the SQG
must transport the waste more than 200 miles to a destination facility.
Begin counting accumulation time when waste is first placed in the accumulation unit.
Waste must be put in an exempt unit, recycled, or sent off site within the proper time period stated above.
If an LOG accumulates wastes beyond the allotted time period, the facility is fully subject to the requirements of a hazardous waste
storage facility unless granted an exemption. SQGs cannot accumulate more than 6,000 kg of hazardous waste at any time.
CESQGs cannot accumulate more than 1,000 kg of hazardous waste, more than 1 kg of acutely hazardous waste, or 100 kg of spill
residue from acutely hazardous waste at any time.
Accumulate waste only in units that are in good condition, remain closed except when adding or removing waste, are inspected at
least weekly, are compatible with the types of waste, and meet special standards for ignitable waste and incompatible waste.
LQGs can use accumulation tanks and containers that have been assessed for integrity, have a secondary containment system, and
are inspected each operating day. SQGs can use certain accumulation tanks as well.
LQGs can use containment buildings as well.
For all units, the date that the accumulation period begins must be clearly marked and visible on each container. All containers and
tanks must be clearly marked or labeled with the words "Hazardous Waste" and accumulation units must be shut down and closed
permanently in accordance with standards at the end of the unit life.
LQGs and SQGs can treat their waste without a RCRA storage permit in accumulation units that meet standards.
LQGs must comply with organic air emissions requirements.
LQGs and SQGs must comply with preparedness and prevention requirements, including the following:
An adequate internal alarm or communications system.
A device capable of summoning emergency personnel.
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Contingency Plan
Personnel Training
DOT Packaging
Offsite Management
of Waste
Onsite Management
of Waste
Manifest
Land Disposal
Restrictions
Notification
Hazardous Waste
Minimization
Biennial Report
Recordkeeping
Adequate water pressure to operate fire control systems.
Adequate testing and maintenance of all emergency systems.
Access to communication or alarm systems during waste handling activities.
Adequate aisle space for emergency response.
An arrangement with local emergency response authorities.
LOG facilities must prepare a facility contingency plan in accordance with regulations.
The contingency plan must be designed to minimize hazards from fires, explosions, or any unplanned release of hazardous waste or
constituents.
A copy of the contingency plan must be kept on site and an additional copy must be submitted to all local emergency services
providers.
LQGs and SQGs must have an emergency coordinator on site or on call at all times to respond to emergencies.
Emergency response information must be posted next to the telephone.
In the event of a fire, explosion, or release that could threaten human health outside the facility, or when a spill has reached surface
water, the emergency coordinator must notify the National Response Center at 800 424-8802.
LQGs must have a personnel training program in accordance with regulatory standards.
Training must instruct facility personnel about hazardous waste management procedures and emergency response.
Training must be completed within 6 months from the applicability of requirements.
The facility must undertake an annual review of initial training.
SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their
responsibilities.
Before being transported, waste must be packaged, labeled, and marked in accordance with applicable DOT requirements. Call the
DOT hazardous materials information line at 202 366-4488 for information.
Hazardous waste sent off site for handling may only be sent to a hazardous waste TSDF or recycling facility unless otherwise exempt.
CESQGs: See onsite management of waste below.
CESQGs may either treat waste on site, if it qualifies as one of the following types of facilities, or ensure delivery of waste to one of
the following types of facilities: permitted RCRATSDF; interim status TSDF; state-authorized to handle hazardous waste; permitted,
licensed, or registered by state to handle municipal solid waste according to standards; permitted, licensed, or registered by state to
handle nonmunicipal waste; if managed after January 12, 1998, facility is permitted, licensed, or registered by state to handle non-
hazardous waste in accordance with standards; facility beneficially uses or reuses, or legitimately recycles or reclaims its waste; facil-
ity treats its waste prior to beneficial use, reuse, or legitimate recycling or reclamation; or a universal waste handler in accordance
with standards.
Hazardous waste sent off site must be accompanied by a manifest, a multipage form that documents the waste's progress through
treatment, storage, and disposal. It can usually be obtained from your state agency.
The manifest must have enough copies to provide the generator, each transporter, and the destination facility with one copy for their
records and a second copy to be returned to the generator after completion by the destination facility operator.
