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The Resource Conservation and Recovery Act (RCRA) requires hazardous waste generators to properly manage their waste from the point of generation, called the cradle, to the point of final destruction, referred to as the grave. This requirement means that as a hazardous waste generator, you are responsible for the waste you generate not only when it is on your site but also once it leaves your site for its final disposal or destruction.
This article will discuss both the cradle and the grave of hazardous waste and the different responsibilities that generators have in each.
As a hazardous waste generator, you carry a lot of responsibility. Here are a few to keep an eye on at the point of generation.
Waste Characterization: After generating a waste material, the generator must first appropriately characterize the waste and determine if it is hazardous (40 CFR 262.11). Doing so allows a generator to make appropriate decisions regarding the waste’s final destination and helps prevent improper disposal, like hazardous waste going to a non-hazardous waste landfill.
Storage: While the hazardous waste is stored on-site, the generator must adequately manage the waste material and follow all requirements for hazardous waste storage (40 CFR sections 260.10 and 262). Through proper management, the generator ensures that waste material doesn’t become a hazard to employees, the community, or the environment.
Documentation: Hazardous waste generators must complete weekly inspections of hazardous waste storage areas. Documentation of these inspections, and completion of any corrective actions required, must be maintained on-site as proof of compliance with the regulations.
As a hazardous waste generator, just because the waste leaves your facility doesn’t mean your responsibility is over. When a hazardous waste generator ships waste off-site for final disposal, the generator is responsible for that waste during transit and even after it reaches its final destination.
Accidental Spills: If an accidental spill or release of hazardous material occurs during transport to a disposal facility, the generator is responsible for the cleanup and disposal of material. As a result, DOT regulation requires a generator to provide a 24-hour emergency number on the shipping manifest in case of a spill. Many companies fulfill this obligation by contracting with a service that offers 24-hour answering and information.
Reputable TSDF: If a generator ships its waste to a hazardous waste Treatment, Storage, and Disposal Facility that is not managing the waste properly, the generator may be held responsible for mismanagement. Therefore, a generator should exercise caution when selecting a TSDF to ensure that their waste will be handled correctly and in a manner that won’t land them in trouble with the EPA.
Some companies will request a tour of the TSDF facility, ask for references, or research EPA inspections and violations before sending their waste to a new facility. The Federal EPA and State hazardous waste regulatory agencies maintain information about violations that a TSDF has received, and a little research would indicate if the facility has had issues with regulatory compliance.
Documentation: You should always be able to prove that you characterized and managed your waste correctly and that the TSDF received the waste. Maintaining all documentation required under Federal and State laws is a generator’s best way to prove proper cradle-to-grave management of hazardous waste.
As a hazardous waste generator, managing your waste correctly, from the cradle to the grave, is essential to maintaining environmental regulatory compliance. Failure to do so could land your organization with surprise inspections, violations, and potentially steep fines. However, with so much going into hazardous waste management, it’s easy for things to fall through the cracks and facility managers need all the help they can get.
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Jenn joined Encamp in 2022 with more than 15 years of environmental compliance experience. Prior to joining Encamp, she spent three years as the head of the Environmental Department for the City of Cleveland, Department of Public Utilities, where she managed a team of HazMat professionals and oversaw all aspects of environmental compliance for a large electric, water, and sewer utility. She also has experience as an EHS Manager in the chemical and biochemical sectors, and eight years of experience in Environmental Consulting. Jenn maintains certification as a Certified Hazardous Materials Manager (CHMM). She is passionate about protecting the environment, understanding complex environmental regulations, and helping companies achieve compliance with these regulations.
