Six key factors to consider during the change review process
- New hazardous waste generation: Changes in the manufacturing process may result in new hazardous waste streams, and it’s critical to determine if those new streams fall under RCRA regulations and how to manage them.
- Waste storage, treatment, and disposal: Modifications to the manufacturing process may result in changes to the volume or type of waste generated and affect the storage, treatment, and disposal procedures required. Therefore, generators must determine the quantity of waste likely to be created and re-characterize it to determine if waste codes have changed.
When evaluating a change, verify that the facility has the necessary permits and authorizations to store, treat, and dispose of the waste and that the waste handling procedures at the facility are in compliance with federal and state RCRA regulations. In addition, new vendors may also need to be secured to handle the waste.
- Transportation of waste: If the changes result in the need to transport waste to a different facility for treatment, reuse, or disposal, that transportation must comply with EPA and DOT regulations.
- Employee training: Anyone who handles hazardous waste must receive training on RCRA regulations and procedures, including contingency and emergency response procedures. In some cases, an increase in waste generation may even bring the facility into a different generator category, resulting in new, more stringent training requirements. Therefore, changes may warrant further training and communication with employees and contractors handling or working near the waste.
- Recordkeeping and documentation: RCRA regulations require detailed records of the generation, storage, treatment, and disposal of hazardous waste. For example, generators must maintain waste determination documentation for three years after sending waste to a Treatment, Storage, or Disposal Facility.
Changes in the manufacturing process may also result in changes to the required documentation or updating existing procedures. For example, required documentation may include a contingency plan or lead abatement procedures. Therefore, whenever generating a new waste, it should be verified that there is a plan in place to meet the recordkeeping requirements.
- Reduce, Reuse, Recycle: It is essential to consider all environmental regulations related to waste when making changes at a manufacturing facility and look for opportunities to reduce, reuse, and recycle. Doing so will help avoid potential penalties and ensure that there are no negative impacts on human health or the environment due to the change.
Waste Screening Checklist
The six tips above are essential to adequately managing change to waste generation at your manufacturing facility. In addition, the Waste Screening Checklist provided below can help you determine whether the change has waste impacts and needs further evaluation by an environmental professional.
| WASTE SCREENING CHECKLIST |
Yes |
No
|
| Does this change involve the generation of new waste sources, routine waste, or non-routine waste (e.g. excavation, exploratory digging, remediation, and/or soil borings)? |
✓ |
|
| Does this change impact a current wastestream and result in a change in the frequency/quantity of the generation of the waste and/or the composition of the waste? |
|
✓
|
| Does this change involve the disturbance or removal of asbestos or material that potentially contains lead (paint, surface coatings, etc.)? |
|
✓
|
| Does this change involve the modification, demolition, removal, and/or relocation of any equipment or buildings/structures (e.g. vessels, tanks, buildings, foundation, etc.)? |
|
✓
|
| Does the change add, modify, or remove equipment associated with hazardous waste tanks or Underground Injection Control wells? |
|
✓
|
| Does this change involve or require the use of a waste storage area (e.g. waste container storage building, satellite accumulation area, 90-day storage area)? |
✓ |
|
| Note: If the answer to any of the above screening questions is Yes, then a follow-up task for the environmental representative at the facility must be assigned to evaluate waste impacts and ensure regulatory compliance. |
Encamp can help
Staying ahead of change and how it may affect your facility’s hazardous waste generator status is vital to maintaining regulatory compliance. However, the process can sometimes feel daunting, and with so much on the line, there is no room for mistakes. Encamp can help.
Encamp solves the complexity of environmental compliance with high-tech solutions and high-touch expert support. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance. Click here to learn how Encamp can help create a more compliant workplace.
Crystal Kukic
As a Compliance Program Manager at Encamp, Crystal provides regulatory expertise and aids in the further development of the Encamp product. Prior to Encamp, she accrued over 8 years of technical experience at Marathon Petroleum Corporation while in multiple different workgroups including process engineering, process controls, environmental services, and process safety. As an Environmental Professional, she led a variety of air programs and spent a great deal of time on work to revamp existing systems and processes to significantly improve site compliance. She enjoys studying the regulations and finding creative ways to ensure compliance in an efficient manner. Crystal is a graduate of Wayne State University, where she earned her B.S. in Chemical Engineering.
