When it comes to continuous improvement, the primary focus of the majority of industrial facilities is production. This type of industrial management is a sensible approach, as production can have the greatest impact on the facility’s profitability. However, singularly focusing on products generated by a facility while ignoring waste generation can be costly not only from a financial perspective but also from a regulatory compliance perspective as well.
In order to decrease the possible risks associated with improper waste management, it is beneficial to examine some of the more common mistakes made throughout industry. This ensures that a facility has a solid foundation from which to build out a waste management program that covers the proper handling of all of its waste streams.
Mistake #7: Not Preparing a Waste Minimization Plan:
Any generator who ships hazardous waste has to certify a waste minimization statement on the hazardous waste manifest prior to shipment. This certification statement changes depending on the generator status. A Very Small Quantity Generator (VSQG) is not required to make a certification statement according to 40 CFR 262.27.
A Small Quantity Generator (SQG) is only required to make a good faith effort to minimize waste generation and select the best waste management method available based on cost. How a SQG proves that the effort has been made is left open-ended and is not well defined, but it is recommended that records be maintained that demonstrate these efforts. This may include material substitutions, schedule changes, training updates, improved operating or housekeeping, and process or equipment changes.
A Large Quantity Generator (LQG), however, is actually required to have a program in place to reduce the volume and toxicity of waste generated in a manner that has been determined to be economically practicable and which minimizes the present and future threat to human health and environment. The Code of Federal regulations does not specify the program requirements or whether it needs to be maintained in a written format, because the management of these programs typically falls to the State.
These programs can have differing names depending on the state in which the generator is located. Some common examples are the Waste Minimization Plan, Waste Reduction Plan, and Pollution Prevention Plan. Another important point about these plans is that not only do the names change from state to state, but the requirements also differ as well. Generally, these plans will require some form of the following: Description of the processes that generate Hazardous Waste, Description of Hazardous Waste Streams, Waste Reduction Policy, Waste Reduction Performance Goals, Previous and Potential Waste Reduction Activities, Impediments to Waste Reduction, and Employee Awareness/Training. A facility’s Waste Minimization Plan may also require consistent update and submittal to the State for review alongside Biennial Hazardous Waste Reporting.
Mistake #8: Not Preparing a Contingency Plan:
All Large Quantity Generators (LQGs) are required to prepare a Contingency Plan according to 40 CFR 262.260. The purpose of the Contingency Plan is to minimize human heath and environmental hazards from fires, explosions, or any unplanned releases of hazardous waste. Contingency Plans ensure that facilities have examined possible emergencies that can occur as a result of the types of hazardous waste generated and stored. These plans require a facility to maintain equipment, measures, and procedures that can be enacted in the event of an emergency. Unlike Waste Minimization Plans, Contingency Plans are clearly defined by federal law as to the required content.
The Contingency Plan must include a description of the actions that employees will take in response to fires, explosions, or unplanned releases of hazardous waste. These actions include emergency procedures such as activation of facility alarms, notification to state/local agencies, characterization of the release, assessment of possible hazards, taking reasonable measures to ensure fires, explosions, and releases do not reoccur, management of resulting hazardous waste, and remediation of the impacted area. The majority of these actions fall under the responsibilities of the Emergency Coordinator(s).
The Contingency Plan must also include a description of arrangements made with the local fire department, police department, hospital, Local Emergency Planning Committee (LEPC), and other emergency response teams. A copy of the Contingency Plan must be submitted to all of the facility’s emergency responders along with a Quick Reference Guide.
All of the names of the Emergency Coordinators and emergency phone numbers must be included. Any Emergency Coordinators must be reachable at all times. All emergency equipment must also be listed in the plan along with the location, description, and capabilities. This includes alarm systems, spill control equipment, firefighting equipment, and decontamination equipment. In addition, the plan must also include an evacuation plan for onsite personnel in areas where evacuation could be necessary. The signal for initiation of evacuation, evacuation routes, and alternate evacuation routes must also be provided. Oftentimes it is most efficient to provide the emergency equipment and evacuation information in the form of a map or multiple maps.
What to do next?
If you find that your facility may need to consider addressing Waste Management issues onsite, Conversion Technology, Inc. (CTI) can provide consulting assistance to ensure that all of your issues and questions are addressed. CTI has had over 30 years of experience working with industrial facilities to assist in proper management of waste. This includes onsite Waste Management Audits, preparation of Hazardous Waste Reports, preparation of Hazardous Waste Contingency and Waste Minimization Plans, preparation of Hazardous Waste Fees, preparation of Site Identification Forms, and provision of Hazardous Waste Training. We will be happy to assist you with whatever consulting services you are in need of.
Look out in our next Quarterly Newsletter for the next part in this 4-part series on common Hazardous Waste Management Mistakes.