SQGs that have a contractual agreement with a waste reclaimer that specifies the types and frequencies of shipments do not need to
manifest the wastes if they retain a copy of the agreement in their files.
Waste must meet certain treatment standards under the Land Disposal Restrictions program when waste is land disposed. Waste
must be treated to reduce the hazardous constituents to levels set by EPA or the waste must be treated using a specified technology.
All waste sent off site for treatment, storage, and disposal must be accompanied by appropriate LDR program notifications and
certifications. There are no required forms, but these papers must indicate whether or not wastes meet treatment standards or
whether the waste is excluded from the definition of hazardous or solid waste, or is otherwise exempt.
To encourage generators to produce less hazardous waste, LQGs are required to have a program in place to reduce the volume and
toxicity of waste generated to the degree economically practicable, and must select a currently available treatment, storage, or dis-
posal method that minimizes present and future threats.
LQGs and SQGs must sign a certification of hazardous waste minimization on the manifest.
SQGs must make a good faith effort to minimize waste generation and to select the best available waste management method that
they can afford.
LQGs must submit biennial reports of waste generation and management activity by March 1 of every even-numbered year. EPA,
other agencies, and the public use this information to track trends in hazardous waste management.
LQGs must maintain personnel training records until the facility closes.
LQGs must keep copies of each biennial report for 3 years.
LQGs and SQGs must keep a copy of each manifest for 3 years.
LQGs and SQGs must keep records of test results, waste analyses, and other hazardous waste determinations for 3 years.
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REDUCE OR MINIMIZE THE
HAZARDOUS WASTES You GENERATE
The following
examples show
hazardous wastes
typically generated
by the leather manu-
facturing industry
and provide sugges-
tions for how to recy-
cle, treat, or dispose
of them according to
federal regulations.
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Recycling and pollution prevention measures can significantly reduce your regulatory
burden and may save your business considerable money. This section presents
information on hazardous wastes typically generated by leather manufacturing facili-
ties and provides suggestions for how to recycle them or implement pollution pre-
vention activities. This list might not discuss all chemicals used or wasates produced
by the leather manufacturing industry. Consult the hazardous waste lists and characteristics to deter-
mine if you generate other hazardous wastes.
Only the federal hazardous waste codes are provided here. Your state might have different codes
for some waste streams. You should check with your state hazardous waste authority for additional
waste codes and requirements.
Soaking
High volume of wastewater and suspended solids.
D002 (wastewater).
Filter rinsewater for reuse in process.
Reuse suspended solids as ingredients in organic fertilizer.
Treat wastewaters in a wastewater treatment unit regulated by the Clean Water Act.
Collect hazardous waste and ship using a registered hazardous waste transporter to a
hazardous waste TSDF.
Use washwater from bating process as rinsewater during soaking to reduce water
consumption.
Use efficient washing procedures to reduce wastewater generation.
Reuse filtered rinse water in soaking process.
Reuse suspended solids as ingredient in organic fertilizers.
Hair Removal/Deliming/Bating
Alkaline wastewater, ammonium sulfate, calcium hydroxide, hydrogen sulfide, suspended
solids, and toxic sulfides.
D002 (alkaline wastewaters) and D003 (reactive sulfides).
10
RCRA IN FOCUS
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Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Reuse secondary washes in the soaking process.
Settle out suspended solids for incorporation into fertilizer.
Destroy sulfides in the lime-sulfide solution and washes by air oxidation with a
manganese sulfate catalyst.
After sulfide destruction, use the lime wastewaters to neutralize acid wastes.
Collect hazardous waste and ship it using a registered hazardous waste transporter to a
hazardous waste TSDF.
Treat wastewaters in a wastewater treatment unit regulated by the Clean Water Act.
Flesh hides before hair pulping and sell fleshings for rendering.
Reuse secondary washes in the soaking process.
Incorporate settled suspended solids into fertilizer.
Chromium, acid and alkaline salts, and acids.
D002 (acid and alkaline salts and acids) and D007 (chromium).
Reuse spent chromium as ingredient in pickle solution.
Reprocess spent chromium for reuse in tanning process.
Neutralize acid wastewaters with liming/unhairing/deliming liquors which have first been
aerated to treat sulfide.
Treat wastewaters in a wastewater treatment unit regulated by the Clean Water Act.
