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What Your Annual Hazardous Waste Plan May Be Missing

Kevin Webber - Nov 13, 2018 7:35:00 AM

Man-Reviewing-Annual-Hazardous-Waste-PlanCongratulations! Your facility has a plan in place to insure proper implementation and management of an effective hazardous waste management program. It includes clear specifications for training employees about how to properly identify, handle, and dispose of hazardous waste, along with defining the specific steps they should take if they’re exposed to hazardous materials in both disaster and regular workday scenarios. It clearly details the entire process from the point of waste generation through final disposal.

As you know, hazardous waste management can be a complicated process. Did you miss anything? Let’s look at some of the details that could be missing from your hazardous waste plan.

Hazardous Waste Identification > Check for These

Your plan includes a thorough list of all the identified hazardous waste in your facility, along with a clear layman’s explanation of the specific dangers they might present. Does it include these items?

  • Maximum waste estimate – you must include an estimate of the maximum amount of hazardous wastes on-site at any given time.
  • Unique treatment identification – you must clearly describe any hazardous wastes at your facility that might require unusual treatment or response.
  • A map of your waste – Even if a location only occasionally contains a waste that requires special treatment, you must provide a map showing where it is located.

Contingency Plan > Make Copies

Your contingency plan clearly lays out your planned and coordinated response to an emergency situation. You maintain a copy at your facility; however, did you also do this?

  • Provide a copy to local emergency response teams including fire departments, police departments, hospitals, and any other local and state emergency response teams that might provide services to your facility
  • Maintain a log identifying each copy and its location

Even if your facility provides its own responders, your plan should still be sent to the appropriate authorities, in case there is an emergency that requires their response.

Contingency Plan > Safety Equipment Location

Your contingency plan clearly identifies the location of safety equipment, such as: fire extinguishers, spill control materials, and other decontamination equipment. Does it include this information?

  • Water supply information – Your plan must identify all water supply locations and highlight the ones that could be used by emergency responders, if necessary.
  • Communication device location – Whether it’s a telephone, two-way radio, or other device, the precise location must be included in your plan, along with clear procedures for who should use the device and when.

Waste Minimization Program > Write it Down

The Resource Conservation and Recovery Act (RCRA) regulations contain a policy that seeks to reduce or eliminate waste by considering reusing or recycling materials before disposing of them as hazardous waste. Facilities that generate or manage hazardous waste must certify that they have a waste reduction program in place to reduce both the quantity and toxicity of hazardous waste generated. Waste reduction is done to the extent that is “economically practicable” and while a written waste reduction plan is not required for small quantity generators, it can be the easiest way to demonstrate compliance in the event of an inspection.

Waste Minimization Program > Added Benefit

Another benefit of a written hazardous waste reduction plan is the potential impact it can have on efficiency and innovation for your organization. There are two basic types of waste reduction: source reduction and recycling. Source reduction is any action that will reduce the amount of waste exiting a process. While this could mean improvements to maintenance or housekeeping and process modifications, it could also mean equipment or technology modifications or product redesign. If your team approaches waste minimization with a creative mindset looking for innovative methods, who knows what technology or design improvements might be made!


These are some of the items that might be missing from your current hazardous waste plan. Reviewing and updating it annually can help ensure that you are not only maintaining compliance, but also operating as efficiently as possible. Your trusted waste services provider can help with any questions you might have about your plan and hazardous waste management.

Topics: Hazardous Waste

Kevin Webber

Kevin Webber

Kevin Webber is a partner at TriHaz Solutions and actively involved in the day-to-day business from a strategic and operational standpoint. He has a successful background in business/investment management and entrepreneurship, including recognition by Inc. Magazine’s 5000 list of fastest-growing private companies.

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