What Manufacturers Must Know About Hazardous Waste Disposal

Posted by author Richard Espinoza on Thu, Mar 10, 2016

As environmental regulation in the United States has become stricter, it is important for American manufacturers to understand their obligations when it comes to handling hazardous waste generated in their factories.


hazardous waste disposalHazardous waste that falls under the Resource and Recovery Act of 1976 (RCRA) needs to be properly identified, packaged, transported, and disposed of. As a hazardous waste generator, you are legally and financially responsible for that waste until it’s been properly treated and disposed of, from cradle to grave.

Every state has slightly different rules and regulations as they apply to the handling of hazardous waste and hazardous waste labels. Now more than ever it’s important to comply with those regulations and one of the best decisions is reaching out to a local hazardous waste disposal company to guide you through this process.

Because the onus falls on you to ensure your waste is disposed of properly, you must ensure that your hazardous waste disposal company is experienced, reputable, and knowledgeable.

Choosing the wrong vendor can have drastic consequences for you and your business, so make sure before anything else that you vet this company for years in the business, honesty, and experience with your particular waste stream.

Here are 5 things to look for:

Credibility

Any good vetting process begins with a thorough background check of your vendor.  Along with the basics state and federal licenses, it is a good idea to formulate a list of questions that your vendor should be able to answer quite easily. 

Here are a few questions to ask in the research and interview process:

  • Are they financially sound e.g., Dun &Bradstreet report, Bank letter of credit, etc.?
  • Are they properly permitted for the transportation, storage, treatment and disposal of waste identified at your facility?
  • Are they able to demonstrate a good sound history of regulatory compliance?
  • Do they meet minimum insurance requirements and have coverage for accidents?
  • Do they have adequate personnel that are properly trained and certified?
  • Are they able to provide a statement of qualifications (SOQ)?
  • Do they have procedures for dealing with unknown chemicals?
  • Are they able to provide a list of capabilities/services (e.g, transportation, disposal, treatment, identification of unknowns, etc.)?
  • If using subcontractors, are they able to identify which companies are utilized and for what activities?
  • Are they able to identify how materials they handle will be managed?
  • Are they able to provide a list of references on past related projects?

 

Experience

There is no substitute for experience. One suggestion is to consider working with a hazardous waste generalist. If you are a manufacturer that produces various waste streams from chemicals used in the manufacturing process to solvents used for cleaning and degreasing, a hazardous waste generalist may be your best bet, because of the breadth of their experience in handling different types of toxic waste.

A hazardous waste generalist can handle a variety of wastes. Services typically include:

  • Identifying the waste streams (profiling and testing them)
  • Development of site-specific plans (including training and emergency preparation)
  • Transportation to recycling and disposal sites
  • Manifest Preparation and other state and federal paperwork

Because they are used to working in different environments, generalist typically have a broad base of experience and are used to working with different toxic chemicals.

They can handle everything from your non-hazardous chemicals all the way up to radioactive materials.

Beware of the Broker

A broker is someone who sits in a room, usually a home based business, and makes bids on disposal jobs. They typically contact several different transportation companies to get the lowest bid, then add a nice fee for themselves and hand off the job to the transportation company that gave them the lowest bid.

Ok, so what! I get the lowest price and my waste is handled for me. Possibly true, but what if something happens to the waste before it is disposed of correctly? Was the disposal company the broker hired a legitimate company? Were they certified to handle your type of waste? Did they have adequate insurance? It’s a huge risk to take when dealing with brokers because you are never certain how your waste is going to be handled. It’s your business on the line, why take the risk!

Consultative

An ideal certified product disposal company is consultative.

Keeping up with hazardous waste regulations is a full time job, and many manufacturing facilities simply do not have the man power and experience to ensure compliance with all state and federal regulations. 

This is where a company that is consultative in nature is worth their weight in gold.

Look for companies that have a hazardous waste walk-through program.

A hazardous waste walk-through program will focus on several key components to regulatory compliance. Areas of focus should include:

  • Waste Manifesting
  • Hazardous Waste Procedures
  • Waste Storage Evaluation
  • Emergency Readiness
  • Hazardous Waste Evaluation
  • Employee Training Procedures

Experienced technicians 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 regulatory inspection is good business practice.

Flexibility

 As a manufacturer, you will need a company that can be flexible.  As your business and products change, so too will your disposal needs. An unusually large or customized order can lead to the creation of hazardous waste in greater amounts than you’re used to.

Large or varied orders can also create different types of waste that your environmental manager isn’t used to dealing with. If you’re lucky, your manager will have the time and foresight to learn all of the different legal requirements to accommodate these changes. If not, your company could find itself in violation of numerous local, state, and federal laws.

With flexible pick up schedules, a good hazardous waste disposal company will be there when you need them most.

As a manufacturer, your time is better spent focusing on sales, purchasing and production schedules and other key tasks that move your company forward.  Working with a qualified, experienced and honest hazardous waste disposal company lets you focus on what’s important, your business.

A great local company is worth their weight in gold!

Image: Photo by Aqua Mechanical / CC BY

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