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Proof of what's in your dumpster

Hazardous Waste Analysis

KPA samples the waste your shop actually throws out, from paint booth filters to oil-water separator sludge, has a certified lab test it, and gives you a written hazardous waste determination you can hand an EPA inspector.

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Hazardous Waste Analysis & Determination

Replace the dumpster guess with lab data from your own waste

hazardous waste
Hazardous Waste Analysis

Your KPA consultant has already walked your waste streams with you: the drums, the booth, the drain out back. Lab results and the written determination go into your Vera Suite compliance file next to the rest of your EHS records, so the paperwork an inspector asks for first is already in one place.

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Sampling, TCLP Analysis & Written Determinations


The sampling kit ships to your store with instructions for pulling a representative sample. A certified lab runs the analysis, and a KPA consultant reads every result and tells you what it means for the drum, the dumpster and your hauler.

Sampling Built Around Your Waste Streams

  • Paint booth filters, sanding dust and body filler debris
  • Oil-water separator and floor drain sludge
  • Still bottoms, waste thinners and leftover coatings
  • Solvent-laden rags, used absorbents and spill cleanup material

  • Kits shipped to your facility, typically 7 to 10 days after contract processing, with step-by-step instructions

Certified Laboratory Analysis

  • TCLP (EPA Method 1311) for the eight RCRA metals, including lead, chromium, cadmium and barium

  • Ignitability and corrosivity testing where the waste stream calls for it

  • Results compared against EPA's regulatory limits in 40 CFR 261.24

Written Determinations

A verified hazardous or non-hazardous determination for each waste stream tested

Handling guidance: what can go in the dumpster, and what needs labeling, storage limits, a licensed hauler and a manifest

Records organized the way an EPA or state inspector will ask for them

Your own analytical basis to hold up against the waste profile your hauler filed

Retest guidance when paint systems, chemical vendors, cleaners or processes change

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Regulatory Spotlight

EPA Hazardous Waste Determinations: What You Have to Prove

Most shops throw out filters, rags and sludge the same way they did ten years ago. Under RCRA, that's only legal if someone has determined the waste isn't hazardous. EPA's rule (40 CFR 262.11) puts that determination on the business that generates the waste, at the point it's generated. Your hauler, your paint supplier and the disposal site don't carry it for you. In some inspections, EPA has emptied a facility's dumpster and gone through it by hand.


The Determination

  • A waste is hazardous if EPA lists it, or if it's ignitable, corrosive, reactive or toxic.

  • The toxicity characteristic is the usual issue in collision and service work. The TCLP test simulates a landfill to see whether metals such as lead (limit 5.0 mg/L) or cadmium (limit 1.0 mg/L) would leach out (40 CFR 261.24).

  • Generator knowledge is allowed, but an SDS describes what went into the can. It can't describe a booth filter holding a month of overspray from a dozen different coatings.

Records and Hauler Profiles
  • Your hauler's waste profile is their paperwork, not your determination. Under RCRA, classifying the waste correctly is the generator's job.
  • Small and large quantity generators must keep determination records, including test results, for at least three years (262.11(f)).

  • When paint systems, cleaners or processes change, the waste can change with them, and the determination needs another look.


EPA civil penalties for RCRA violations can reach $93,058 per violation, per day. A determination is about more than the fine, though. It means the tech emptying the booth filters knows which bin they go in, and the drum out back is labeled for what's actually inside it.

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Dick Hanna

Penske

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Beck Automotive Group

AutoNation

Foundation Automotive Corp

Featured Resources

Since 1986, we've seen it all. Explore the resources our clients rely on most.

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Running a dealership isn’t just about selling cars. It’s about protecting your team and meeting strict safety and regulatory standards. This checklist gives you a clear path to building an EHS program that actually works.

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