The Resource Conservation and Recovery Act (RCRA) regulations contain a national policy for “waste minimization” or “waste reduction.” This policy seeks to reduce or eliminate waste by considering reusing and/or recycling materials before disposing of it as a 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. Let’s look at what your plan should contain and what it might be missing.
What Your Plan Must Contain
Generally, the law says that the following should be included in your waste reduction plan:
- Written policy of management
- Written scope and objectives of the plan including quantitative performance goals that are production-related
- Options that will be evaluated and an implementation schedule based on the waste reduction assessment
- System for tracking and managing hazardous waste costs
- Employee training programs for waste reduction
- Description of procedures that will make waste reduction an ongoing effort
- Annual update of waste reduction efforts
Include a Waste Reduction Assessment
Your facility’s waste reduction plan should include a waste reduction assessment. The assessment requires that you:
- List all hazardous waste streams
- Assess whether or not you need to set performance goals or KPIs (key performance indicators). If setting KPIs isn’t practical at this point, then list which actions will lead to them being established in the future.
- Evaluate all processes, operations, and activities that include toxic substances and create hazardous waste
- Evaluate options for reducing each waste that you target in your plan’s KPIs.
What Your Plan Really Needs
There is one key element that some waste reduction plans are missing. It can literally “make or break” your facility’s waste reduction efforts. What could be so important? Commitment from management. After all, management sets the goals and policies for your organization and influences the culture. Your waste reduction plan must become a part of your standard operating procedures and be integrated into all areas of the company, including operational procedures, product development, and training.
For example, a plan that requires changes in equipment as a reduction method will need a financial commitment. If top management commits resources (time, personnel, and money) to the waste reduction program, then it can be successfully implemented. If your organizational culture supports continuous improvement and there is involvement and communication across all departments, other barriers can be avoided. Common objections involve attitudes like skepticism (“That won’t work.”) and having other priorities (“Those funds are earmarked for something more important.”)
Don’t let lack of commitment from management become an obstacle to your waste reduction efforts. If necessary, provide education and motivation for management by showing the benefits of waste reduction planning, such as: meeting regulatory requirements, cost and liability control, product quality improvement, protecting employee health, and safety. For some organizations, there may be other benefits such as being seen as a leader in environmental issues. Many organizations are adopting strategies to achieve corporate sustainability goals, including industrial waste reduction. Toyota’s waste minimization projects are a great example of hazardous waste reduction. A waste reduction policy statement can also be used as a starting point for ISO certification.
Besides the required documentation in your waste reduction plan, such as a detailed waste assessment, there is one other key component — full support from management. Without management’s commitment to your waste reduction plan, you might as well not have a plan. Implementation with long-term management support can ensure a successful hazardous waste reduction program for your facility. Your trusted waste services provider can help with your waste reduction planning.