The Resource Conservation and Recovery Act (RCRA) mandates hazardous waste generators to appropriately manage their trash from the site of origin, known as the cradle, to the point of final annihilation, known as the grave. This obligation means that as a hazardous waste generator, you are liable for the waste you produce not only while it is on your premises, but also after it leaves for eventual disposal or destruction. This article will go over the cradle to grave hazardous waste and the many roles generators play in each.
The Cradle: The Point of Generation.
As a hazardous waste generator, you have a great deal of responsibility. Here are a handful to watch at the time of generation.
Waste Characterization: After producing waste material, the generator must properly characterize it and determine whether it is hazardous (40 CFR 262.11). This enables a generator to make appropriate judgments about the trash's final destination and helps to prevent improper disposal, such as hazardous waste being sent to a non-hazardous waste landfill.
Storage: While hazardous waste is stored on-site, the generator must manage it properly and adhere to all hazardous waste storage standards (40 CFR sections 260.10 and 262). The generator guarantees that waste material does not pose a risk to personnel, the community, or the environment by managing it properly.
Documentation: Hazardous waste generators must conduct weekly inspections of hazardous waste storage facilities. Documentation of these inspections, as well as completion of any necessary remedial actions, must be kept on-site as proof of regulatory compliance.
The Grave: The Point of Ultimate Destruction.
As a hazardous waste generator, simply because the garbage leaves your plant does not mean your responsibility ends. When a hazardous waste generator sends garbage off-site for final disposal, the generator is liable for the material both during transit and after it arrives at its destination.
Accidental Spills: If a hazardous material leak or release happens during transport to a disposal facility, the generator is responsible for cleaning up and disposing of it. As a result, DOT regulations require generators to include a 24-hour emergency number on their shipping manifests in the event of a spill. Many businesses meet this responsibility by engaging with a service that provides 24-hour answering and information.
Reputable TSDF: If a generator sends its trash to a hazardous waste Treatment, Storage, and Disposal Facility that does not adequately manage the waste, the generator may be held liable for mismanagement. As a result, a generator should take caution when selecting a TSDF to ensure that their waste is treated correctly and in a way that will not find them in issue with the EPA. Before shipping their garbage to a new facility, some companies will request a visit to the TSDF facility, ask for references, or look into EPA inspections and infractions. The Federal EPA and state hazardous waste regulatory bodies keep track of infractions that a TSDF has received, and little research can reveal whether or not the facility has had regulatory compliance concerns.
Documentation: You should always be able to document that you appropriately described and managed your trash, as well as that it was received by the TSDF. Maintaining all documentation necessary by federal and state standards is the most effective approach for a generator to demonstrate adequate cradle to grave hazardous waste management .
A Better Approach To Managing Hazardous Waste
As a hazardous waste generator, proper waste management, from cradle to grave, is critical to ensuring environmental regulatory compliance. Failure to do so could result in unexpected inspections, violations, and even large fines. However, with so much involved in hazardous waste management, it's easy for items to slip between the cracks, and facility managers need all the assistance they can get. A better approach to managing hazardous waste
As a hazardous waste generator, proper cradle to grave hazardous waste management, is critical to ensuring environmental regulatory compliance. Failure to do so could result in unexpected inspections, violations, and even large fines. However, with so much involved in hazardous waste management, it's easy for items to slip between the cracks, and facility managers need all the assistance they can get.
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