The Resource Conservation Recovery Act (RCRA) is one of the most important set of regulations by the Environmental Protection Agency (EPA) of which businesses should be aware. RCRA regulations on hazardous waste management not only protect the environment and human health, but understanding and following them also protects companies from incurring heavy fines, lawsuits and criminal prosecution. RCRA deals with properly managing and disposing of hazardous and solid wastes and underground storage tanks containing certain chemicals or petroleum. Companies that generate these types of waste must be knowledgeable about the details and updates to RCRA regulations, or risk serious threats to their bottom line.
Of course, consulting RCRA experts, like those at Enviro-Safe, can save you precious time and minimize your risk of being in noncompliance. State and local regulations for waste disposal in your area might also be more stringent and vary by location, and if you are transporting your waste over some distances, following regulations can get complicated quickly. Our experts can help you better understand (and comply with) regulations and paperwork for transportation, storage and disposal of your hazardous waste. But it is also important businesses have a working knowledge of common missteps other companies make that lead to RCRA noncompliance. Knowing common errors – and how to avoid them – will ultimately save you your good reputation, time and money.
Error 1: Improper disposal of hazardous waste.
This violation is perhaps the most obvious – and one of the easiest to avoid. The EPA fines companies that mistakenly or intentionally improperly dispose of their hazardous waste by dumping it into the drain, municipal dumpsters and sewers. Generators can avoid these violations by knowing their waste generator status, having a complete understanding of their hazardous wastes they are responsible for, and working with a reliable TSDF to ensure compliance. Companies must also remain up-to-date about changes to RCRA regulations that apply to them. For example, a new rule beginning August 2019 also now regulates certain pharmaceuticals from being disposed of down the drain. The EPA also heavily regulates disposal of toxic compounds, like mercury, so if your company generates toxic materials be sure you understand properly handling for those materials to be in compliance and protect employee health.
Error 2: Inadequate (or no) hazardous waste manifests.
Pay attention to your paperwork. Any hazardous waste that is transported offsite must have an accompanying Uniform Hazardous Waste Manifest. These forms are required by both the EPA and the Department of Transportation. If your hazardous waste manifests are requested, you must be able to produce them from the last three years, so be sure to keep copies. Generators must also be sure to obtain signed copies of the manifests upon receipt from the receiving facility, since the generator ultimately has “cradle-to-grave” responsibility for their waste. If you are unsure of whether or not you are keeping proper records of your hazardous waste, do not hesitate to call experts who can help you, like those at Enviro-Safe Resource Recovery. Consulting experts and being assured your paperwork is in order could save you thousands of dollars in fines.
Error 3: Inadequate employee training.
Failed inspections, unnecessary health risks, explosions, fires and health and safety violation fines have something in common: they can be prevented with proper employee training. Hazardous waste disposal poses many risks to employee health but providing training for employees in waste handling and management and emergency preparedness helps them safely carry out their duties without risking lives. No matter your generator status, large and small quantity generators alike are required to train employees, though documentation and training frequency varies by state. It takes time, expertise and money to properly train employees, but the cost of not doing so could be in the hundreds of thousands – not to mention potential lawsuits, legal action and worse, lives lost. Today’s progressive companies look beyond compliance and are stepping up their game to develop cost-effective health and safety programs that are integrated with their core business objectives. To best serve your employees and your company’s bottom line, consult experts in strategic safety training.
Be sure to check back next week for most common errors #4-8.