April 2018 DRAFT
All-hazards Waste Management Decision Diagram
Background Waste management (also referred to as debris management) is a critical part of the response to
and recovery from a homeland security incident, such as an act of terrorism involving chemical, biological, or
radiological agents, a large-scale natural disaster, and an animal disease outbreak. Waste is generated
immediately by the incident itself and continues to be generated by the characterization, decontamination, and
cleanup processes. More efficient and effective management of the amounts and types of waste generated can
result in a quicker and less costly recovery from an incident.
Purpose: This waste management decision diagram is intended to assist emergency planners and managers in
the public and private sectors with the waste management decision-making process after a homeland security
incident occurs. It includes considerations that aid in making waste management-related decisions and
identifies areas where pre-incident waste management planning can be useful.
Notes about this Decision Diagram:
•	This decision diagram is divided into three stages - initial activities, on-site activities, and off-site activities
- at which waste management decisions are typically made during an incident. The diagram is intended to
be a guide only. While many of these considerations and decisions are part of every response, differences
in the waste management decision-making process exist but are not accounted for in this all-hazards
decision diagram. Also, many of the steps may occur concurrently during an incident, as well as in a
different order. The needs and specifics of the response should guide the decision-making process.
•	Planning for waste management, including waste staging, sampling, characterization, packaging,
transportation, reuse, recycling, treatment, and disposal, before an incident occurs is very important.
Pre-incident planning facilitates the decision-making process during an incident response, assisting with
the steps in this flowchart. More information about pre-incident planning can be found in EPA's Pre-
incident All-hazards Waste Management Plan Guidelines: Four-step Waste Management Planning Process
document, which can be found at https://www.epa.gov/homeland-security-waste.
•	This diagram does not discuss the Federal Emergency Management Agency's (FEMA's) Public Assistance
Program and Policy Guide. Review FEMA's eligibility requirements at https://www.fema.gov/media-
library/assets/documents/l I 1781 in the event of a federal emergency or major disaster declaration.
•	Different waste management requirements may apply to different types of wastes. For example, solid
waste that is non-hazardous under the Resource Conservation and Recovery Act (RCRA) would likely
take a different route than RCRA hazardous waste, as well as from waste that falls outside RCRA's
scope. Alternatively, all waste may be managed under the more stringent requirements for hazardous
waste. In addition, states may have more stringent requirements for waste than the federal regulations.
•	Reuse and recycling opportunities are potentially available for many different waste streams, including
hazardous waste. Legitimate reuse and recycling options, if applicable, should be considered before other
waste management options (e.g., landfills) to help lessen the environmental and economic impacts of the
incident. Hazardous waste being legitimately recycled still needs to meet the RCRA hazardous waste
management requirements, unless specifically excluded from regulation.

All-hazards Waste Management Decision Diagram for Homeland Security Incidents
Conduct Damage Assessment
•What is the nature of the incident?
•Select Waste Management Plan that aligns
to the specific incident, if applicable
•Establish and maintain communication
across the whole community (e.g.,
regulatory agencies, general public)
•Investigation by law enforcement may
impact initial waste management activities
Identify Generated Materials1
and Estimate Their Quantities
•> Begin identifying potential waste
management sites, facilities, and
resources if not already pre-
{~ Conduct cost-benefit analysis of
waste management options
Decontaminate the Materials
with Appropriate Assistance
•	Prepare a site sampling and analysis plan
•Establish a clearance level
•	Confirm effectiveness of decontamination
•	Manage waste (e.g., decontamination water
generated from the decontamination process)
Segregate the Materials as
Much as Practicable
{~ Separate materials that have the
potential for reuse or recycling
from materials that will be
otherwise managed
•> May also segregate the materials
by type, potential waste stream,
receiving facility, contaminant, or
required treatment technology
Will Materials
Be Decontaminated?
Process Waste if
Applicable or Feasible
~	Consider treatment options
~	Waste minimization (e.g.,
volume reduction, toxicity
~	Biosecurity, chemical agent,
and particulate concerns
~	Conduct environmental
Make Waste Determination
~	Are materials reusable?
~	Develop or update waste sampling and analysis
strategy for waste characterization and classification
~	How does RCRA status (hazardous vs. non-hazardous)
impact storage, documentation, handling, safety, and
other considerations?
~	How do other EPA statutes and statutes from other
federal agencies (e.g., CDC, NRC, USDA) apply?
~	How do state/local/tribal/territorial regulations apply
to the waste (which may be more stringent than
federal requirements)?

Materials ^

Will the Waste
Be Recycled or
Can the Waste
Be Disposed of
•Vendor verification
Dispose of Waste in a
Manner that Protects Human
Health and the Environment
Environmental monitoring/controls
Prepare Waste for Transport
~	Packaging, labeling, and transport
requirements (e.g., EPA, DOT,
~	Other federal/state/local/tribal/
territorial regulations may apply
~	Any special handling/safety
Select Appropriate
Disposal Facility
•	Capacity, cost, permit considerations
> Community concerns and
Environmental Justice issues
•	Coordinate with stakeholders
Can Waste Be
Directly Transported
to the Facility?
Manage Waste in a
Storage/Staging Area
~	Segregate the waste
~	Kemove hazards
~	Decontaminate as necessary
~	Conduct environmental monitoring
~	Volume reduction
~	Can be on-site or off-site
~	Comply with applicable regulations
Vendor verification suggested
Manage Waste in an
Appropriate Disposal
"Material" is defined broadly at this point in the process: materials ultimately may be reused, recycled, or disposed of as waste.
1 In some circumstances, waste can be recycled (e.g., breaking up and grinding concrete on-site for immediate use in backfill) or composted (e.g., in-house composting of
poultry) on-site.
1 Waste identified as hazardous would need to meet the RCRA hazardous waste management requirements for transportation, recycling, storage, treatment, disposal,
April 901 8 DRAFT