Choosing a disposal firm
Assist in manifesting, waste sampling and analysis (if required), and offer a flexible pick-up schedule.
Have undergone a rigorous environmental audit from a third party.
Be financially stable.
Maintain adequate environmental insurance for accidental spills and long-term environmental liability.
Not be under any significant orders, actions or claims from government or individuals.
Have an environmental and safety program.
Provide you with spill, environmental and safety records.
As the generator, you have "cradle to grave" responsibility and liability for hazardous wastes. Because of the long-term financial risks, it is especially important to use good judgment in the selection of your waste service firm: Always deal with a firm that has an EPA ID number and has obtained the proper EPA permits. This does not limit your liability, however, and is not a guarantee that the firm is in compliance with state or federal rules. Consider an on-site visit and/or conduct an audit of the processing facility. If you can’t visit the final destination, visit the local transfer station. Consider using a full-service firm. This is not always possible, but dealing with one firm that transports and processes your wastes makes it easier to monitor and manage. Check with your state environmental agency to see if the firm has current or past problems. Are there any past or pending lawsuits or actions filed against the company? Check with your colleagues, industry and professional associations and other businesses or consultants for references or recommendations. Be cautious of unusually low pricing. It may cost more to use a more expensive firm but consider the cost difference in terms of environmental liability insurance. The firm you choose should:
Practice the three Rs
Do not mix non-hazardous wastes with hazardous wastes.
Do not mix other waste liquids with used oil. You may render the entire quantity of used oil a hazardous waste by doing so.
Avoid mixing several different hazardous wastes. This may also make recycling more difficult, if not impossible, and increase treatment/disposal costs.
Avoid leaks and spills. Clean-up materials may also be hazardous. Frequent leaks and spills are most likely caused by carelessness and can easily be reduced.
Make sure you empty all containers and aerosol cans prior to disposal.
Purchase only what you need.
Use the least hazardous substance for a particular job.
Take immediate action when a release or threatened release of a hazardous substance or waste is suspected or confirmed.
Wherever possible, recycle hazardous materials.
Implement a training program for employee environmental awareness.
The best waste management practice is to not produce the waste in the first place! Good housekeeping and common sense are the cornerstones to sound environmental management. Waste reduction is largely dependent upon these factors and the three Rs — Reduce, Reuse and Recycle. To practice the three Rs, keep the following in mind:
For more information
For further assistance in understanding hazardous waste regulations, contact your state environmental agency. Other resources include the EPA Resources Center, the RCRA Hotline at 800/424-9346 and your EPA regional office. In addition, your waste management firm may provide information on training, written reference material and other assistance. This article is not intended as legal or professional advice. Neither the author, Laidlaw Transit Inc., nor the publisher makes any warranty or representation expressed or implied with respect to the accuracy, completeness or utility of the information and shall not be held liable for any loss or injury.
Robert Yanchis is director of environmental affairs for Laidlaw Transit Inc. in Burlington, Ontario