If your company regularly manages hazardous waste on its property, you know you should routinely remove it and transfer it to the appropriate disposal facility.
Like any area of your business, waste disposal may seem like an area where there are opportunities to reduce costs. After all, your bottom line matters when it comes to your company’s success.
There’s a big difference between properly managing costs and cutting corners, and hazardous waste disposal is one area you don’t want to do the latter. Otherwise, you could be opening yourself up to significant fines if your hazardous waste is not disposed of properly.
Look no further than the case against Ulta Beauty and other companies that have faced steep fines from federal and state regulators for not ensuring their hazardous waste was transported and disposed of according to the law.
So how do you ensure that your waste is transported to hazardous waste disposal sites?
Transport Hazardous Waste Yourself
In many states, including California, it is against the law for any person to transport hazardous wastes. The only individuals who may do so are those who hold a valid registration, and the Department of Toxic Substances Control (DTSC) must issue this registration.
There is one exception to this … if you are a conditionally exempt small quantity generator (SQG). Federal regulations allow you to transport your waste to a household hazardous waste collection facility. However, in CA conditionally small quantity generators do not get this exemption. To determine if you are a Large Quantity Generator or a Small Quantity Generator, click the link to learn more.
It’s important to keep in mind that as a generator, you are responsible for your hazardous waste from the moment it is generated to when it is properly disposed of (known as cradle to grave).
Don’t Hire A Hazardous Waste Broker
A hazardous waste broker is NOT the same as a hazardous waste transporter.
Brokers typically do not own a hazardous waste transportation business. They act as a middleman between the buyer (you) and the transportation company that takes your waste to a disposal site.
Here’s how the broker process often works:
- You look for a company online to give you a quote to dispose of your hazardous waste.
- You find a company that seems to fit your needs and place a request for a quote.
- What you will likely not know is that the company you just made the request from is not a hazardous waste transportation company, but a broker. To understand if you are talking to a broker, read our article Hazardous Waste Transporters vs Brokers.
- The broker receives your request and then starts calling hazardous waste transportation companies to get a price from them for your disposal.
- The broker takes the quoted price then marks it up with whatever percentage it wants and submits the quote to you for approval.
In the end, you pay more for a service you could receive directly from a waste transportation company. Perhaps more disturbing, you lose control over who is handling your waste. There is no way to know who the broker is using to transport your hazardous waste.
That means you run the risk of the broker using an unlicensed transportation company. If something goes wrong during transport, your business is at risk due to cradle to grave requirements.
Hazardous waste brokers also do not need any qualifications to sell you disposal services. These brokerage type businesses could even be call centers handling inquiries and processing orders.
Work With A Hazardous Waste Transporter
Working with an experienced hazardous waste disposal company to transport your waste can ensure your business is in compliance and meeting all regulations.
The best disposal companies will work with you to establish a waste management plan that covers all areas of your operations … from the moment the waste is generated to its final disposal.
Here is what reputable hazardous waste services will offer to ensure the entire process of transporting your waste to disposal sites is seamless. They will:
- Identify uncertain waste streams through profiling and testing to ensure the right TSDFs receive the right waste.
- They will evaluate your waste streams to determine if the waste could be reclassified as non-hazardous waste and save you money on the disposal fees.
- Develop site-specific plans that include training and emergency preparation so that the preparation that takes place before transport is safe and efficient.
- Transport your waste to the proper recycling and disposal sites.
- Prepare a manifest and other state and federal paperwork required for transport.
- Offer evidence that your waste has been properly disposed of at the treatment and disposal facility.
It’s important to note that even before transportation takes place, it’s vital to make sure your company is equipped with the tools and procedures it needs to ensure storage and disposal are according to regulations. One way to ensure this is if the disposal company you work with offers a hazardous waste walk-through program.
This service evaluates your hazardous waste procedures, allowing for potential issues to be caught before they become costly mistakes. A walk-through is also collaborative and ensures that your company and employees are protected and in legal compliance with transport areas like waste manifesting, proper labeling procedures and emergency readiness.
If you decide to work with a hazardous waste transporter, what should you look for in a disposal company?
- All background checks passed: This includes checking state and federal licenses (Motor Carrier Permit, DOT Hazardous Material License, DTSC Transporter Registration, etc.).
- A great reputation: Ask for contact information of clients the disposal company has worked with so that you can hear about their experiences first-hand.
- Consultative in nature: You may hire a transport company to take your waste off site, but the best disposal companies do much more. A walk-through program is a good example of a company that has your best interest in mind and will work with you to improve all areas of your waste transport process.
- Knowledge of your types of hazardous waste: There are many types of hazardous waste that require special disposal, from e-waste to medical waste. Each type has its own set of disposal regulations that must be followed.
- Knowledge of state and federal laws: If your waste is being transported across state lines, a disposal company should be aware of all laws pertaining to your type of hazardous waste in every state it travels.
Transporting hazardous waste to disposal sites is anything but a point A to point B route. There are many steps that must be taken before, along the way and during disposal to ensure your hazardous waste is being disposed of properly and according to the law.
Working with a trusted hazardous waste transport can provide reassurance that your business is in good hands.
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