Waste Minimization Plans

SB 14 Source Reduction – Waste Minimization Plan

Source reduction is preferable to recycling and treatment options.

In 1989, California adopted legislation requiring hazardous waste generators, who are subject to the Hazardous Waste Control Law, to consider source reduction as the preferred method of managing hazardous waste.  This law, the Hazardous Waste Source Reduction and Management Review Act of 1989 (SB 14), promotes source reduction over recycling and treatment because it avoids the generation of hazardous waste and its associated management liability.  Hazardous waste generators must determine if they are captured by SB 14 every four years in target years (2014, 2018, 2022, etc.).

Waste Minimization – Who Needs It?

To determine if your operation must comply with the source reduction planning requirements, ask yourself the following questions:

  1. Did my facility generate 12,000 kg/year or more of hazardous waste or 12 kg/year or more of extremely hazardous waste in the target year?
  2. Is this waste routinely generated from ongoing operations?  (One-time waste streams such as demolition debris from decommissioning a production line are excluded.)
  3. Does my business generate aqueous hazardous waste that undergoes on-site treatment prior to discharge to the sewer?  (If the facility produced over 3,100 gallons/year it is captured by SB 14.)

If you answered yes to questions 1 and 2, or yes to question 3, your facility is subject to the SB 14 planning requirements.


Waste Minimization – What Is Required?

SB 14 requires the preparation of waste minimization documents every four years for those facilities that meet the waste generation thresholds in the reporting year.  Generators are required to prepare three documents.

  1. The first document is the Hazardous Waste Source Reduction Evaluation Review and Plan (Plan.)
    1. The plan is a forward-looking document in which a generator evaluates potential source reduction/waste minimization measures for each major waste stream.
    2. Minimization techniques need to be considered in five different areas for each waste stream.  Possible techniques are evaluated for feasibility and accepted or rejected.
    3. The document must include documentation of the evaluation and feasibility review as well as an implementation time table for each minimization technique to be implemented.
  2. The second document is the Hazardous Waste Management Performance Report (Report) and is a backward-looking document that must assess the effect each source reduction measure implemented in the previous plan on waste generation.
  3. The third document, the Summary Progress Report (SPR), summarizes the Waste Minimization Plan and Performance report details.

Because this plan is required to look ahead to the next four years and the progress report is required to look at the previous four years, DTSC expects a new plan to be developed each reporting year and not an “update” of the previous plan.  DTSC requires that a current evaluation of process, waste, technology, etc., be documented to consider any newly available waste minimization techniques and potential each reporting year.


Waste Minimization – Due Date

Plans and reports are to be completed by September 1 after each target year.


Waste Minimization – CDMS Is Here To Help

CDMS has prepared hundreds of Waste Minimization Plans for facilities throughout California.

We evaluate the waste volumes and waste streams to determine which qualify, facilitate the minimization technique evaluation, document the process, and develop the final plan, Performance Report and Summary Progress Report.

We can ensure you have the documentation needed to comply with SB 14 requirements.

Contact CDMS for help in:

  • Determining whether or not your facility must comply with SB 14 requirements
  • Determining which waste streams must be included in the Plan
  • Preparing your Plan, Report, and Summary Progress Report documents in a professional and efficient manner

CDMS does offer discounts for those that contract early to avoid the rush for our services later in the year.  Contact CDMS for a quote to help your facility meet these requirements.