Take a look at these five reminders about hazardous waste and consider how well your company complies with Federal, State and Local Regulations.
5 Important Reminders Concerning Hazardous Waste Disposal
Today’s business world is changing at a rate unimagined even a generation ago. Business leaders are adapting to new marketing channels—via the web and social media. New technologies are changing the way materials are transported and the way products are created and sold. The world is your market place—but that greatly increases the competition you face for market share. As a CEO or business manager, it can be overwhelming trying to keep up with these rapid changes that have such profound impacts on your business decisions. That’s why you hire personnel who possess the skills and expertise to address these challenges in ways that will grow your market share.
Another one of those rapidly changing details pertains to Hazardous Waste. It’s not a glamorous topic, but it can have a profoundly negative impact on your company’s growth, market share and reputation if you don’t stay on top of things. Take a look at these five reminders and consider how well your company complies with Federal, State and Local Regulations.
First Reminder—Never Dump Illegally
This may seem obvious, but many companies, large and small, take tremendous risks to save the cost of proper disposal in the hopes they won’t get caught. Illegal dumping on public or private property, dumping waste into waterways or municipal sewer systems or even dumping on your own property without having the proper license can result in crippling fines, restitution and remediation expenses and embarrassing publicity. Depending on the severity, illegal dumping can be punished as a felony that may include incarceration.
Second Reminder—Properly Label and Date Hazardous Waste Containers
In the busy process of your production environment, it’s easy to forget this seemingly trivial task. As a generator of Hazardous Waste, your waste containers must indicate the accumulation dates as well as the date of the first addition to the container. The container must be clearly labeled with the words “Hazardous Waste.” Proper training and assigning responsibility to a specific employee goes a long way towards complying with this requirement. Document your training policies, provide (and document) refresher training at least annually or as new procedures go into effect. Ensure your hazardous waste containers meet applicable safety requirements and are compliant with regulations through a regular inspection program, keeping logs of these inspections that include the inspector’s full name, date and time and any problems noted.
Third Reminder—Keep Hazardous Waste Containers Closed
Hazardous Waste Containers that are open or in poor condition will guarantee a regulatory violation. Under the EPA standards, “closed” means leak proof and vapor tight. The Agency may consider leaving the lids off of your hazardous waste containers as a “treatment” since the volume of hazardous waste may be reduced by evaporation. Post notices in the areas where hazardous waste accumulates and provide regular reminders to your employees, especially if you have high employee turnover rates at your facility.
Fourth Reminder—Maintain a Current Contingency Plan
If you’re a Large Quantity Generator of hazardous waste, you must create a contingency plan that covers all potential emergencies and the proper coordinated response pertaining to hazardous waste. Your plan must contain emergency contact information (name, address and phone number) for key managers and must be posted at an on-site phone. You must update the plan when significant changes occur at your facility and local authorities should receive a copy as well. Annual reviews and updates will help ensure you keep current on regulatory changes as well as your own operational changes. Include contingency plan training as part of all relevant new hire orientations.
Fifth Reminder—Document Disposition of Hazardous Waste
It’s not sufficient to comply with all of the regulatory details concerning the collection of hazardous wastes at your facility. You must also document the proper disposal of all the hazardous waste you collect. Your hazardous waste transporter should be using a manifest system that acknowledges their acceptance of the hazardous waste from your facility. You are responsible for maintaining copies of the final manifest to document your compliance with disposal requirements.After that quick review, how are you feeling about your company’s hazardous waste program? Do you feel confident that your company is in full compliance? Or did these reminders trigger a need to reexamine your program? Remember, these five reminders only cover the basics. There are many other details pertaining to Hazardous Waste Management and Disposal that will be subject to inspection. We hope these five reminders will provide a starting point for a total review of your Hazardous Waste Program.
Mike Watts, President, Pinnacle Environmental Services, Inc. http://www.pinnacleenv.com
