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12 Ways for Hazardous Waste Generators to Avoid Compliance Problems and Minimize Liability

12 Ways for Hazardous Waste Generators to Avoid Compliance Problems and Minimize Liability

OK,  full disclosure:  The following list borrows heavily from The Hazardous Waste Generator’s Handbook created by the Kansas Department of Health and Environment (KDHE).  I highly recommend it to any Kansas business that requires an introduction to the state regulations for generators of hazardous waste, universal waste, and used oil.  What I have appropriated for my own use below are some very good guiding principals that can be used by any business anywhere to ensure compliance with the Federal and state – whatever state you’re in – regulations and to minimize the liability associated with generating a waste.

  1. Minimize the amount of hazardous waste generated. This can be done in several ways including a formal Waste Management System or a simple review of what is used at the facility and a look at alternatives to see if less toxic substitutes can be found. Another waste minimization method is to change to different processes that utilize less product and/or produce less waste. Most waste minimization projects pay for themselves within a couple of years through reduced product purchases and reduced waste disposal costs.
  2. Determine what is the primary environmental regulatory enforcement agency in your state.  The USEPA allows all states, territories, and tribes to operate their own hazardous waste program within their jurisdiction if the program meets USEPA requirements and is thereby “authorized”.  Does your state/territory/tribe have its own authorized hazardous waste program?  Or is it subject to Federal regulations?  Read this article to find out:  State Authorization Under RCRA.
  3. Good housekeeping, by removing old, unused products, empty containers, old parts, etc. to create space and reduce potential regulatory issues and complaints.  Proceed carefully through any clean-up of old or unused product.  The act of “cleaning-up” could be interpreted as disposal which results in the generation of a waste.  It is quite possible that one result of your clean-up may be the generation of enough hazardous waste to change your hazardous waste generator status.

    Not sure of your hazardous waste generator status?  Take this short survey

  4. Locate and deal with reputable transportation, treatment, and disposal firms. If a price quote is substantially less than the competition, there is probably a reason why.  It is also a good idea to conduct audits of your hazardous waste disposal sites and the transporters who deliver it.
  5. Have backup transporters and disposal sites selected in case your primary providers have problems.
  6. Recognize when you lack the expertise to handle a particular problem and seek help from a person with experience in hazardous waste management.  I’ll answer all of your questions for free!

    Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

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  7. Follow up on all hazardous waste shipments to ensure they reach their intended destination and are treated or disposed.  Remember:  depending on your hazardous waste generator status (see the survey above) you may be required to submit an Exception Report to your state or the USEPA if you do not receive a signed copy of the Uniform Hazardous Waste Manifest within a specified time-frame.
  8. Do not mix hazardous wastes with nonhazardous wastes unless you are familiar with all regulations that may apply.  The resultant mixture may be a hazardous waste and may be more difficult or costly to dispose than the original waste.
  9. Maintain all records regarding the hazardous waste program (test results, contingency plan, manifests, exception reports, annual reports, training documents) in one location.
  10. Designate at least one employee with an appropriate background to be responsible for hazardous waste management. Give that employee the authority and resources to do the job, and then hold him or her accountable.
  11. The best hazardous waste personnel training

    Training for Hazardous Waste Personnel can increase knowledge of the regulations

    Provide high-quality training for any employee whose job responsibilities require knowledge of hazardous waste regulations.  Depending on your hazardous waste generator status (see the survey above) you may be required to provide applicable employees with specific training at a regular frequency.  In many cases the training must be documented and records kept to demonstrate compliance.  Read more about USEPA training for Hazardous Waste Personnel.  Even if training isn’t required – as is the case for a Conditionally Exempt Small Quantity Generator of hazardous waste – it’s always a good idea to increase the awareness of the regulations at your facility.

  12. Conduct inspections of your facility and its operations. Do so with an open mind and no preconceived notions of the way things ought to be.  Depending on your hazardous waste generator status and the requirements of your state, weekly inspections may be required of all areas where hazardous waste accumulates.

Use these guidelines to stay in compliance with both Federal and State regulations and to minimize – and perhaps eliminate – the cradle-to-grave responsibility your company has for the waste it generates.  And don’t hesitate to contact me if you have any questions about the generation or management of waste.