When your facility uses hazardous materials, you’re quite aware of both the risks and the obvious need for proper hazardous waste disposal. (After all, if you’re working with the likes of trichlorofluoromethane, you know it simply can’t be tossed in the garbage can… Bad things happen… both to you and the garbage can.)
So whether it’s:
- Toxic, or
- Acutely Hazardous
It’s important to dispose of these chemicals in accordance with EPA requirements. If you’re a bit fuzzy on the EPA’s regulations, you can read the RCRA details here, or call for expert advice if you’d rather speak to an actual person. Risking the obvious, you’ve got to stay on top of your legal requirements for hazardous waste. But some problems have cropped up lately that you want to stay ahead of.
Dealing with Inspections
Currently, there’s a huge backlog of hazardous waste inspections, and it may be that your facility hasn’t had an inspection in quite some time. Missed inspections can cause a number of issues, and the overriding concept at your company needs to be: thorough preparation.
After all, some of these regulatory entities want to get back out there and make people understand the sheriff is back in town. Couple that with the fact that states are looking for revenue, and they can get some of that revenue from fines.
So how do you thoroughly prepare, avoid fines, and keep inspections running smooth and trouble-free?
When regulators come to your facility, the first thing they see is housekeeping. Simply put, if your housekeeping isn’t good, that’s a red flag.
The second thing they’ll look at is your paperwork. And if your paperwork doesn’t look good, that’s another red flag. That double-red-flag combo is what makes the regulators take a deep dive into your facility and record keeping, resulting in in-depth, even multi-week inspections.
So if you get the housekeeping and the paperwork right, you’re off to a good start. But even with a good start there are some common areas where facilities still run into trouble.
Where Trouble Happens Most Frequently
Your good housekeeping and paperwork should support an organized system for handling hazardous waste storage. But a few things can still fall through the cracks:
- What’s in your waste containers needs to be the same as what the label says is in there. No surprises.
- If you’re mixing chemicals in the same container you need to make sure – absolutely sure – you know which chemicals can be mixed with which chemicals. No science experiments gurgling in the corner. Not sure? Ask the experts.
- Make sure those container lids are closed. Double check.
- Along with those nicely labeled toxic waste containers, you need a system tracking how long contents have been stored. Don’t keep those toxic concoctions longer than you should. (How long can depend on your generator status.)
- The labels on the containers must have a start date for when the container was first used.
Scary but true, when there’s no start date on a waste drum, who knows how long it’s been there? Regulators can assume the worst and can charge you with operating an illegal disposal facility.
Take those labels seriously!
Keep Hazardous Waste Simple and Surprise Free
Put hazardous waste in the proper storage area, in the right containers, and have it picked up by a reliable company that you trust and has a good safety rating.
It’s important that with whatever company you use for your toxic waste needs, you’re able to set the right service terms, tailored for your facility. Arrange for your disposal company to come on a regular, prescheduled basis, to maintain compliance and streamline disposal. Have a company that will check on your storage area and make sure everything is up to snuff. Best, also, when the company also knows your compliance requirements and can also manage your paperwork for you.
Most importantly, look for a company that helps you help yourself.
Keep hazardous waste simple and surprise free. This way, when the regulator comes to your facility, it’s a short, pleasant visit, and you get to go home that evening knowing it’ll be a good day tomorrow.