New Requirements for Treated Wood Waste Management
Updated: Mar 31
As of January 1st 2021, the State of California banned the disposal of Treated Wood Waste (TWW) in Class II and III landfills. Read on to find out what that means for the worlds of construction and stormwater alike.
Why Treated Wood Waste is Toxic
According to California's Department of Toxic Substances Control (DTSC), "TWW contains hazardous chemicals that pose a risk to human health and the environment. Arsenic, chromium, copper, creosote, and pentachlorophenol are among the chemicals used to preserve wood and are known to be toxic or carcinogenic. Harmful exposure to these chemicals may result from touching, inhaling or ingesting TWW particulate (e.g., sawdust and smoke)." Given these qualities of TWW, proper disposal is crucial to public and environmental health.
Transitioning to New Standards
While previous Alternative Management Standards allowed for TWW to be disposed of at Class II or Class III landfills, current legislation requires disposal at Class I Hazardous Waste Landfills exclusively. In her coalition response letter, Meredith Williams, Ph.D., and Director of DTSC acknowledges that transitioning to this new requirement could be difficult for TWW handlers.
To assist with this difficulty, DTSC will allow temporary variances that will let TWW be managed according to previous Alternative Management Standards. However, applying for temporary variances are not yet available; the application process is projected to open up in mid-February of this year. For more information on temporary variances, or who to contact if you have questions about general TWW management, see here.
Treated Wood Waste and Construction
Caltrans' Division of Construction Chief, Rachel Falsetti, has released a memorandum on how these new requirements will affect Caltrans construction projects. The expectation is that TWW is to be designated on the hazardous waste manifest and transported to a Class I hazardous waste landfill in accordance with the 2021 standard.
Caltrans is also requiring Resident Engineers to revise Standard Specifications that include "Treated Wood Waste" in Section 14-11.14 to adhere to the new TWW removal guidelines. Falsetti elaborates on the storage of TWW, stating that "it will only be allowed in secured metal containers approved by the U.S. Department of Transportation no longer than 90 days from the start of waste generation."
While the above storage requirement is specific to Caltrans construction projects, the DTSC has outlined TWW storage guidelines that non-Caltrans projects should abide by. The DTSC fact sheet specifies that TWW is to be "stored in either a closed container, on a properly configured drip pad, or inside a hazardous waste storage building."
Ultimately, all construction projects within California are expected to follow DTSC guidelines regarding the disposal of TWW waste management.
Treated Wood Waste and Stormwater Management
When it comes to TWW management and stormwater, we'll be taking extra care to update our BMP narratives to reflect the new legislation. While performing inspections, we'll also be keeping an eye out for proper TWW storage on site. Whether your site is public, private, Caltrans, or CASQA-affiliated, we'll help you comply with this new regulation.
If you have questions about TWW management, BMPs, rain event prep, or anything else stormwater-related, ask your QSP! For tips on preparing your site for Winter Weather, check out our guides here.