The concept of Generator’s Knowledge

There are two ways to determine if you have a hazardous waste: The first way is generator’s knowledge and the second way is laboratory analysis.

If you purchase and use 100 gallons of solvents a month to clean your machine, you know that you have generated spent solvent which in most instances is a hazardous waste. This is your “generator’s knowledge”. You do NOT need to analyze your spent solvent to show that it is hazardous. Based on your knowledge of how you use your material, you have the knowledge to determine that it is hazardous.


On the other hand, if you find 5 drums of unknown chemicals sitting in your warehouse and no one can tell you where they came from. You have NO generator’s knowledge and you must conduct chemical analysis to determine if these drums contain hazardous waste.


3 responses to “The concept of Generator’s Knowledge

  1. Norman.
    Good article. One point that I know you have covered before is, although you know what it is and you have had it analyzed, How do you know it is hazardous?
    We use the acronym; “TRIC”. If it’s Toxic, Reactive, Ignitable or Corrosive, it is hazardous.
    Lyndon Pousson

  2. I would add: first determine whether it is a waste or excluded. If the example is parts washer solvent, there are some arrangements with companies to supply and then retrieve the solvent and use it without any reclamation (as an ingredient or product as solvent suitable for other solvent uses). Numerous facilities have understandings with these companies but do not have any documentation that either the material is not waste or if it is waste, that it does not have hazardous waste characteristics. They do this because they don’t understand their relationship with the parts washer supplier and just assume everything is OK.

  3. Your blog is really interesting to read esp where we have the same issues in th UK.

    We get this issue quite regularly as we take drummed wastes from all over the country into our transfer stations direct from producers and from third party transfer stations.

    It’s about building a picture, if they know what industry the waste is form then that normally gives a good start. I.e. you don’t get radioactive waste from a print shop, or high quality acetone from a garage. Following on from that we can get some basic testing done to start identifying the material and categorising it.

    The less we have to go on, the longer it takes, but we can normally get a good idea of the waste if its at the producers site.

    Where it becomes more difficult is if the material is sat at a 3rd party transfer station having lost its identity.

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