You should select your hazardous waste transporter and your treatment, storage and disposal facility (TSDF) very carefully. As a hazardous waste generator, you have cradle-to-grave responsibility for your waste and remain responsible for its proper management even after it leaves your facility.
How do you know that your hazardous waste is being properly managed by your waste services provider? After the waste leaves your facility, how can you be sure that it’s transported and treated following state and federal regulations? We’ve put together a list of things to look for, including a checklist to help you select your hazardous waste partner to ensure compliance with state and federal regulations.
Preparing Your Waste
If your waste is not properly prepared, many waste service providers will not pick it up for transport. Something as simple as an unsealed container or mislabeled drum can derail your scheduled pickup. Your waste provider is legally not supposed to seal containers or provide any other assistance in preparing your hazardous waste for transport. As the waste generator, you are responsible for properly packaging, labeling, and marking all hazardous waste shipments This means:
- Your containers must meet DOT shipping specifications.
- Containers must be properly labeled, including the proper UN identification number and correct hazardous waste class.
You are also responsible for correctly preparing the Uniform Waste Manifest form for all hazardous waste shipments.
Transporting Your Waste
A hazardous waste transporter will deliver your waste from its point of generation to its ultimate destination. This includes transporting the waste from your site to a facility that can treat, store, recycle, or dispose of the waste. It can also include transporting treated hazardous waste to a site for further treatment or disposal. Because these transporters move regulated wastes on public roads, highways, rails, and waterways, the U.S. Department of Transportation (DOT) and EPA jointly developed the regulations. You should make sure that your hazardous waste transporter adheres to these regulations:
Obtain an EPA Identification Number – Each transportation company is required to obtain an EPA ID number and may not transport hazardous waste without one. (Unlike your generator EPA ID number, which is site-specific, these ID numbers are assigned to the transporter company as a whole.)
Comply with EPA’s hazardous waste manifest system – The manifest system tracks hazardous waste from the time it leaves your facility, until it reaches the off-site waste management facility. As mentioned above, the uniform waste manifest form is required for all hazardous waste shipments. A transporter may not accept your waste unless they receive a properly prepared manifest. They must then sign and date it to acknowledge receipt. You should receive a copy of the form before the transporter leaves your property.
The Waste Manifest Trail: It’s important to note that the manifest (with the exception of water and rail shipments) must accompany a copy of the shipment of waste at all times. Once your transporter accepts your waste, they are required to deliver the entire quantity of that waste to the next designated transporter or facility. When the waste arrives at its next destination, the recipient there must sign and date the manifest. Your transporter is required to keep a copy of the manifest for three years.
Handle Hazardous Waste Discharges – Your hazardous waste transporter is required to take immediate action in the case of a discharge or spill in order to protect human health and the environment. Your transporter must be trained in emergency procedures, including notifying the proper authorities, clean-up, and reporting.
Follow All Applicable Hazardous Materials Regulations – There are other requirements for labeling, marking, placarding, and containers that must also be followed.
In addition to DOT regulations, there may also be state regulations that must be followed. For example, the State of Alabama requires a hazardous waste transportation permit from the Alabama Department of Environmental Management (ADEM).
Finally, your hazardous waste transporter must also maintain a state notification of regulated waste, properly filed with EPA to notify regulating authorities that they engage in the transportation and management of regulated waste categories.
Treating Your Waste
In addition to initially transporting the hazardous waste generated by your facility to a TSDF, your hazardous waste transporter may also then transport your treated hazardous waste to a site either for further treatment or disposal. This is why the waste manifest trail is so important. In some cases, a transfer facility may be used.
A transfer facility can be any transportation-related facility such as storage areas, loading docks, parking areas, and other similar areas where hazardous waste shipments are temporarily held. If your waste is not going to a TSDF that is close, your waste may go to a transfer facility first. Ask your hazardous waste transporter where you waste is going, so you can follow the exact trail. A hazardous waste transporter may hold waste without a storage permit in containers at a transfer facility for 10 days or less, provided the waste is manifested. The waste must also be kept in DOT specification containers. If the transporter stores the waste for more than ten days, the transfer facility would become a storage facility—and subject to all requirements for TSDFs. Failure to adhere to these requirements could result in hefty penalties for the transporter and for you, the waste generator.
Using a hazardous waste management services company that can pick up your waste with a commercially licensed vehicle and driver, and can treat your waste will ensure a higher level of safety. You can be confident that your hazardous waste transporter is properly trained to service your facility. The necessary safety protocols will be in place on the vehicle used to transport your waste, in case of an emergency. They have the necessary transportation permits and if they are located in the State of Alabama, the equipment at their treatment facility has been approved by the Alabama Department of Environmental Management (ADEM). This means that their treatment technology is approved for use and they have been issued a waste treatment permit.
Selecting a Transporter and/or TSDF
- One of the best sources for the selection process is referrals from trusted business colleagues. Ask for references from your friends and other business people.
- If your industry has a trade association, they may keep a list of companies on file that handle hazardous waste.
- Check with the Chamber of Commerce to see which transporters or TSDFs in your area are members.
- The Better Business Bureau should have a record of any complaints that may have been registered against companies in your area; check to avoid transporters or TSDFs with a record of poor performance.
- The Alabama Department of Environmental Management (ADEM) or Tennessee Department of Environment & Conservation (TDEC) can tell you whether or not the transporter or TSDF has an EPA identification number and a permit. (If you’re outside our area, there is a convenient EPA list of state hazardous waste programs.)
Carefully reviewing the custody and disposal chain for all of your facility’s hazardous waste, cradle-to-grave, will ensure proper compliance and reduce risk. Working with a qualified, experienced hazardous waste transporter and a reliable treatment, storage, and disposal facility can further guarantee proper management of your hazardous waste after it leaves your facility. Having one point of accountability for both the transportation and treatment of your hazardous waste makes the most sense. Schedule a free consultation with the button below to learn more about our services and see how we can help meet your needs and exceed your expectations.