Evaluating a shop process based only on the "bottom line" doesn't always give the whole picture. For example, throwing disposable wipes into general trash versus using an industrial rag-laundering service could make good business sense in some cases, but many times it could lead to a hazardous waste-compliance issue.
The reason is simple. It's not the rags, but the solvents used on the rags that make them hazardous. The solution is simple, but improper management of hazardous waste can lead to complex problems. It may not seem as easy as ABC, but the following steps can be used as a guide to get started on a proactive hazardous waste management program.
Ask Your Regulators
As environmental consultants, we use a variety of tools to help advise clients on hazardous waste management. Special software and Internet links help with regulatory guidance, and seminars and special training provide help on how to implement best management practices. But a very important tool in our trade is talking to the regulators.
The law that governs hazardous waste is the Resource Conservation Recovery Act, or RCRA, 40 CFR 261-265. RCRA's primary goals are to protect human health and the environment from the potential hazards of waste disposal, to conserve energy and natural resources, to reduce the amount of waste generated and to ensure that wastes are managed in an environmentally sound manner.
Federal and State EPA offices provide information on how to understand RCRA and manage waste from "cradle to grave." The best way to start is by visiting the U.S. EPA's web site at www.epa.gov. This web site leads to many other helpful links ranging from basic to specific types of industrial activities.
Most state environmental agencies have divisions to provide assistance on managing hazardous waste. Programs often include guidance on pollution prevention without the threat of enforcement and typically offer detailed assessments of your facility and a report with helpful suggestions.
Build an Inventory of Wastes Generated
After you have a basic understanding of the law, the next step should be an inventory of wastes that your company can generate. Take a careful look at all of the processes and the waste each generates. Don't overlook general trash (like the rags mentioned earlier) or empty aerosol cans. Think about how the waste is created and verify what products were used in the process.
Hazardous waste can take many physical forms and can be solid, semi-solid and liquid. A waste may be considered hazardous if it is ignitable (i.e., burns readily), corrosive or reactive (e.g., explosive). A waste also may be considered hazardous if it contains certain amounts of toxic chemicals or is found on a list of over 500 specific hazardous wastes developed by the EPA.
Characterize Unknown-Waste Streams
If you are not sure of how the waste was created, or if you know that a product used in the manufacturing process contains ingredients that are potentially hazardous, the next step is to characterize your waste. This step can include a laboratory analysis of the waste stream, which will reveal the presence of any hazardous characteristics listed above. Material Safety Data Sheets (MSDS) also can help characterize the waste.
Licensed waste transportation and disposal facilities are a good resource to consider when characterizing your waste. Reputable firms will assist in the identification and characterization process as part of their waste disposal fees. But remember, only you will be held accountable for violations that occur because of improper management of hazardous waste.
You know your manufacturing process better than anyone else; therefore, it is your responsibility to identify the hazardous waste streams. In other words, the phrase "I didn't know" is not a viable defense if you are cited.
The letter "D" (if included in this article) would stand for documentation. In fact, an entire article could be dedicated to the importance of documentation, but the summary can be simply stated: Document each step taken to identify and manage your hazardous waste. Keep the information in easily accessible files and maintain copies of all correspondence, data, manifests and waste profiles.
The processes outlined above can help you begin to manage your hazardous waste, but they also can help in identifying inefficient processes. Waste costs money, so taking the time to reduce it not only meets one of RCRA's primary goals, but it also makes good business sense.