Collect hazardous waste and ship it using a registered transporter to a hazardous waste
TSDF for treatment and disposal.
Reuse spent chromium as ingredient in pickle solution.
Reprocess spent chromium for reuse in tanning process.
Use tanning splits to maximize efficiency of chromium.
Manage trivalent chromium to prevent oxidation into hexavalent chromium.
Maximize equipment efficiency.
PROCESS
Retanning/Dyeing/Fatliquoring
Wastes Generated
Possible RCRA
Waste Codes
Chromium, kerosene, solvent and dye overspray, solvent still bottoms, toluene, and
toxic dyes.
D001 (kerosene, solvent and dye overspray, solvent still bottoms, and toluene), D007
(chromium), F001-F005 (solvent overspray, solvent still bottoms, and toluene).
LEATHER MANUFACTURING
11
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Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
PROCESS
Reclaim solvents in an onsite distillation unit and reuse on site.
Reclaim and reuse retanning solutions.
Collect hazardous waste and ship using a registered transporter to a hazardous waste
TSDF for treatment and disposal.
Use less toxic dyes and coatings.
Seal solvent to prevent product volatilization.
Reduce air emissions by thermal drying in a controlled area with solvent recovery
systems.
Reclaim solvents in an onsite distillation unit and reuse on site.
Reengineer processes to utilize less chemicals.
Reclaim and reuse retanning solutions.
Buffing/Coating
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Alcohols (methanol, ethanol, propanol, butanol, diacetone alcohol), chromium in leather
dust, esters (ethyl, propyl, and butyl acetates), glycol ethers (butoxyethanol and
propoxyethanol), ketones (methyl isobutyl ketone, acetone, cyclohexanone, di-isobutyl
ketone), methyl ethyl ketone, solvent overspray, solvent still bottoms, toluene, volatile organ-
ic air emissions and xylene.
D001 (methyl ethyl ketone, solvent overspray, solvent still bottoms, and toluene), D007
(chromium), D035 (methyl ethyl ketone), and F001- F005 (methyl ethyl ketone, solvent over-
spray, solvent still bottoms, toluene, and xylene).
• Capture, recover, and reuse solvent.
• Use trimmings and leather dust from buffing to make reconstituted leather.
• Collect hazardous waste and ship using a registered transporter to a hazardous waste
TSDF for treatment and disposal.
• Use water-based coatings and lacquer finishes to decrease volatile organic air
emissions.
• Prepare smaller test batches of solvents and coatings.
• Install automated spray systems which adjust spray angle for each hide and reduce
overspray.
• Cover containers used during spray coating operations to prevent solvent volatilization.
• Capture, recover, and reuse solvent.
• Store waste solvents separately to facilitate recycling.
• Use trimmings and leather dust from buffing to make reconstituted leather.
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RCRA IN FOCUS
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PROCESS
Product Storage
Wastes Generated
Possible RCRA
Waste Codes
Chromium, kerosene, methyl ethyl ketone, trichloroethylene, and toluene.
D001 (kerosene, methyl ethyl ketone, trichloroethylene, and toluene), U159 (methyl ethyl
ketone), U228 (trichloroethylene), and U220 (toluene).
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Collect hazardous waste and ship using a registered transporter to a hazardous waste
TSDF for treatment and disposal.
Use a first in, first out policy in storage areas to prevent materials from expiring.
Computerize inventory control to prevent materials from expiring.
LEATHER MANUFACTURING
13
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CFR GUIDE TO
HAZARDOUS
WASTE
REGULATIONS
To review the
RCRA regulations
referred to in this docu-
ment, consult the fol-
lowing citations in 40
CFR:
Part 260—Hazardous
waste management sys-
tem: general.
Part 261—Identification
and listing of hazardous
Part 262—Standards
applicable to generators
of hazardous waste.
Part 263—Standards
applicable to transporters
of hazardous waste.
Part 264—Standards for
owners and operators of
hazardous waste and
specific types of haz-
ardous waste manage-
ment facilities.
Part 265—Interim status
standards for owners and
operators of TSDFs.
