Changing existing processes or adding new equipment or chemicals often creates new waste sources and alters the amount of waste generated. That's why a thorough change review and its waste impact is essential to maintaining site compliance with Resource Conservation and Recovery Act (RCRA) environmental regulations.
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||
|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.|
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.
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.