Best Practices in Hazardous Waste Information Management. Presented by Mike Ryan Product Manager of Technical Service at 3E Company

Transcription

1 Best Practices in Hazardous Waste Information Management Presented by Mike Ryan Product Manager of Technical Service at 3E Company

2 Agenda Hazardous Waste Determina2on Generator Status Determina2on Hazardous Waste Handling and Storage Vendor Management Recordkeeping Requirements & Document Management Common Viola2ons

3 What is RCRA? Resource Conserva2on and Recovery Act Enacted in 1976 / Amendment to SWDA Protect human health and the environment Conserva2on (energy and resources) Waste reduc2on Waste management HSWA 1984 Amendments Reduc2on in land disposal Prohibi2on of open dumping Encouragement of state specific programs Focus on R&D for recovery, recycling and treatment alterna2ves

4 Cri2cal Elements to a Waste Program The Cri$cal Elements of any program should address the en2re waste life cycle Define! Train! Execute! Document! Audit! Improve and Manage Change 1. Genera2on 2. Determina2on 3. Disposi2on 4. Disposal Program refers to the set of organiza$onal prac$ces deployed to manage hazardous waste informa$on

5 Common Misconcep2ons The regula2ons are as is and always correct. We don t generate Hazardous Waste.

6 Common Misconcep2ons Our employees know how to iden2fy and handle hazardous waste

7 Common Misconcep2ons We don t have any spills

8 Common Misconcep2ons Our hazardous waste hauler takes care of everything, even manages the paperwork

9 Common Misconcep2ons We donate most of our returned, damaged, unused and expired products We send the rest back to the vendor for credit

10 Waste Lifecycle Generation Source identification Expected event Unplanned incident Reporting Annual / Biennial State-specific Determination Identification Classification Responsible Generator Party Disposition Reduce, Reuse, Recycle, Return Containerization and Labeling Permitting Record Keeping UHWMs Invoices BOLs LDRs Disposal Information Management Vendor Management

11 Hazardous Waste Determina2on Solid Waste? You probably think you learned what a solid is in eighth grade science class. The folks who wrote the RCRA rules weren't in that class. RCRA states: The term solid waste means any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollu2on control facility, and other discarded material including solid, liquid, semisolid or contained gaseous material ( US Code, Title 42, paragraph 6903, emphasis added)

12 Hazardous Waste Determina2on A material is considered a solid waste if it: Is a solid, semi- solid, liquid, or contained gaseous material which is discarded or has served its intended purpose Is abandoned, spilled, no longer intended for use Is being recycled by being placed on the ground (and that is not the normal use), burned for energy recovery, reclaimed, or accumulated more than one year Is inherently waste- like (e.g., dioxin wastes)

13 Hazardous Waste Determina2on Is the solid waste excluded from hazardous waste regula>ons? The EPA grants specific exclusions and variances from some hazardous waste regula2ons if certain condi2ons are met Some materials are excluded from the defini2on of solid waste, while some solid wastes are excluded from the defini2on of hazardous waste Applying these exclusions to your waste classifica2on process can be an integral part of your waste management programs hip://

14 Hazardous Waste Determina2on Is the solid waste considered a hazardous waste? If the waste is not excluded, then you must determine if the waste: Meets one or more of the hazardous waste lis2ng descrip2ons found in 40 CFR 261 or Exhibits any of the characteris2cs of a hazardous waste: ignitability, corrosivity, reac2vity or toxicity

15 Hazardous Waste Determina2on Listed RCRA Hazardous Wastes F listed waste wastes from non- specific industrial processes, such as spent solvents used for cleaning or degreasing; K listed waste wastes that are from specific industry sources, such as certain petroleum refining wastes and veterinary pharmaceu2cals; P listed waste unused, acutely hazardous commercial chemical products, such as aldrin, a chemical used as an agricultural insec2cide; U listed waste unused, commercial chemical products, such as DDT and formaldehyde. The defini2ons and determina2ons for these lis2ngs can be found in 40 CFR through

