Hazardous Waste Annual Report Program

Senate Bill 294 was signed by the Governor in early June, and became effective September 5, 2012.  One component of that bill allows the Director of Ohio EPA to report certain hazardous waste management data to the Governor biennially now instead of annually.  Ohio EPA changed certain annual reporting requirements to biennial reporting requirements to correspond with the federal program. 

Under these rule changes, the “Hazardous Waste Report” that would have been due March 1, 2013, for 2012 data will not be required to be submitted to Ohio EPA.  The first biennial report will be due March 1, 2014, for 2013 data.

The “Biennial Set” rules that changed the annual reporting requirement to a biennial reporting requirement became effective on February 5, 2013.

However, if you normally submit other reports/data with your annual report that are not part of that report (e.g., the ground water monitoring annual report required by OAC 3745-65-94), those other reports/data will maintain an annual reporting requirement.

For more information about the rulemaking, go to the Hazardous Waste Rulemaking Web page or to the Answer Place.

For more information about the reporting changes, read Hazardous Waste Report Changes for 2013

A Hazardous Waste Report (HWR) is required to be submitted no later than March 1 of even-numbered years by Large Quantity Generators and Treatment, Storage, and Disposal Facilities and covers the activities conducted in the previous odd-numbered calendar year.  If a site became a Large Quantity Generator in one or more months of an odd-numbered year, they are required to file a HWR.  The data in the reports is reviewed by Ohio EPA and forwarded to U.S. EPA in fulfillment of the Biennial Report requirement; facilities do not need to file a separate Biennial Report.

Electronic filers use the eDRUMS Web-based Hazardous Waste Report Service through Ohio EPA's eBusiness Center.   Filing electronically saves time and prevents common errors.  Edit checks help the user submit a higher quality report than if it is completed on paper.

Below are popular/useful links for the Hazardous Waste Report Program

eBusiness Center

2011 Instruction Booklet

Site ID Form (to be completed by all facilities filing a report)

GM and OI Forms (to be completed by facilities that generate  and/or ship HW)

eBusiness Center

2011 Instruction Booklet

Site ID Form (to be completed by all facilities filing a report)

GM and OI Forms
(to be completed by facilities that generate and/or ship HW)

WR and PS Forms
(to be completed by off-site receivers only)

Sign up to receive HW Report updates via e-mail


The File Specification Guide for the Hazardous Waste Annual Report explains how to format data files that can be imported to create an eDRUMS report.


Generators who have shipped hazardous waste off-site are required to submit an HWR (OAC Rule 3745-52-41).  If they generated less than 1000 kg (2200 lbs) of non-acutely hazardous waste in each month of the calendar year, then the generator is exempt from reporting (OAC Rule 3745-52-44).  In other words, if the site was a Large Quantity Generator (LQG) in any one month during the calendar year, they must file an HWR and list all the wastes they generated and/or shipped during the entire year.  A LQG is defined as a site that generates 1000 kg (2200 lbs) or more of non-acutely hazardous waste or 1 kg (2.2 lb) or more of acute hazardous waste in one calendar month.  There is no exemption from reporting for one-time or short-term LQG activities.

Facilities that have a permit to treat, store, or dispose (TSD) of hazardous waste must also file an HWR (OAC Rules 3745-54-75 or 3745-65-75).   Commercial or limited commercial facilities that receive hazardous waste from off-site must identify their customers, what was received, and how it was managed.  Facilities that conduct on-site management of their own wastes in permitted units report the quantity and the method(s) used.

eDRUMS is an electronic reporting service available to users through the agency’s eBusiness Center (“eBiz”).  You may already be familiar with eBiz from filing reports with the air and water programs.  To obtain general information about eBiz, go to https://ebiz.epa.ohio.gov and click on the words “Click here for online help”.  eBiz Fact Sheets are available there as well as a link to the Answer Place.  There is no charge for establishing an eBiz account. 

For an overview on how to get started in eBiz, go to the Training Resources tab of this web page to listen to recorded webinars or view a PDF of the slides.  Webinar training and slides are also available for applying for the eDRUMS service and delegating access to other users as well as how to prepare a report using eDRUMS.

To get started with eBiz, the facility's Responsible Official (RO) or their duly authorized representative (i.e. Delegated Responsible Official, or DRO) must apply to use eDRUMS.  The RO or DRO are the individuals who can sign a report, either electronically or on paper.  The definition of who can be an RO or DRO for the RCRA program is in Ohio Administrative Code rule 3745-50-42.  Once the RO or DRO has a PIN, they will submit an eDRUMS service request to associate them with a specific facility.  Once the service request is approved the RO or DRO can start working on a report or may delegate report preparation duties for a facility to another eBiz user. 

Only the RO or DRO needs a PIN; report preparers simply need an eBiz account and the delegation of the preparer role.  Consultants can be designated as preparers.  The eBiz PIN uniquely identifies the individual it is assigned to and can be used for all regulatory programs that use eBiz for electronic submissions.  If the RO or DRO already has a PIN for water or air data submissions, there is no need to obtain another.  The PIN cannot be shared with other people and must be kept confidential.

