March 30, 2015
By Roland Fornoff
For over ten years, I have worked in environmental management. During that time, one thing that has remained constant is the disillusion of business owners and managers that they are in compliance with regards to hazardous waste. They have identified their waste as hazardous and have hired a company to haul the waste away and dispose of it. In their minds, they have done the “right thing”.
While making sure the waste is disposed of properly via a licensed waste hauler is essential, there is so much more to hazardous waste compliance than simply shipping the waste away. As a hazardous waste generator, you need ensure that you meet the numerous requirements, including (but not limited to):
- Determining your generator status
- Aquiring an EPA identification number
- Proper on-site storage in satellite and central accumulation areas
- Container labelling including EPA waste codes and a start date
- Weekly Container Inspections
- Accumulation time limits (90 days or 180 days)
- Employee training
- Maintaining up-to-date and accurate documentation (manifest, land disposal restrictions, inspection records, training records, contingency plan, pollution prevention plan, etc.)
- Biennial reporting
Unfortunately, this is not the responsibility of the company hired to haul the waste; it is the responsibility of the business generating the waste. Too often is there a misconception that hiring a waste hauler solves all a business’s compliance issues. However, a waste hauler’s job is just to haul the waste. More than likely, if your business is out of compliance, the truck driver will not recognize that or say anything because it is not their responsibility. This creates a false sense of security for business owners, who frequently only learn about their compliance issues when they get an inspection from state or local officials.
If your business generates hazardous waste, start taking a proactive approach to compliance. Lucky for you, the Business Environmental Program is here to help. We provide the free and confidential guidance you need to be confident in your compliance. We offer phone, email, and on-site assistance. Call (800) 882-3233 to schedule an appointment with a BEP staff expert today.