Life on the floor of a manufacturing facility is hectic. There are deadlines to meet, quotas to reach and new problems to solve every day. For many managers, keeping up with production schedules and overseeing employees is a huge challenge.
Add the regulatory complexities of the Resource and Recovery Act of 1976 (RCRA) and the requirement to operate within the scope of hazardous waste compliance, and now you have an overburdened staff.
The mindset for many companies is that employee productivity and producing goods take precedence and hazardous waste compliance issues can be easily put off until tomorrow.
For some, however, TOMORROW can come at the most inopportune times, like when a federal or state regulator comes knocking at the door. The good news is that a hazardous waste walk-through can ensure you are operating in compliance.
What is a hazardous waste walk-through? A hazardous waste walk-through is an evaluation of your hazardous waste procedures. An experienced and properly licensed hazardous waste company should perform the walk-through to ensure that your hazardous waste procedures meet all state and federal regulations.
If keeping up with regulations is a full-time job for you or your staff is overburdened with ever-changing laws, here’s how a walk-through can help.
Regulatory Burdens Are Eased
For many hazardous waste generators, the answer to the question, “Am I operating in compliance?”, is decidedly no. Operating within compliance requires two things:
- Someone monitoring the Environmental Protection Agency (EPA), Department of Transportation (DOT) and California Department of Toxic Substances Control (DTSC) to stay current to changes in the law.
- Regular process review to ensure that your operating procedures are current and within regulation.
Many companies...even those known for cutting edge facilities and efficient processes…have holes in their hazardous waste operations. Many are utilizing outdated operations manuals (some that haven’t been updated or reviewed since Ronald Reagan was president) and implementing procedures from a bygone era.
For large companies that operate facilities in multiple states, the regulatory burden is compounded. What passes in Texas or Arizona may not fly in California and vice versa.
An experienced hazardous waste management program will take the burden of keeping up with continually changing federal laws and different state laws off your staff so that they can focus on their roles within your company.
Potential Issues Are Caught
The goal of a hazardous waste walk-through program is to catch potential regulatory issues before they become costly mistakes.
A California glass manufacturer learned that the hard way when it was fined $3.5 million for not having a contingency plan, which the DTSC and EPA require. So did Clean Harbors Environmental Services, which federal regulators fined $790,000 in civil penalties for improper waste management.
So, what areas does a hazardous waste walk-through focus on to catch any potential issues?
- Waste manifesting
- Hazardous waste procedures
- Waste storage evaluation
- Proper labeling procedures
- Emergency readiness
- Hazardous waste evaluation
- Employee training procedures
This process is collaborative and ensures your company and employees are protected and in legal compliance. It’s important to note that in many cases, a hazardous waste walk-through will identify outdated procedures that were once legal but have been changed over the years and are no longer valid.
The best hazardous waste companies will also identify ways to save money, including combining waste streams or looking for new and better ways to dispose of your waste more efficiently.
Remember … a walk-through is NOT an audit of your operations. It’s a collaborative effort to determine what potential issues need to be addressed.
Effective Solutions Are Offered
Experienced advisers who are current on both the federal and state laws can pinpoint areas of concern and provide cost effective and simple solutions to hazardous waste violations.
Many times the solutions require only minor changes in procedure and can provide cost savings to the company. Like going to a routine checkup at the doctor, pinpointing areas of concern before you have a DTSC inspection is good business practice.
If you are just beginning your research on hazardous waste management or you are an experienced manufacturing company evaluating your operations, a great place to begin your research is to download a copy of our eBook, “The Top 10 Hazardous Waste Violations and How To Avoid Them.” In it, you will find the most common sources of regulatory fines.
Knowing how to identify any potential problems with managing hazardous waste can be costly if not handled correctly.