If the RO wants to delegate annual report signatory authority to someone else pursuant to OAC rule 3745-50-42, this can be done in two ways:

    • On paper:  A letter or form authorizing a specific individual or a specific position of responsibility to sign the report can be sent to Ohio EPA, DMWM, PO Box 1049, Columbus, OH, 43216-1049.  This option can be used if the Responsible Official doesn't want to establish their own account in eBiz or obtain a PIN.  The process is as follows:
      • The duly authorized representative (DRO) would obtain an eBiz account and PIN and then apply for the eDRUMS service by clicking the   "Delegated Submitter" box in the HWAR Service Request screen.

      • After clicking Submit, the user must print the partially populated Delegation of Authority document that appears in PDF format on the acknowledgment screen.

      • The Responsible Official authorizing the user to electronically sign reports must complete the remainder of the form and send it to DMWM via US mail.

      • Once the mailed form is received by DMWM, the DRO's service request will be approved.

    • Electronically:  If the RO has a PIN, they can delegate the certify/submit role to the duly authorized representative (DRO) after the RO's eDRUMS service request has been approved.  The DRO must have a PIN before they can certify/submit a report.  Sending an authorization letter/form to DMWM is not necessary for electronic delegations.
       

      From reporting cycle to reporting cycle, there may be a need to change who prepares the report or who certifies it as the RO.  Ohio EPA has posted a file which details how to manage a Change in Roles within the eBusiness Center.

DMWM has recorded three training sessions to orient report filers to the procedures and functions of eDRUMS.  These sessions are free to view and can reviewed as many times as you like.


Session #1 - Getting Started in the eBusiness Center

This session provides a brief overview of eBusiness Center basics such as:

  •     Setting up an account;

  •     Securing a Pin;

  •     The role of the Responsible Official

Click here to listen to the recorded session, or you can just view the slides (PDF).  Note:  in the PDF, slide 11 has been updated since the session was recorded. Session #2 - Applying for and Delegating the HW Service

The course provides an overview of eBusiness Center basics such as:

  •     Applying for the HW service

  •     DMWM's review of service requests

  •     How to delegate privileges

Click here to listen to the recorded session, or you can just view the slides (PDF).


Session #3 - Preparing an Annual Report in eDRUMS

This session includes a hands-on demo on how to complete a report.  

Click here to listen to the recorded session, or you can just view the slides (PDF).


Generator and Facility Report Frequency will change from Annual to Biennial

Senate Bill 294 was signed by the Governor in early June, and becomes effective September 5, 2012.  One component of that bill allows the Director of Ohio EPA to report certain hazardous waste management data to the Governor biennially now instead of annually.  Ohio EPA intends to change certain annual reporting requirements to biennial reporting requirements to correspond with the federal program.

Under these intended rule changes, your “Hazardous Waste Annual Report” currently due March 1, 2013, for 2012 data would not be required to be submitted to Ohio EPA.  Your first biennial report would be due March 1, 2014, for 2013 data.

The proposed “Biennial Set” rules that will change the annual reporting requirement to a biennial reporting requirement are on track to be final filed in late January or early February, 2013.  We anticipate that their effective date will be in February, 2013.

However, if you normally submit other reports/data with your annual report that are not part of that report (e.g., the ground water monitoring annual report required by OAC 3745-65-94), those other reports/data will maintain their annual reporting requirement.

It is our goal to have annual to biennial rule amendments effective prior to March 1, 2013. If the process is delayed for some reason, Ohio EPA will use enforcement discretion and you will not be held to the annual report requirement that is changing to biennial.

For more information about the rulemaking, go to the Hazardous Waste Rulemaking Web page or to the Answer Place.

New for 2011 Reporting:

There are no form changes for 2011.  There are two new Form Codes (waste pharmaceuticals, dried paint) and description enhancements to one Form Code and three Source Codes.  Click here for a complete list.

Code changes for the 2013 cycle will be posted here once they are finalized by U.S. EPA.

Requirements for Generators:

OAC Rule 3745-52-41

OAC Rule 3745-52-44 (exemption)

Requirements for Treatment, Storage, or Disposal Facilities:

OAC Rules 3745-54-75 or 3745-65-75

HW Report responses found on Ohio EPA’s AnswerPlace 

Where do I send completed paper forms?

USPS Mailing Address

Ohio EPA – DMWM

PO Box 1049

Columbus, OH 43216-1049

Courier Delivery Address:

Ohio EPA – DMWM

Lazarus Government Center

50 W Town St, Suite 700

Sarvis, Harry

Manager

(614) 728-5333

Regulatory Program Development Unit

McGinnis, Ralph

Supervisor, Reporting, Analysis, and Data Management

(614) 644-3065

Canter, Paula

Hazardous waste, solid waste System Administrator

(614) 644-2923