Hazardous Waste – Regulatory Oversight

Note: Responsibilities for implementing Maryland’s program for the regulatory oversight of hazardous waste are distributed among several units within MDE’s Land Management Administration.  The Resource Management Program is responsible for hazardous waste regulatory development, regulatory interpretation, and permitting for facilities that treat, store or dispose of hazardous waste.  The Technical Services and Operations Program is responsible for managing various tracking and certification programs, including the issuance of site identification numbers (EPA ID numbers), the hazardous waste manifest system, the biennial reporting system, and the certificatio​n of transporters of hazardous waste.  The Solid Waste Program’s Compliance Division is responsible for checking compliance with hazardous waste regulatory requirements.

Hazardous Waste may be produced as a by-product of certain manufacturing operations. In addition, many commercial chemical products are regulated as hazardous waste once they are discarded or intended to be discarded.


Major revisions to Maryland’s hazardous waste generator regulations became effective on May 3, 2021. These revisions incorporate provisions of the U.S. Environmental Protection Agency’s hazardous waste generator improvements rule. More details are found in the document that is linked to “Revisions to Maryland’s Hazardous Waste Generator Regulations” in the above list. 

What is hazardous waste?

To be regulated as a hazardous waste, a substance must either have the potential to cause or contribute to an increase in mortality or serious illness, or, threaten human health or the environment if mismanaged. As a practical matter, a substance is regulated as a hazardous waste if it is specifically listed as such in State regulations, is mixed with or derived from one of those "listed" wastes, or exhibits certain characteristics defined in the regulations.

The characteristics of hazardous waste include ignitability, corrosivity​ (strong acids or caustics), reactivity (explosives or items which can release toxic gases when mixed with water), and toxicity (substances which will release certain levels of toxics when subjected to a test simulating conditions in a landfill).

What can be done with hazardous waste?

Some hazardous waste is recycled into usable products.  Hazardous waste is also treated through chemical, biological or physical treatment to render it non-hazardous. It may also be incinerated or disposed of in a specially designed landfill.

What requirements apply to persons who generate hazardous waste?

Hazardous waste generators must arrange for shipment of their hazardous waste to a facility permitted to accept it or, with the appropriate permits, treat it themselves. A person who ships hazardous waste off-site must use a hauler certified by MDE and the waste must be accompanied by a document that tracks it from generation to disposal (the hazardous waste manifest). A person must comply with regulations on the storage of the waste, and must follow specified procedures to prevent the occurrence of circumstances which would threaten human health or the environment. These requirements are spelled out in Title 26, Subtitle 13 of the Code of Maryland Regulations (COMAR 26.13).

How does MDE check on compliance?

MDE inspectors make routine, unannounced inspections of hazardous waste generators and permitted hazardous waste facilities. Generator facilities found in violation of hazardous waste rules may be penalized under administrative or civil actions. Violations of hazardous waste laws in Maryland may be considered a felony and subject the violator to criminal sanctions, including imprisonment.

How do I report illegal activity concerning hazardous waste?

Email or call the Solid Waste Program's Compliance Division at 410-537-3315. 

What is MDE doing to reduce the generation of hazardous waste?

Persons who generate hazardous waste are required by law to have a program in place to reduce the volume and toxicity of the hazardous waste they produce. The Hazardous Waste Program has a pollution prevention/waste minimization group which assists generators who are attempting to reduce the amount of waste they create. They provide technical assistance and serve as a clearing house for information.

What about hazardous household products?

Persons should strive to minimize the amount of hazardous household waste they generate. Consideration should be given to purchasing less hazardous products. If a hazardous product must be used, only the amount needed for the job should be purchased.

Household waste is exempted from being regulated as hazardous waste. Nevertheless, it should not be disposed of indiscriminately. If you no longer have use for a hazardous product, try to find someone who can use it. Failing that, contact your county government​ to determine if they have a household hazardous waste collection day scheduled.

Are there any proposed actions currently open for public comment?​

BGE Storage Facility Permit Renewal: The Land and Materials Administration of the Maryland Department of the Environment (MDE) has completed the review of an application for renewal of a Control Hazardous Substance (CHS) facility permit. The permit authorizes Baltimore Gas and Electric Company (BGE) to continue to operate their existing CHS storage facility at 7210 Windsor Boulevard, Baltimore, MD 21244. A Public Hearing was held on June 2, 2022, and the public comment period ended on June 13, 2022.  

The final decision of MDE is to affirm the tentative determination to renew CHS Permit Number A-181. The renewed permit is unchanged from the draft permit that was made available for public comment as part of the tentative determination to renew the permit, except that changes have been made to correct 4 internal cross references to other permit conditions, and to address 3 instances where obsolete regulatory citations needed to be updated.
The renewed permit will have an effective date of December 3, 2022.  Separately from the permit, MDE will encourage BGE to complete removal of PCB-containing equipment from BGE’s transmission and distribution system by the end of the 10-year term of the permit.  The "Response to Comments" document contain responses to the comments that were received in writing or at the public hearing. ​Links to pertinent documents are provided here:

​See the ​"Notice of Final Determination" for information concerning rights of appeal of this decision.  For further information regarding this notice or to schedule an appointment to review the administrative record, contact Mr. Edward Hammerberg at (410) 537-3314, or <ed.hammerberg@maryland.gov>.​

U.S. Army Garrison Aberdeen Proving Ground (APG) Permit Renewal: The Land and Materials Administration of the Maryland Department of the Environment (MDE) has completed the review of an application for renewal of a Control Hazardous Substance (CHS) facility permit.  previously issued to U.S. Army Garrison Aberdeen Proving Ground, Aberdeen Proving Ground, Maryland, 21005-5001.  Renewal of the CHS permit would allow APG to continue to treat and/or store hazardous wastes at various facilities and operational units located on the installation, subject to the conditions specified in the permit.  This notice provides additional information about the draft permit, and describes opportunities for the public to review and comment on the draft permit.

The Notice and a Fact Sheet can be viewed here: [link to pdf file of Notice and Fact Sheet]

The draft permit can be viewed here: [link to draft permit]

During the public comment period, any interested person may request a hearing on this matter.  A request for a public hearing shall be in writing, and shall state the nature of the issues proposed to be raised in the hearing.  Requests for a public hearing will be accepted until the close of business on July 5, 2022 and should be addressed to:

Ms. Kaley Laleker, Director

Land and Materials Administration

1800 Washington Boulevard, Suite 610

Baltimore, Maryland 21230-1719

​For further information regarding this notice or to schedule an appointment to review the administrative record, contact Mr. Edward Hammerberg at (410) 537-3315, or ed.hammerberg@maryland.gov.


How can I get more information?

For additional information on hazardous waste reduction email or call the Solid Waste Program at 410-537-3315.

For information on regulatory requirements associated with hazardous waste, email or call the Solid Waste Program at 410-537-3314. 

For information on hazardous waste generator identification numbers (EPA ID Numbers) or hazardous waste hauler certification, email or call the Technical Services and Operations Program at 410-537-3400.

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