Part 266—Standards for
the management of spe-
cific hazardous wastes
and specific types of
hazardous waste man-
agement facilities.
continued
OTHER ENVIRONMENTAL LAWS
AFFECTING THE LEATHER
MANUFACTURING INDUSTRY
THE CLEAN WATER ACT
The Water Pollution Control Act, commonly known as the Clean Water Act (CWA), is the fed-
eral program designed to restore and maintain the integrity of the nation's surface waters. CWA
controls direct discharges to surface waters (e.g., through a pipe) from industrial processes or
storm-water systems associated with an industrial activity. It also regulates indirect discharges, or
discharges to POTWs, through a public sewer system, by requiring industrial facilities to pretreat
their waste before discharging to a public sewer. Industrial pollutants from the leather manufactur-
ing industry that might be regulated by CWA include solvents, heavy metals, and alkaline wastes.
CWA Resources:
• 40 CFR Parts 100 to 129 and 400 to 503 (Leather manufacturers should pay particular attention
to Part 425 which provides the effluent guidelines and standards for leather tanning and finish-
ing-)
• Internet access: www.epa.gov/OW/
• EPA Office of Water: 202 260-5700
• Your state water authority, regional EPA office, and local POTW
THE CLEAN AIR ACT
The Clean Air Act (CAA) regulates air pollution. It includes national emission standards for new
stationary sources within particular industrial categories. It also includes national emission stan-
dards, which are designed to control the emissions of particular hazardous air pollutants (HAPs).
Leather facilities generate some HAPs such as volatile organic compounds in organic solvents. The
CAA also seeks to prevent the accidental release of certain hazardous chemicals and to minimize the
consequences of such releases.
CAA Resources:
• 40 CFR Parts 50 to 99
• Control Technology Center, Office of Air Quality, Planning and Standards, EPA, general infor-
mation: 919 541-0800; publications: 919 541-2777
• Internet access: www.epa.gov/ttn/catc
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND
LIABILITY ACT (CERCLA OR SUPERFUND)
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, commonly known as Superfund, authorizes EPA to respond to releases, or threatened releas-
es, of hazardous substances that might endanger public health, welfare, or the environment, that
releases might come from any source. Superfund also grants EPA the authority to force parties
responsible for environmental contamination to clean it up or to reimburse response costs incurred
by EPA. The most important part of this act applicable to leather manufacturers is the hazardous
substance release reporting requirement. The person in charge at your business must report to the
National Response Center (phone: 800 424-8802) any release of a hazardous substance that exceeds
a designated "reportable quantity" for that substance within a 24-hour period.
Superfund Resource:
• Internet access: www.epa.gov/superfund
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RCRA IN FOCUS
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THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT
The Superfund Amendments and Reauthorization Act (SARA) of 1986 created the Emergency
Planning and Community Right-to-Know Act (EPCRA). This law was designed to improve com-
munity access to information about potential chemical hazards and to facilitate the development of
chemical emergency response plans by state and local governments. The EPCRA regulations estab-
lish several types of reporting obligations for facilities that store or manage specified chemicals. If a
leather facility uses or stores extremely hazardous substances, such as hydrogen sulfide, of certain
quantities, certain notification requirements apply. Also, many of the chemicals used by leather
manufacturers may be considered hazardous chemicals as defined by the Occupational Safety and
Health Act (OSHA). Contact your local OSHA office if you have questions about whether the
chemicals used in your leather manufacturing business are considered hazardous under OSHA
Certain facilities that generate benzene, toluene, and trichloroethylene have reporting requirements
under the Toxic Chemical Release Inventory.
EPCRA Resources:
• 40 CFR Parts 350 to 372
• The State Emergency Response Commission (contact available from RCRA Hotline)
• Internet access: www.epa.gov/opptintr/tri/index.htm and www.epa.gov/swercepp/
SAFE DRINKING WATER ACT
The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect human
health from contaminants present in drinking water. Under the authority of SDWA, EPA developed
national drinking water standards and created a joint federal-state system to ensure compliance with
these standards. EPA also regulates underground injection of liquid wastes under the SDWA to pro-
tect underground sources of drinking water.
SDWA Resources:
• 40 CFR Parts 141 to 148
• SDWA Hotline: 800 426-4791
• Internet access: www.epa.gov/ogwdw
TOXIC SUBSTANCES CONTROL ACT
The Toxic Substances Control Act (TSCA) allows EPA to collect data on chemicals to evaluate,
assess, mitigate, and control risks that might be posed by their manufacture, processing, and use.
