A recent fine against a biopharmaceutical manufacturer in California is yet another example of how an oversight in how you manage the hazardous waste your business generates can lead to costly consequences.
The U.S. Environmental Protection Agency recently announced it had settled with Genentech over environmental regulations that took place at one of its former plants. The result: Genentech must pay $158,208 in civil penalties.
In August 2021, EPA inspectors discovered a number of violations at the company’s former South San Francisco plant, including:
Earlier this summer, the EPA issued fines for two other companies in a separate incident for also failing to meet hazardous waste regulations. That incident also resulted in a steep fine of $230,000.
The lesson all companies that generate hazardous waste should take away: Mishandling hazardous waste can lead to costly fines and hurt your public image as a member of your community.
Yet these incidents aren’t simply mistakes - they’re often instead the results of systemic issues that demand immediate attention and comprehensive solutions. And to prevent these issues, it’s critical to take a look at how you manage your hazardous waste, from the moment it is generated to the moment it is disposed of.
If …
Then … you’re at serious risk for many of the same costly fines and tarnished public image the companies above are facing. Here’s what you need to know to avoid the same headlines.
During a visit to Genentech’s former plant in the city of South San Francisco, inspectors discovered that the company
Storing hazardous waste is a critical aspect of maintaining safety in the workplace. Hazardous waste poses a threat to human health and the environment, so it must be carefully managed on-site while it awaits disposal.
In the case of Genentech, the company’s violations came in the form of failing to secure a permit for the waste. Yet there’s several more areas of waste storage that you must consider to ensure you’re meeting state and federal regulations (and avoiding fines).
Here are some additional areas of concern that companies should address when evaluating their waste storage management:
In light of the Genentech case, it’s evident that even well-established companies can fall short of compliance when it comes to hazardous waste storage. Any company that generates hazardous waste should prioritize developing a hazardous waste management plan that helps the business not only avoid fines and legal issues, but also to protect the environment and the well-being of their employees and the surrounding community.
Inspectors also found that manifests for the waste being held on-site didn’t include all the required federal waste codes, according to the EPA.
Waste codes are essential for identifying the nature and characteristics of the hazardous waste that is being stored. They provide critical information about the waste’s composition, toxicity and potential hazards, which is essential to preventing an emergency or if one occurs. Without complete and accurate information, responders may not have the necessary details to mitigate the situation.
Some states also require state-specific waste codes in addition to federal waste codes. California waste codes are typically three digits, according to the California Department of Toxic Substances Control, and identify certain characteristics like whether the substance is an alkaline solution, the type of solvent, or it’s a pharmaceutical waste, among others.
Hazardous waste codes are just one portion of the manifest, however. A hazardous waste manifest tracks a shipment from the point of generation through transportation to the final treatment storage and disposal facility (TSDF). If you generate hazardous waste, you must submit a hazardous waste manifest that ensures your waste is correctly identified and is being handled accordingly within the law.
You must also register in the e-Manifest system to view manifest records and submit any data corrections to your manifests.
Key types of information that are found in manifests typically include:
Manifests, as well as any type of record keeping, ensures transparency, compliance with regulations and the safe management of hazardous waste from cradle to grave.
Another area of concern that the EPA addressed in its allegations involved Genentech’s role in failing to maintain overfill protection controls for a hazardous waste tank on the property.
Hazardous waste storage areas should have environmental controls in place to prevent contamination of soil, groundwater or nearby water bodies. These controls may include secondary containment systems, spill response kits and measures to prevent rainwater from coming into contact with the waste.
When these controls are not properly maintained, there is a heightened risk of breaches that could lead to spills or leaks, endangering both the environment and the surrounding communities. Lapses in maintenance can not only violate environmental regulations, but also by a symptom of a failing waste storage infrastructure that doesn’t prioritize safety.
You may have several procedures in place that ensure the waste your business generates is being handled and stored safely when on your property. But what about when that waste leaves the safety of your facility? Unfortunately, not all disposal companies are created equal.
While all hazardous waste disposal companies must be registered with the state of California, you should go beyond checking these certifications when choosing the right disposal company for your business.
Even though your waste is no longer in your hands, you’re still responsible for it until it is safely disposed of. That makes the disposal company you choose to transport your waste an extremely important decision.
A hazardous waste disposal company should:
The best disposal partners will also provide you with a free quote and work with you to better understand how your budget aligns with your waste disposal needs.