The Resource Conservation and Recovery Act (RCRA) regulations establish the hazardous waste management standards for hazardous waste generators. RCRA was amended in 1984 to establish a national policy for waste minimization. More commonly referred to as waste reduction, this policy refers to source reduction and environmentally sound recycling of RCRA hazardous waste.
According to the law, “...the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment.”
The main goal of a waste reduction plan is to reduce or eliminate waste by considering reusing and/or recycling materials before disposing as a hazardous waste. Let’s take a look at the two types of waste reduction and why you need a plan for them.
Waste Reduction Methods
Let’s take a look at the two basic types of waste reduction: source reduction and recycling.
Source reduction refers to any action that will reduce the amount of waste exiting a process and may include the following measures:
- Process or procedure modifications
- Redesign or reformulation of products
- Substitution of raw materials
- Equipment or technology modifications
- Maintenance or housekeeping improvements
- Inventory control or training improvements
“Environmentally sound recycling” includes the use, reuse or reclamation of residuals that are designated either as materials in a hazardous waste or as a hazardous waste. Recycling can be done either on or off-site and may include these methods:
- Removing contaminants from hazardous waste to allow reuse
- Reclaiming useful ingredients from a waste material
- Reusing or using a waste as a substitute for a commercial product
- Reusing a waste in order to delay purchasing a new commercial product
After looking at these lists, you can see why a plan is necessary to effectively implement waste reduction practices at your facility. Below are other reasons.
The first, and most obvious reason, to have a waste reduction plan is for compliance. And, while a written waste reduction plan is not required, it can be the easiest way to demonstrate compliance in the event of an inspection. Facilities that generate or manage hazardous waste must certify that they have a waste minimization 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.” Many states also have laws that require facilities to complete specific waste minimization activities, including a waste minimization plan.
When the uniform hazardous waste manifest is signed, your facility is certifying that you have a program in place to minimize the volume and toxicity of the waste generated. As a small quantity generator, your responsibility is as follows: “I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”
Waste minimization reduces both volume and toxicity, which contributes to increased safety for your employees as well as protection for the environment. With the required training, employees are empowered to take steps in waste reduction and well-equipped to handle any challenges. Plus, they have the confidence of knowing that management cares about their health and safety.
A Waste Reduction Plan Has Business Benefits
There are other, tangible benefits for industry that can be realized as the result of having a waste reduction plan in place.
A hazardous waste assessment is a key part of any waste reduction plan. This detailed assessment includes an evaluation of options for reducing each type of waste that has been identified. Waste is an indication of inefficiency. By setting trackable performance goals, your facility will be able to see where waste reduction options can reduce waste and improve efficiency.
It’s a simple fact: waste reduction will reduce your raw materials cost. If you effectively use recycling methods such as reusing waste as a substitute for a commercial product or removing contaminants from waste to allow its reuse, you will see cost savings. There are cost-accounting tools available that can help you track and improve resource use. Also, your facility’s waste handling and disposal costs will also be reduced since you are lowering your hazardous waste volume.
Particularly in the area of source reduction, which means any action that reduces the amount of waste exiting a process, there is vast opportunity for exploration and innovation. This method of waste reduction could include actions such as modifying equipment or technology and redesigning products.
Working toward a common goal of successful waste reduction requires teamwork. For waste reduction efforts to be successful, every member of the team must support and work toward agreed upon goals, making waste reduction an integral part of daily operations. Working together toward a common goal of protecting the environment as well as the safety of all employees can build morale and a positive culture.
Companies that reduce their waste streams can also improve their public image. Being a good steward of resources and protecting people and the environment is a hallmark of a company with a conscience. In today’s competitive environment, any point of differentiation resonates with customers.
A hazardous waste reduction plan can have positive, long-range effects on your organization. While RCRA regulations require that you have a plan, the other benefits such as improved employee morale, increased business innovation, and costs savings can directly benefit your organization. Your trusted waste services provider can help you identify areas for waste reduction.