16 Hazardous Waste Determina2on RCRA Hazardous Characteris>c Wastes Ignitability: liquids < 140 F, solids ignite by fric2on (D001) Corrosivity: ph <2 or >12.5 (D002) Reac2vity: unstable, water- reac2ve, contain cyanides, explosive (D003) Toxicity: liquid wastes which contain, and solid waste which leach out threshold or higher concentra2ons of metals, organics, pes2cides (D004- D043)

17 Hazardous Waste Determina2on Waste Classifica>on 3 ways to determine if your waste has these characteris2cs listed above based on 1. Test a Sample 2. Use own Exper2se (based upon the raw materials you used) 3. SDS

18 Non- RCRA Hazardous Waste A hazardous waste is a non- RCRA hazardous waste if it meets all of the following criteria 1. It does not exhibit any of the characteris2cs of ignitability, corrosivity, reac2vity, or toxicity 2. It is not listed as a hazardous waste, or is listed and has been excluded by the federal regula2ons 3. It is listed and is not iden2fied as a RCRA hazardous waste 1. Examples: Waste Oil, An2freeze, and Asbestos Any waste that does not meet the defini2on of a hazardous waste by RCRA standards, but s2ll a hazardous chemical, is a non- RCRA hazardous waste

19 Universal Waste EPA's universal waste regula2ons streamline hazardous waste management standards for federally designated "universal wastes," which include: baieries pes2cides mercury- containing equipment and bulbs (lamps). Regula2ons govern the collec2on and management of these widely generated wastes, to Facilitate environmentally sound collec2on and proper recycling or treatment Ease regulatory burden on retail stores and others that wish to collect these wastes Encourage development of municipal and commercial programs (reduce quan2ty of wastes) Ensure the wastes subject to this system will go to appropriate treatment or recycling The federal universal waste regula2ons are set forth in 40 CFR part 273. States can modify the universal waste rule and add addi2onal universal waste(s) in individual state regula2ons so check with your state for the exact regula2ons that apply.

20 Pharmaceu2cal Waste Creams, Pastes, Ointments Eye Drops Inhalers IV bags & tubing Nebulizer containers Syringes (sharps) Vials Powders PPEs and absorbents used to clean up pharm spills Tablets and Pills Test Strips Sprays (e.g. throat, nasal)

21 Hazardous Waste Determina2on State Authoriza>on (40CFR Part 271) State programs have the op2on to be more stringent than the Federal Standards, and many do EPA is authorized to accompany state inspectors to ensure the adequacy of the state program 2008, 3E Company, All Rights Reserved

22 State Requirements

23 Generator Status Determina2on EPA Iden>fica>on Numbers: 40 CFR Part EPA Iden2fica2on Numbers Small and Large Quan2ty generators must not treat, store, dispose of, transport, or offer for transporta2on of hazardous waste without having received an EPA iden2fica2on number from the state, federal or other administrators See State Requirements for CESQG Federal Generator Status Categoriza2on Condi2onally Exempt Small Quan2ty Generator (CESQG) Small Quan2ty Generator (SQG) Large Quan2ty Generator (LQG)

24 Generator Status Determina2on Condi>onally Exempt Small Quan>ty Generator (CESQG) 40 CFR Part Generates less than 100 kg of hazardous waste in any calendar month Generates less than 1 kg of acutely hazardous waste (P- listed) in any calendar month Accumulates less than 1,000 kg of hazardous waste Accumula2on 2me limit of 90 days begins at accumula2on of 1,000 kg

25 Generator Status Determina2on Small Quan>ty Generator (SQG) 40 CFR Generates more than 100 kg but less than 1000kg of hazardous waste in any calendar month Generates less than 1 kg of acutely hazardous waste (P- listed) in any calendar month Accumulates up to 6,000 kg of hazardous waste Accumulates waste on- site for no more than 180 days, or 270 if waste is being shipped more than 200 miles

