Hazardous waste that is improperly managed poses a serious threat to human health as well as to the environment. Once your facility has established a compliant regulated waste management process, the bulk of the work required to maintain it centers around documentation and other hard copy information, including a hazardous waste plan.
Reviewing and updating your plan annually is an important part of the process. All employees involved in any part of your hazardous waste disposal process must read and have a thorough knowledge of the procedures contained in your plan.
You Need a Policy
One of the most important aspects of any hazardous waste plan is a firm commitment from management, which sets organizational goals and policies and deeply influences the culture.
A written policy clearly addresses an organization’s commitment to proper hazardous waste management. It states the objectives of the plan and outlines a program for compliance, including instructions for all employees. Consequences for non-compliance should be clearly outlined as well. The plan should be a part of standard operating procedures and integrated into all areas of the organization. If management embraces a culture of safety, that provides a strong foundation for successful waste management efforts.
You Need a System
The guidelines established in your plan will create an awareness of hazardous wastes and specific procedures for your facility personnel to follow. Having a procedural system not only protects the health and safety of your employees, it helps ensure compliance. From establishing proper hazardous waste identification and segregation to monitoring a compliant waste collection process including packaging and labeling, having a system in place will increase efficiency and reduce risk for your facility. Inefficiencies due to a flawed process and/or a lack of employee training can result in a loss of productivity and have a negative effect on your facility’s bottom line.
You Need a Contingency Plan
Did you know that contingency plan violations are among the most common hazardous waste generator violations? As a small- to large-quantity hazardous waste generator, you are required to have a disaster contingency plan. Contingency plans are required by the Occupational Health and Safety Administration (OSHA) for all employers who have hazardous chemicals in their workplace. Such plans are designed to protect against chemical source illnesses and injuries by ensuring that employers and employees are provided with sufficient information to recognize chemical hazards and take appropriate measures. Your disaster plan should clearly lay out your planned and coordinated response to an emergency.
You Need a Waste Minimization Plan
The Resource Conservation and Recovery Act (RCRA) requirement for a waste minimization program is a key component of any hazardous waste plan. After all, the easiest and most cost-effective way to manage waste is to not generate it in the first place. If you can reduce the amount of hazardous waste your facility has to deal with, you can reduce risk, increase efficiency, and save money. Small quantity generators (SQGs) are not required to document waste minimization efforts like large quantity generators (LQGs); however, including these efforts in writing as part of your plan will help you achieve your waste reduction goals. Also, a written waste reduction plan can be the easiest way to demonstrate compliance with RCRA’s waste reduction policy.
You Need a Chain of Command
Who is responsible for monitoring compliance with state and federal regulations?
Who is responsible for identifying non-compliance and providing consultation, if needed?
If non-compliance is identified, what is the procedure for notification and what actions will be taken?
Who is responsible for regular inspections of hazardous waste containers?
If there is a problem with a container, who is responsible for action?
Who signs the uniform hazardous waste manifest?
These and other questions will be answered in your plan and it will establish a clear chain of command and accountability that drives the process as a team effort.
The overriding goal of any hazardous waste management plan is to protect the health and safety of people and the environment, while adhering to applicable state and federal regulations. By providing information and guidance for your facility personnel, you can help insure proper implementation and management of an effective hazardous waste management program. Partnering with a fully certified and experienced waste services provider can further ensure compliance when managing your hazardous waste.