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Companies that produce hazardous waste must adhere to a large array of compliance obligations and numerous environmental regulations. These companies bear a significant liability which can be mitigated to a certain extent, but never entirely eliminated. In the event that hazardous waste is mismanaged, there can be substantial financial penalties and public relations damage to an organization. Waste management violations can be avoided by implementing a few practices that reduce the risk of the generator. Determination of hazardous waste – Determination of hazardous waste may seem like the simplest part, but it is actually the fundamental reason behind most violations. There is a direct impact on the generator’s ability to abide by mandated labeling, storage, segregation and disposal requirements for that waste. If hazardous waste is misclassified as non-hazardous, huge fines can be imposed. And on the other hand, over-classifying of non-hazardous waste can pointlessly increase company liability and increase spending. To make sure that hazardous waste is handled efficiently, it is best to always: (a)Analyze all waste generated on site (b)Handle unknown material as hazardous waste (c)Keep a record of the assessments of hazardous and non-hazardous wastes By definition, if the material is not a solid waste, it cannot be termed as hazardous. It is therefore important to understand that the definition of a solid waste is completely independent of its physical form, whether solid, liquid or gas. There are usually two options for identifying waste. One is to apply ‘process knowledge’ information about the raw materials, which can be somewhat effectively obtained from the materials safety data sheets (MSDS) or other manufacturer or vendor supplied resources. Or, alternately, a laboratory analysis of the waste can be conducted. This can be an expensive process, although it is a more definitive basis for classification. Vendor Management - When it comes to disposing of hazardous waste, many companies rely heavily on vendors. It is very important to select a vendor carefully as it is the generator who is ultimately responsible for the disposal of the waste. A reputable vendor will be able to recommend the most cost effective and environmentally preferred options for the disposal of hazardous waste. The following tips can be kept in mind when selecting a vendor to help minimize the generator’s risk: (a)Vendors need to accessible on an emergency basis. (b)If there is a need for the vendor to use subcontractors, comprehensive examination should be done. (c)The vendor should be able to provide a listing of: Hazardous-waste response capabilities Regulatory compliance, as evidenced by current licenses Customer service records, customer references and personal experiences. (d)Hazardous waste vendors need to meet a minimum standard of insurance coverage. (e)Vendors must commit to a regular review of their performance. When qualifying vendors, it is also important to be updated on where the waste will eventually be disposed. It is important to specify approved treatment, storage and disposal facilities. There are some vendors who transport waste to their own TSDFs (treatment, storage, and disposal facilities) and others who are waste brokers. To control the generator’s liability, it is essential to know how and where the waste is to be disposed. Document control – In hazardous waste management, there are regulations that specify the need for generators to retain specific records pertaining to the generation and disposal of hazardous waste. Records like hazardous waste manifests, biennial reports, etc., need to be maintained for three years. LDR, or land disposal restriction, notifications and certifications need to be maintained for a minimum of five years. As there could be a direct impact on compliance, accurate retention is a must. It is best to have an electronic records system that can provide instant accessibility to the necessary documentation. Managing hazardous waste can be a very involved task. Sound hazardous materials management software can mitigate the risk and liability involved in the disposal of hazardous waste. Also having sophisticated materials management can provide cradle-to-grave tracking of materials.
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