Leather manufacturing facilities may be affected by some of the TSCA requirements.
TSCA Resources:
• 40 CFR Parts 702 to 799
• TSCA Hotline: 202 554-1404
• Internet access: www.epa.gov/internet/oppts/
CFR GUIDE
continued
Part 268—Land disposal
restrictions.
Part 270—EPA adminis-
tered permit programs:
the Hazardous Waste
Permit Program.
Part 271—Requirements
for authorization of state
hazardous waste pro-
grams.
Part 272—Approved
state hazardous waste
management programs.
Part 273—Standards for
universal waste manage-
ment.
Part 279—Standards for
the management of used
oil.
FOR MORE
INFORMATION
For additional infor-
mation on any of
these laws, contact the
RCRA Hotline at 800
424-9346 or 703 412-
9810 in the Washington,
DC, area. TDD (hearing
impaired): 800 553-7672
or 703 412-3323 in the
Washington, DC, area.
LEATHER MANUFACTURING
15
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CONTACTS AND RESOURCES
HOTLINES AND
INFORMATION CENTERS
RCRA Hotline
U.S. Environmental Protection Agency
Phone:800424-9346
or TDD 800 553-7672
In the Washington, DC, area:
703 412-9810, or TDD 703 412-3323
Home page: www.epa.gov/epaoswer/hotline
Answers questions on matters related to
RCRA solid waste, hazardous waste, and
underground storage tanks, EPCRA, and
CERCLA.
RCRA Information Center
U.S. Environmental Protection Agency
RCRA Information Center (5305W)
401 M Street, SW.
Washington, DC 20460
Phone: 703 603-9230
Fax: 703 603-9234
E-mail: rcra-docket@epa.gov
Holds and provides public access to all regula-
tory materials on RCRA and distributes tech-
nical and nontechnical information on RCRA
issues.
Small Business Ombudsman
Clearinghouse/Hotline
U.S. Environmental Protection Agency
Small Business Ombudsman (2131)
401 M Street, SW
Washington, DC 20460
Phone:800368-5888
Fax: 703 305-6462
Home page: www.smallbiz-enviroweb.org
Helps private citizens, small businesses, and
smaller communities with questions on all
program aspects within EPA.
EPA Headquarters Library
U.S. Environmental Protection Agency
Headquarters Library
401 M Street, SW, Room 2904
Washington, DC 20460
Phone: 202 260-5921 or 5922
Fax: 202 260-6257
E-mail: library-HQ@epa.gov
Home page: www.epa.gov/natlibra/liblists.html
Maintains environmental reference materials
for EPA staff and the general public, including
books, journals, abstracts, newsletters, and
audiovisual materials generated by government
agencies and the private sector. Also provides
access to online computer service bulletin
boards and CD-ROM systems.
Pollution Prevention
Information Clearinghouse
(PPIC)
U. S. Environmental Protection Agency
Pollution Prevention Clearinghouse (PPIC)
401 M Street, SW (7409)
Washington, DC 20460
Phone: 202 260-1023
Fax: 202 260-4659
E-mail: ppic@epa.gov
U.S. Department of
Transportation
Hazardous Materials Information Center
Phone: 800 467-4922
Provides information about DOT's hazardous
materials regulations.
U.S. Government Printing
Office
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
Phone: 202 512-1800
Fax: 202 512-2250
Prints and distributes the Code of Federal
Regulations. Title 40, Parts 260 to 299, contain-
ing most of the RCRA requirements.
National Response Center
(NRC)
Phone: 800 424-8802
In the event of a fire, explosion, or other
release of hazardous waste that could threaten
human health outside the facility, call the
NRC to report the emergency. The NRC will
evaluate the situation and help you make
appropriate emergency decisions.
ADDITIONAL INTERNET
ADDRESSES
EPA Home Page
www.epa.gov
EPA RCRA Hazardous Waste Resources
www.epa.gov/osw/topics.htm
Code of Federal Regulations
www.epa.gov/docs/epacfr40/
Envirosense
es.inel.gov
Contains technical, policy, and general infor-
mation on pollution prevention topics.
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RCRA IN FOCUS
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