26 Generator Status Determina2on Large Quan>ty Generator (LQG) 40 CFR Most stringent requirements Generates more then 1000 kg of hazardous waste in any calendar month Generates or accumulates more than 1 kg of acutely hazardous waste (P- listed) in any calendar month Accumulates hazardous waste on- site for no more than 90 days

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28 Hazardous Waste Handling Personal Protec2ve Equipment (PPE) Protec2ve equipment shall be provided, used, and maintained in a sanitary and reliable condi2on wherever it is necessary. This includes personal protec2ve equipment for eyes, face, head, and extremi2es, protec2ve clothing, respiratory devices, and protec2ve shields and barriers. The hazards of the processes, environment, or situa2on should be considered when determining the level of PPE. Four levels of PPE, Level A, B, C, and D

29 Hazardous Waste Handling Levels of Personal Protec>ve Equipment Level A: To be selected when the greatest level of skin, respiratory, and eye protec2on is required. Level B: The highest level of respiratory protec2on is necessary but a lesser level of skin protec2on is needed. Level C: Required when the concentra2on and type of airborne substances is known and the criteria for using air purifying respirators is met. Level D: A work uniform affording minimal protec2on: used for nuisance contamina2on only.

30 Hazardous Waste Storage Establishing a Hazardous Waste Storage Area: Not exposed to the elements (rain and snow) Located on an impervious surface (concrete) Away from vehicular traffic, sewer drains, storm drains and property boundaries Clear signage iden2fying the area. Adequate space for proper accumula2on and segrega2on Secured from unauthorized entry. Presence of fire ex2nguishing agent(s), and emergency response equipment (spill kits)

31 Hazardous Waste Storage Storage Containers: Containers must be in good condi2on and compa2ble with the hazardous waste being stored Must be inspected weekly (SQG and LQG) Must be marked with words Hazardous Waste Must be marked with accumula2on start date

32 Hazardous Waste Storage Labeling: It is recommended to label all Hazardous Waste Containers with the following minimum informa2on: Generator Iden2fica2on Container Contents Informa2on on the Hazardous Waste Characteris2cs Waste Accumula2on Start Date *States may require addi4onal informa4on on the label. Please reference your State regula4ons for any addi4onal informa4on.

33 Hazardous Waste Storage

34 Hazardous Waste Storage Dangers of Incompa>ble Hazardous Wastes Many hazardous wastes, when mixed together with other hazardous waste, can produce effects which are harmful to human health and the environment, such as: 1.) Heat or pressure 2.) Fire or explosion 3.) Violent reac2on 4.) Toxic dusts, mists, fumes, or gases 5.) Flammable fumes or gases. Some examples, include: Corrosive acids with corrosive bases Reac2ve metals (Sodium, Potassium) with either corrosive acid, corrosive base, alcohol, or water

35 Vendor Management Hazardous Waste Disposal To consider when disposing of waste: Cost End Disposal Op2ons Organizing Policies (Green Ini2a2ves) Reducing Waste Hazardous Waste Transporters Key points to consider when making a selec>on Qualifica2ons Reliability/Safety Cost Effec2veness

36 Vendor Management Statement of Qualifica>ons Company history and experience Have the contractor supply copies of current licenses, permits, registra2ons, and compliance records Know where the wastes go, specify appropriate Hazardous Waste Treatment, Storage, and Disposal Facili2es (TSDF) How is it being disposed of Geographical areas covered Lis2ng of loca2ons and 24- hour contact numbers Customer References regarding data keeping and record keeping

37 Vendor Management Insurance Requirements Require Vendors contractors meet minimum standards of insurance coverage: Worker s Compensa2on Employers Liability Commercial General Liability Automobile Liability Contractor s Pollu2on Liability Professional Errors and Omissions Liability Maintain Copies of Insurance Cer2ficates

38 Data & Document Management EPA ID# and Generator Status Uniform Hazardous Waste Manifest (cradle to grave management system) 3 Year Reten2on Requirement Excep2on Repor2ng Consider Electronic Reten2on Op2ons Land Disposal Record (LDR) Waste Profiles

