Too many business owners shrug off the importance of properly disposing of hazardous waste. Not only does poor waste management harm the environment and reflect badly on your business, but it can also violate important RCRA regulations, placing your company at risk. Education, organization, and vigilant management are crucial, so we’re exploring the top ten hazardous waste violations, so that you can implement effective strategies to avoid them.
Top Ten Hazardous Waste Violations
Recently, Dara Hall of the Arkansas Department of Environmental Quality (ADEQ) Legal Division created a list to identify the top ten hazardous waste violations as well as some helpful compliance strategies. This list echoes the sentiments of the Missouri Department of Natural Resources (MDNR), which created a very similar presentation and list. To encourage proper waste management and help companies and facilities avoid common mistakes, we’re comparing the lists and creating a summary of the top ten hazardous waste violations:
1. Waste Identification
One of the most common waste management mistakes is incorrectly identifying waste or failing to provide proper waste identification to the regulatory agency. It is important that you include and identify all waste codes, UHCs (underlying hazardous constituents), and keep the agency updated with current waste and facility contact information.
It isn’t enough to simply schedule inspections. You must document the inspections, keep your logs up-to-date, and include all of the necessary data (full name of inspector, date and time, potential problems, etc).
In Missouri, Large Quantity Generators (LQG) of hazardous waste (i.e., those who generate at least 1,000 kilograms (kg) of hazardous waste per month OR at least one kg of acutely hazardous waste per month) are required to report quarterly to the Missouri Department of Natural Resources (MDNR) and submit biennial reports to the EPA. Small Quantity Generators (SQG) (i.e., those who generate more than 100 kg but less than 1,000 kg of hazardous waste per month) must submit annual waste reports to MDNR.
Failure to report may cause disposal facilities to not accept your hazardous waste and increase the likelihood of regulatory agency inspections.
4. Container Management
Containers that are open or in poor condition represent a clear hazardous waste violation. Drums and other containers for hazardous waste must remain closed except when adding or removing waste. The container must not be handled in a manner that may cause it to rupture or leak.
5. Marking/Dating Containers
Marking hazardous waste containers with correct labels and dates should be second nature to you. Generators are required to mark containers with accumulation dates (month, day, and year, as well as the time of first addition) and to clearly label the containers with the words “Hazardous Waste.”
6. Preparation, Prevention, and Contingency Plans
Are you ready for an emergency? Large Quantity Generators are required to create a contingency plan that covers all potential emergencies in detail and post this emergency information beside an on-site phone. Copies of this plan should be sent to local authorities, and the plan must be updated after any significant changes occur at your facility. Remember to update your contingency plan annually.
7. Personnel Training
In addition, remember that a thorough and carefully-considered plan will not be effective if your employees have not been educated and trained. Provide adequate training when new procedures go into effect and implement an annual refresher class. Document this training properly as well.
8. Tank Management
Tank management violations typically come in the form of nonexistent (or inadequate) secondary containment, nonexistent assessment certification, or leaks and overflows. Take some time to ensure that your tanks used for storage of hazardous waste are safe and compliant.
9. Transporter and Manifest Requirements
Hazardous waste must be transported to the disposal facility using the manifest system. The transporter must sign the manifest, acknowledging acceptance of the waste from your facility. You are responsible for maintaining copies of the final manifest received from the disposal facility.
10. Universal Waste Management
All universal waste (i.e., used batteries, fluorescent lamps, mercury-containing equipment, pesticides) should be labeled as “Universal Waste.” The box or container must be securely closed except when adding waste, and universal waste can only be stored for one year before it must be recycled. Don’t forget to include your universal waste storage area during your weekly inspections.
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To avoid these common mistakes regarding hazardous waste management, be sure to follow up after inspections, review your compliance program regularly, and conduct routine self-audits to spot potential issues early.
Do you need help managing your facility’s waste? Contact Environmental Works, a full-service environmental consulting and contracting firm. We have had great success developing environmental management systems (EMS) for large and small facilities that need help with waste management responsibilities. To learn more about our services, please give us a call at 417-890-9500 or contact us online.