If you’re a business owner, you might feel like you already have enough on your plate without worrying about the proper disposal of hazardous waste, particularly if your company doesn’t belong to one of the industries that typically ranks high up on the list of significant hazardous waste producers. But regardless of what industry you’re in or how big or small your company is, it’s important to pay attention to your handling of hazardous waste.
Improper handling and disposal of hazardous waste is not only harmful to the environment and human health, but it can also lead to heavy fines or other penalties under the Resource Conservation and Recovery Act (RCRA). Read on for a list of nine hazardous waste violations and mistakes that all business owners should take care to avoid.
One of the biggest (and most easily prevented) reasons for RCRA non-compliance is improper waste identification; that is, simply not knowing what is and is not classified as hazardous waste. Business owners should be sure to stay up to date with the RCRA Orientation Manual, which has clear and helpful guidelines for hazardous waste identification; any uncertainties should be referred to representatives of state or federal regulatory agencies.
The EPA and its representatives have the authority to conduct periodic inspections at facilities to monitor regulatory compliance regarding hazardous waste management. But often, businesses are inadequately prepared for these inspections. Companies should not only have critical records readily available during the inspection (including waste identification reports as described above), but they should keep a comprehensive log of the inspections themselves for future reference, including key details like the name of the inspector, the date and time of the inspection, and any potential problems that were identified.
Proper reporting of hazardous waste handling and management can be an administrative burden, but it’s an important part of ensuring compliance and minimizing the likelihood of unexpected regulatory inspections. Large quantity generators (producing at least 1000 kilograms of hazardous waste or 1 kilogram of acutely hazardous waste every month) and small quantity generators (producing more than 100 but less than 1000 kilograms of hazardous waste monthly) each have different reporting requirements and timelines, so businesses should be sure to know which category they belong to, and follow the requirements accordingly.
One of the most easily visible hazardous waste violations is waste storage containers that are either left open or are in poor or damaged condition. Except when adding or removing waste, drums and other hazardous waste storage containers must be fully closed at all times; in addition, containers should not have any holes or leaks, and they should not be handled in a manner that might cause them to rupture.
All business owners should be in the habit of keeping hazardous waste storage containers clearly labeled. Not only should the waste be identified as hazardous, but the accumulation dates (i.e., the exact date and time that the first waste was added to the container) should be easily visible.
A contingency plan that addresses courses of action in an emergency is mandatory for large quantity generators. But even though many businesses create such a plan, it’s not always updated as often as it should be. A contingency plan should be reviewed at least once a year to ensure that all information, particularly contact information, is current. Copies of the plan should be kept next to one or more on-site phones, and sent to local authorities.
Staff and personnel training.
It’s one thing to have a contingency plan, yet another to have properly trained personnel who can put the plan into action if need be. Business owners must not neglect staff education and training concerning hazardous waste management and handling, both on a daily basis and in the event of an emergency. Training initiatives are particularly important when there are major changes at the facility or when new procedures go into effect. All training should be properly documented.
Transporter and manifest requirements.
Businesses are not only responsible for hazardous waste while it’s on their property, but they’re also responsible for its proper transport to an appropriate disposal facility. Businesses must be careful to correctly follow the manifest system, under which the transporter acknowledges the acceptance of waste from the facility in question. Copies of the final manifest received from the disposal facility should be kept on record.
Universal waste management.
Universal waste is a special category of waste that contains very common hazardous materials (batteries and mercury thermometers are two examples of universal waste items). But even though these types of waste are common, there are still rules to be followed in their handling and management. All universal waste must be stored in securely closed and clearly labeled containers; in addition, the allowable time frame for storing universal waste before its disposal is limited to one year.