For hazardous waste generators one of the most challenging aspects of your operations is selecting a hazardous waste vendor for transportation and disposal of your waste streams. As an RCRA regulated business, you are ultimately responsible for the waste from "cradle to grave."
Pick the right vendor and they will be able to help you stay in compliance with state and federal regulations, provide minimal disruption to your operations and find ways to save you money on the disposal process.
Choose the wrong vendor and you can end up with more headaches than you bargained for in terms of increased liability, fines and financial disaster.
Here are 5 tips to aid in your search for the right vendor.
As business owners we are conditioned to look for the best price when selecting vendors. The best vendor for you isn't necessarily the least expensive one. Many companies have gotten into hot water by settling for short term cost savings resulting in long term headaches like extensive fines and lawsuits.
As the old saying goes, “If it is too good to be true, it probably is.” There are many unscrupulous vendors that are just looking to make a buck and do not handle the waste in the correct fashion. Here is a great example of the danger of selecting the wrong vendor.
Remember the “cradle to grave” provisions of RCRA mean that the waste generator has the ultimate responsibility for what happens to waste streams, even if you outsource. YOU ARE RESPONSIBLE!
Performing due diligence background checks on your vendors is a good business practice that can limit headaches down the road. At a minimum check the following:
Financial references - Dun &Bradstreet report, Bank letter of credit, etc.
Insurance – Ensure that they have business liability and workers compensation insurance
Proper Licensing – EPA, Department of Toxic Substances Control, Department of Transportation
Regulatory Compliance – Check with the DTSC in California
Make sure their employees are properly trained
Another important part of the due diligence process is speaking with references provided by your potential vendor. Ask your prospective vendor to provide the names and phone numbers of current customers as references.
Make sure that you follow up with these references and check to see how satisfied they are with the company's services, employees and the quality of their work. Make sure that you ask the company to provide references that have similar waste streams.
If your business or research facility produces a number of hazardous wastes, it is crucial to find a vendor that can provide a variety of services. Consider hiring a general hazardous waste vendor. These vendors or brokers have experience with a variety of waste streams. Services typically include:
Identifying waste streams (profiling and testing them).
Transporting wastes to recycling and disposal sites.
Preparing Manifests and EPA/DTSC Paperwork
Providing Training Solutions for your employees
Hazardous Waste Walk-Throughs
It's a good business practice to conduct yearly environmental audits of your hazardous waste vendor. The Registered Hazardous Waste Transporter Database is a great place to start. Any business can run into rough patches and their service can become unreliable. With fines and investigations on the rise, it is more important than ever to work with a reliable company. Make sure that you do your part to ensure that the company is performing.
It’s not hard to find a capable hazardous waste vendor that can handle your waste streams and ensure that you are acting within compliance with all federal and state regulations regarding hazardous waste. Knowing what to look for as you begin the process of selecting a vendor can help you establish a strong relationship and ultimately reduce your liability exposure.