Asia Chi, EHS Associate and Kevin Cosgrove, CPP, Senior Engineer
Are you on track to complete your SB14 plans and reports by September 1st, 2023?
What is SB14?
Senate Bill 14 (SB14) is the Hazardous Waste Source Reduction and Management Review Act of 1989, which requires hazardous waste generators to focus on source reduction as the preferred method of managing hazardous waste. The goal of the regulation is to reduce the generation of hazardous waste at its source, reduce the environmental impacts of waste released to the environment, and improve documentation of hazardous waste management.
SB14 requires generators to prepare documents every four years, when the generation of hazardous waste or extremely hazardous waste exceeds the corresponding applicability threshold during a reporting year. This table summarizes the upcoming 4-year reporting timeline:
(Fixed by statute)
(Fixed by statute)
(Fixed by statute, except in a generator’s initial report)*
* The schedule above is based on facilities with a reporting cycle which began in the 1990 plan year. Facilities may have a different schedule depending on their baseline year.
Steps to Determine Reporting Applicability:
Here are some simple steps you can follow to determine if your facility is subject to the SB14 regulation.
- Sum the total hazardous waste generated at your facility during calendar year 2022.
- Subtract any waste that is exempted, not routinely exempted, or excluded per recycling law.
If this quantity exceeds 13.2 tons of hazardous waste or more than 26.4 lbs of extremely hazardous waste, SB14 applies to your facility. Note, the requirements apply to both Resource Conservation and Recovery Act (RCRA) and Non-RCRA (California Only) hazardous waste.
Aqueous Hazardous Waste:
Do you generate aqueous hazardous waste that undergoes on-site treatment prior to discharge to the sewer?
- Is this volume greater than 3,100 gallons/year?
If yes, SB14 applies to your facility.
Required Plans and Reports
SB14 requires generators to prepare three documents on or before September 1, 2023, for the 2022 reporting year. These reports do not have to be submitted to the Department of Toxic Substances Control (DTSC) but must be completed and ready for inspection by the DTSC or Certified Unified Program Agency (CUPA).
- The Source Reduction Evaluation Review and Plan
The Plan is a forward-looking document and must include an estimate of the quantity of hazardous wastes generated, an evaluation of potential source reduction approaches, a timetable for implementing selected source reduction measures, and a four-year numerical goal. The Plan must also address the predicted effectiveness of selected measures at reducing hazardous waste and releases to all environmental media (the air, land, and water).
- Performance Report
The Performance Report is a retrospective document and must include an assessment of the effect on waste generation of each waste management approach implemented since the baseline year. The report can serve as a way for the generator to share with the public all of the positive efforts to improve the management of hazardous waste at the generator’s site. If a generator qualifies as a small business, they can use their biennial generator report (BGR) as their Performance Report.
- Summary Progress Report
The Summary Progress Report summarizes the result of implementing the source reduction measures identified in the generator’s previous Plan and the amount of reduction that the generator anticipates will be achieved by the implementation of source reduction selected in the current Plan. To develop the report, you would need to gather general information, total hazardous waste generation data from previous reporting years, a summary and comments on your organization’s historical source reduction successes and waste management practices. These reports are requested most often.
NV5’s Environmental Health and Safety Professionals specialize in helping companies comply with local, state and federal Environmental Health and Safety requirements, including SB14 applicability analysis and determination of exempted wastes, and preparation of SB14 Plans and Reports. If you would like assistance or more information, please contact Kevin Cosgrove at Kevin.Cosgrove@NV5.com.