39 Data & Document Management Waste Data & Analysis Using data to facilitate filing of generator reports Monitoring changes to generator status and poten2al impact on waste management programs that have been implemented

40 Data & Document Management Waste Data & Analysis Using data to develop effec2ve waste minimiza2on strategies by looking at waste streams and disposal methods over 2me Benchmarking data to compare to performance of other facili2es Using data to help demonstrate effec2ve cost management implica2ons and jus2fica2on for EH&S ini2a2ves

41 Data & Document Management 40 CFR Recordkeeping Requirements All records for the following must be keep for a minimum of 3 years.* Manifests - A generator must keep a copy of each manifest signed in accordance with (a) for 3 years or un2l a signed copy is received from the designated facility which received the waste. This signed copy must be retained as a record for at least 3 years from the date the waste was accepted by the ini2al transporter. Reports A generator must keep a copy of each Biennial Report and Excep2on Report for a period of at least 3 years from the due date of the report. Tes2ng/Analysis - A generator must keep records of any test results, waste analyses, or other determina2ons made in accordance with for at least 3 years from the date that the waste was last sent to on- site or off- site treatment, storage, or disposal. *The periods or reten$on referred to in this sec$on are extended automa$cally during the course of any unresolved enforcement ac$on regarding the regulated ac$vity or as requested by the Administrator.

42 Data & Document Management Other Notable Documents with Requirements: The following regula2ons either require or infer the maintenance of records by generators of hazardous waste include: 40 CFR : Training 40 CFR & : Inspec2ons 40 CFR 268.7: Land disposal restric2ons (LDR) 40 CFR : Con2ngency Plan (LQG) 40 CFR : Repor2ng Most of the men4oned records must be maintained for at least 3 years, or longer, if required by your respec4ve State regula4ons.

43 Data & Document Management Con>ngency Plan Descrip2on of ac2ons taken by facility personnel in the event of any unplanned release of hazardous materials Appropriate responding Police, fire, and hospital arrangements made on the approved ac2ons Contact list home and office phone numbers of EC s Emergency equipment list and where it s kept Evacua2on plan

44 Data & Document Management Con>ngency Plan will be: Reviewed and Updated immediately when there are changes to: Regula2ons Phone numbers & addresses Equipment Emergency coordinators Or the building process, construc2on or opera2on that may either increase the possibility of a release or affect the response to a release

45 Data & Document Management Emergency Coordinators (EC) Must be one available at all 2mes to respond in case of an emergency. Must be thoroughly familiar with hazardous waste facili2es ac2vi2es and opera2ons, con2ngency plans, loca2on and characteris2c of waste, and loca2on of records. Iden2fy (nature, source, amount of released materials, possess possible hazards to human health and environment) Home addresses now being requested.

46 Data & Document Management Biennial Hazardous Waste Report: Required by U.S. EPA for Large- Quan2ty Generators (LQG) Completed on Form A Due March 1 of every even- numbered year Waste reported covers the en2re period of the previous repor2ng year (i.e. 1/1/ /31/2014 reported by 3/1/2015)

47 Data & Document Management Annual Hazardous Waste Repor>ng: May be required by certain state agencies, regardless of waste generator status State agencies may charge an annual repor2ng fee that can be based on amount of waste generated or, possibly, based on waste generator status State agency may require addi2onal repor2ng submiial in addi2on to the EPA Biennial Report

48 Data & Document Management SITES THAT SHOULD NOT FILE THE BIENNIAL HAZARDOUS WASTE REPORT Do not file the Hazardous Waste Report if, during the repor2ng year, your site was not a RCRA Large Quan2ty Generator (your site did not meet any of the LQG criteria) and your site did not treat, store, or dispose of RCRA hazardous wastes on- site in waste management units subject to a RCRA opera2ng permit. Excep2on: File the report if your State has more stringent repor2ng requirements. If you are not required to report, you should no2fy the EPA if your hazardous waste generator status has changed; please fill out the RCRA Sub2tle C Site Iden2fica2on Form (EPA FORM ) and submit it to your State Office. STATE- SPECIFIC REQUIREMENTS States may impose repor2ng requirements above and beyond the Federal requirements. If your State does so, it will aiach informa2on to (or delete informa2on from) the EPA Hazardous Waste Repor2ng Instruc2ons Booklet. Alterna2vely, some States use a modified version of the EPA report or their own instruc2ons and forms to fulfill their repor2ng requirements.

