If your workplace generates regulated medical, pharmaceutical or hazardous waste, having a good handle on the regulatory requirements in regards to handling, transporting and storing that waste is essential. While there are many state and federal agencies that have a hand in regulating this process, the basic framework upon which most of that regulation is based come from the Resource Conservation and Recovery Act (RCRA). That means that understanding your responsibilities under the law starts with learning the requirements laid out by RCRA.
RCRA: regulation and liability
RCRA, enacted in 1976, gave the Environmental Protection Agency (EPA) the authority to control hazardous waste management from cradle to grave, regulating every step of the process from the point of waste generation all the way through to its final destruction or disposal. It also granted the EPA the authority to hold waste producers accountable for the waste they produce across the entire span of its existence.
What this means for a waste generator, like your workplace, is that the waste it produces is tracked every step of the way, and that environmental standards outlining compliant waste handling practices are imposed on every step of the waste management process. It also means that your workplace is fully responsible for its waste, legally and financially liable for any harm it may cause, from the time it is generated at your facility right through to the point that it is destroyed or rendered harmless.
What is required of waste generators?
Regulated waste generators must meet certain standards when managing waste, from start to finish, to maintain compliance with regulatory standards, including the following:
Generators must develop a comprehensive waste management plan that outlines standard procedures for handling the regulated waste streams generated on site.
Employees must be trained in proper waste classification and handling in accordance with state and federal compliance standards.
Waste streams must be properly classified and segregated into approved containers.
Segregated waste must be properly packaged and labeled.
Waste must be stored in compliance with state and federal regulations.
Waste generators must have proper documentation for waste that is transported off-site. Permits required for waste transport and delivery must be kept on file, as well as waste manifests and certificates of destruction for each load of waste that leaves their facility.
Compliance: The importance and the realities
Understanding and complying with these standards is essential to protecting your workers, the public and the environment from harm. It is also essential to protecting your workplace from the potential legal and financial consequences of non-compliance. Cradle-to-grave accountability means that you are responsible for any problem caused by your waste, whether issues occur in your workplace, on the road as it is transported, or at a disposal site long after it has left your facility. Consequences of such problems can be fines, lawsuits and/or being held financially responsible for any necessary cleanup.
That being said, understanding and complying with the standards set forth by RCRA and the federal and state agencies that enforce those standards can be difficult. For example, rules on waste handling, packaging, storage, treatment and disposal vary according to many factors, including how much waste your workplace produces and the types of waste produced. This can make it difficult to determine which standards apply to you. Waste classification standards can be confusing for both administrative staff and their employees, leading to waste segregation mistakes.
The complexity of maintaining compliance and the potential consequences of failure are among the top reasons why many regulated waste generators choose to seek professional help with waste management. Working with a reliable, full-service waste management provider provides an easier path to minimizing the risks associated with the process, giving waste generators access to services like waste management education, waste process audits, and employee compliance training, as well as reliable and compliant waste pick-up and transportation. Some providers – TriHaz Solutions for example – can also offer safe and compliant waste treatment and disposal, rendering your waste harmless to ensure that your cradle-to-grave responsibility is successfully laid to rest.