Fact Sheets

Photographic Wastes

A Summary of Regulatory Requirements

January 2005

Title V of the Illinois Environmental Protection Act (Act) establishes statutory requirements to ensure that solid waste will be handled in a safe and responsible manner. The requirements found in the Act and the Board's regulations are intended to reduce the occupational and environmental health risks that occur during storage, treatment, transport, transfer and disposal of solid waste.

The information presented in this fact sheet does not eliminate any person's responsibility to fulfill any legal obligation under the Act or regulations promulgated thereunder.

The purpose of this fact sheet is to provide some of the solid waste requirements, found in both the Act and the Board's regulations. For the complete requirements, please see Title V of the Act and 35 Illinois Administrative Code (IAC): Subtitle G.

For additional information on solid waste regulations in Illinois, please contact the Disposal Alternatives Unit at the Illinois Environmental Protection Agency; Bureau of Land; 1021 North Grand Avenue East; P.O. Box 19276; Springfield, Illinois 62794-9276; (217) 524-3300.

How are photographic wastes regulated?

Photographic film (including x-ray film) is a by-product. By-products are considered a recyclable material (not subject to regulation) when sent for reclamation. However, photographic film is regulated as a general solid waste (non-special) when sent for disposal. If the photographic film exhibits the characteristic of a hazardous waste, it is a hazardous waste when sent for disposal.

Silver flake (from an electrolytic recovery process) is considered a product (not subject to regulation) when sent for silver recovery. When sent for disposal, it is a special waste and may be a hazardous waste if it exhibits the characteristic of a hazardous waste.

Spent developing solutions and silver traps (steel wool or ion-exchange canisters) are spent materials. Therefore, they are special wastes and may be hazardous if they exhibit the characteristic of a hazardous waste. If the sludge from a steel wool silver trap is removed and handled separately, it would be considered a sludge (characteristic) which is not subject to the waste management regulations when sent for non-listed reclamation.

Waste generated at a household is excluded from regulation as a hazardous or special waste. Household waste means any waste material derived from households (including single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas) but not wastes from a business operated at a place of dwelling.

Who can accept photographic wastes?

For non-special solid waste:
No person can accept solid wastes for storage, treatment, or disposal without a current, valid operating permit issued by the IEPA (i.e., the receiving facility has been permitted by the IEPA to receive wastes).

For non-hazardous special waste:
No person may accept special wastes (such as spent developing solutions or silver traps) for storage, treatment, or disposal without a current, valid operating permit issued by the IEPA.

For hazardous waste:
No person may accept hazardous wastes containing recoverable precious metals unless the facility has satisfied the notification requirements under Section 3010 of the Resource Conservation and Recovery Act and the facility uses, maintains, records and reports discrepancies in the manifest to the Agency. Additionally, a facility must show that the material has not been accumulated speculatively (i.e., the amount of material that is recycled, or transferred to a different site for recycling, equals at least 75 percent by weight or volume of that material accumulated during the calendar year and the facility has the records to prove this).

Exemptions:

1. Wastes which are classified as a product, by-product, or a non-listed characteristic sludge are not subject to regulation unless sent for disposal.
2. Waste, generated at a household (i.e., non-business derived), is excluded from regulation as a special or hazardous waste and may be placed with the general refuse.

The generator should ask the appropriately permitted facility (i.e., special waste or hazardous waste landfill or treatment facility) for the permit number which authorizes the facility to accept the waste.

Who can transport my wastes?

A person hauling or transporting any special or hazardous waste within Illinois must have a current, valid, waste hauling permit issued by the IEPA.

Exemptions:

1. Persons transporting only conditionally exempt small quantity generator waste (one who generates 220 pounds or less of waste in a calendar month) are not required to have a special waste hauling permit.
2. Persons transporting only household waste are not required to have a special waste hauling permit.

Note: hazardous wastes are a subset of special wastes and must be included in the total quantity generated in a calendar month for special wastes.

Do I have to manifest my wastes?

A manifest must be completed before offering a special or hazardous waste to a permitted waste hauler.

Exemptions

1. A generator who generates 220 pounds or less of special waste including hazardous waste in a calendar month is not required to use a manifest.
2. Wastes which are considered to be a product, by-product, or a non-listed characteristic sludge are not solid wastes and not subject to manifest requirements when sent for recycling.

In all instances, the generator must insure that his/her wastes go to a properly permitted facility for storage, treatment, transfer or disposal. The generator should ask the waste hauler who transports his/her wastes for their special waste hauling permit number and should obtain from the facility where the waste is being taken, their permit number and facility ID number.

Do I have to submit an annual report?

A generator of non-hazardous special waste who generates more than 220 pounds in any month must submit an annual special waste report to the Agency by February 1 if the generator sends any non-hazardous special waste out of state.

A generator of hazardous waste who generates 2200 pounds or more in any month must submit an annual hazardous waste report to the Agency by March 1.