An effective waste management program involves more than site procedures for identifying, storing, and disposing of waste. To manage environmental liabilities appropriately, an effective program must also include a process for evaluating the compliance status of your waste facility receptors. Ideally, the process should allow you to answer the following questions:
- How are you disposing of waste?
- When you send waste to a third party, do you know how it is handled?
- Are you sure the waste is disposed of properly?
- Is your firm liable?
Environmental Compliance of Your Waste Receptors
A waste receptor is the site/location to which the waste from your facility is delivered for final disposal/disposition. The waste may be placed in a landfill or mixed with other waste at a hazardous waste treatment, storage, and disposal (TSD) facility. Typical waste receptor sites include hazardous waste landfills, non-hazardous waste landfills, hazardous waste incinerators, tote and drum re-conditioners, tanker washes, metals recovery, waste water treatment, universal waste processing, used oil recycling, hazardous waste TSD sites, and fuels blending sites.
Remember “Cradle to Grave”. Once you have generated a hazardous waste, there is no way to rid yourself of complete responsibility for its final disposition. You will be responsible for any improper offsite transportation and disposal along with all the legal and financial liabilities that might apply. Hazardous waste generators must track waste from the moment it enters the site as a hazardous material to the eventual treatment or disposal of that material. The responsibility for hazardous waste may go beyond the grave, making the waste generator responsible (in part) for the waste handler's actions. Thus, if the handler does a poor job and pollutes the environment, the generator may be responsible for cleanup.
Each hazardous waste generator's cradle-to-grave liability includes joint and several liability. This means that if there ever is an incident in the future involving the release of hazardous wastes that have been landfilled or otherwise land-disposed, every entity who has ever put waste into that landfill is a responsible party and is responsible for cleanup costs. When a TSD facility cannot cover all of the associated costs, the responsible parties must pick up the difference. Thus, it is prudent for generators to carefully consider their waste handling and disposal options. Options like landfilling are often initially less expensive than incineration or fuels blending, but they have a higher degree of future liability.
It is very important that your facility select the right hazardous waste disposal company. It is important to monitor the performance of your waste receptors. A properly licensed and experienced hazardous waste disposal company is invaluable in helping your company maintain federal and state standards. The right vendor will help you stay in compliance with these regulations, ensure minimal disruption to your operations, and perform these tasks in a cost-effective manner.
Waste Receptor Sites: Auditing
The process for evaluating waste receptor sites typically involves an audit focused on the areas outlined below.
- General Information
Company profile, site profile, facility staffing, facility setting and use, security, and emergency response
- Summary of Permits
List of permits and registrations, authorized and prohibited waste
- Operations Review
Hazardous waste TSD, recycling, non-hazardous waste, container management, bulk storage, transportation, laboratory operations, receipt control/waste tracking
- Residuals Management (including containers)
Residuals generated/offsite receiver, storm water management
- Regulatory Compliance Status
Spill Prevention, Control, and Countermeasure (SPCC)/Resource Conservation and Recovery Act (RCRA) contingency plan, agency reporting, health & safety compliance, agency contact, regulatory inspection history
- Site Inspection
Review of the physical site
- Supporting Data
Site maps, site layout, insurance certificate, financial statements, permit copies, photographs, logs, correspondence including inspections or violations, agency databases
The Audit Process
Trinity can schedule this audit for your third-party waste receptors. The process begins:
- with an initial discussion with your facility to identify all third-party waste receptors, and
- Trinity then contacts the receptor(s) to schedule the site visit and provides a list of audit questions for completion and use during the audit
Trinity collects information about the waste receptor prior to the audit, during the audit, and after completion of the audit. Once on site:
- the Trinity Auditor thoroughly examines site procedures and processes,
- interviews the site contact(s), and
- reviews various permits and written programs
- The Trinity Auditor also conducts a site walk-through to evaluate, storage areas, outfalls, property boundaries and housekeeping
- Photographs of the site are taken when approved by the site
Trinity will organize all the data collected from the site audit into a finished report. The report includes details regarding site documentation and conditions as well as conclusions regarding the risk of using the facility for waste disposal. Corrective actions are also noted.
Trinity Can Help
Trinity staff has conducted more than 1,500 of these audits for our waste-generating industrial clients. For all your environmental or occupational health and safety challenges, Trinity has the deep experience and commitment to client service to meet your needs. For assistance, contact Trinity at (800) 229-6655.