49 Data & Document Management BIENNIAL REPORT 40 CFR (a) A generator who ships any hazardous waste off- site to a treatment, storage or disposal facility within the United States must prepare and submit a single copy of a Biennial Report to the Regional Administrator by March 1 of each even numbered year. The Biennial Report must be submiied on EPA Form A, must cover generator ac2vi2es during the previous year, and must include the following informa2on: (1) The EPA iden2fica2on number, name, and address of the generator; (2) The calendar year covered by the report; (3) The EPA iden2fica2on number, name, and address for each off- site treatment, storage, or disposal facility in the United States to which waste was shipped during the year; (4) The name and EPA iden2fica2on number of each transporter used during the repor2ng year for shipments to treatment, storage or disposal facility within the United States; (5) A descrip2on, EPA hazardous waste number (from 40 CFR part 261, subpart C or D), DOT hazard class, and quan2ty of each hazardous waste shipped off- site for shipments to a treatment, storage or disposal facility within the United States. This informa2on must be listed by EPA iden2fica2on number of each such off- site facility to which waste was shipped. (6) A descrip2on of the efforts undertaken during the year to reduce the volume and toxicity of waste generated. (7) A descrip2on of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years to the extent such informa2on is available for years prior to (8) The cer2fica2on signed by the generator or authorized representa2ve. (b) Any generator who treats, stores, or disposes of hazardous waste on- site must submit a biennial report covering those wastes in accordance with the provisions of 40 CFR parts 270, 264, 265, 266, and 267. Repor2ng for exports of hazardous waste is not required on the Biennial Report form. A separate annual report requirement is set forth at 40 CFR

50 Common Violations Not safely segregating incompatibles Storing hazardous waste beyond the authorized time limits Failure to have a contingency plan or failure to keep it up-to-date Failure to mark the words hazardous waste on containers Failure to inspect containers Failure to close and secure containers

51 Common Violations $$ The Prosecutor s Hit List $$ Previous violators Chronic violators Violators who cause significant adverse impact Willful and repeat violators Violators who cannot achieve compliance within restrictive deadlines Industry trends

52 Common Violations The Inspector s Checklist List " Hazardous waste storage areas " Claims return areas " Used spill absorbent material " Grounds, maintenance and janitorial areas " Universal waste " Pharmaceutical waste " E-waste " Record keeping and documentation

53 Common Violations Most common hazardous waste viola>on: Failure to determine which wastes are hazardous Lack of documenta2on 40 CFR Sec>on Hazardous Waste Determina>on A person who generates a solid waste, must determine if that waste is a hazardous waste

54 Classified Waste Can be integrated with exis2ng hazardous waste programs and systems

55 Classified Waste Can be easily separated from incompa2ble materials Corrosive Ignitable Toxic Reactive

56 Classified Waste Can be stored and labeled properly

57 Classified Waste Can be routed & disposed of properly

58 Behavioral and Cultural Obstacles Employee Level Affec2ng behavioral changes from managing waste at home vs. waste in the workplace Recognizing the shi in responsibility and risk Management Level Understanding poten2al adverse impacts (financially environmentally, to worker safety, and to the brand) Suppor2ng standard repeatable process vs. tribal knowledge

59 Q &A Ques2on: Is there a Right way or a wrong way to manage hazardous waste informa2on? Answer: There are a host of methods available to manage this informa2on in the right way effec2vely in order to maintain safety and compliance.

60 Ques2ons? Mike Ryan Product Manager, 3E Technical Services Office: