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The determined effort to identify and control the types of wastes that are generated by an industrial process. To have a comprehensive understanding of all the different types of wastes generated at a site and to ensure the proper handling, storage and disposal of these wastes.

Hazardous Waste Management

The management of hazardous waste is a detail-laden adventure. Having been providing this service for years to generators from East to West, we can come to your facility and develop a comprehensive HWMP that will cover all your RCRA regulated activities. Once a substantial program is developed, then the routine of day-to-day operations becomes the focus.

Program Development

We can work with you to develop a full-scope program for the safety, security, handling and management of the hazardous waste generated at your facility. The basic elements of such a program are:

Identification

Ensuring that all hazardous wastes are cataloged and the processes they are used in are recognized. This will allow us to capture and identify all potential waste streams and classify them in a general sense.

Characterization

By applying generator knowledge and laboratory analysis, the wastes can be characterized according to the DOT hazard class and RCRA characteristics. Wastes that are RCRA regulated (hazardous wastes, waste oils and universal wastes) are subject to specific management standards and non-RCRA wastes are not subject to those standards. This step is fundamental in the proper management of your waste. Every other step of the process is based on an accurate characterization of the waste.

Handling Methods

The processes that your chemicals or products are used in is very important in the identification of the properties and the regulatory status of the wastes generated. To standardize the character of the waste it is important to manage the processes so the waste is consistent as possible. Developing Standardized Operating Procedures will accomplish this and they can also reduce the likelihood of accidents, help to maintain costs, and show inspectors that you take the waste management function seriously.

Satellite Storage

Many waste generators operate "Satellite Accumulation Points", but they are not operated in accordance with the regulations. Inspectors will almost always spend time on any SAPs that you have because they are soft targets. Making sure that your SAPs are in order will show the inspectors that you are fully aware of the regulations and you are on top of your game.

Packaging, Marking and Labeling

The DOT regulates the way that hazardous wastes are packaged for transportation. The packaging and labeling requirements for hazardous waste will vary with the classification of the waste. Proper packaging is essential because it provides for safe movement of the waste over the road and that package is what the world will see when the waste leaves your possession. Having already characterized your wastes, now you can select the proper packaging and ensure that you have taken all possible precautions to prevent spills and mark the packages properly to communicate the hazards of the material in transportation.

Transportation

Selection of a qualified and responsible transportation company will be effective in the safe movement of your wastes. Once the waste leaves your facility, the transporter assumes some of the responsibility in the event of a spill, but you are never completely free of liability.

Disposal

The final disposition of your hazardous waste is where your final liability will be resting. Using the most reliable and secure disposal facility is of the highest importance because there is a clear trail of possession for the waste. If the disposal facility ever closes and your waste is not properly handled, the paper trail will lead right back to your front door.

Waste Storage

There are several criteria for the area that you use to store your hazardous waste. Depending upon your generator status (CESQG, small quantity or large quantity generator), there are requirements for labeling, signage, physical condition, security, communication, etc. This is another area where inspectors will take a close look at your operation and if you can show them a well-run storage area, they will know that you know your responsibilities.

Documentation

The decisions that you make regarding the handling of your waste must be fully documented. This will allow you to present regulators or inspectors with the information they need to determine that you are in compliance. A clear package of documentation presented to an inspector will show them that you have put considerable effort to produce and maintain your hazardous waste management program.

Training

From a liability standpoint, the disposal of the waste pales in comparison to the potential for harm to your employees from the improper handling of hazardous waste. Your most effective tool against this liability is effective training. Providing training to your workers that communicates the importance of safety and compliance without making them afraid will reduce the potential for accidents and increase the confidence of your employees. In addition, there are training requirements for many aspects of your hazardous waste operation and these must be documented to the satisfaction of any inspectors.

Waste Minimization

One of your primary focuses should be on ways to reduce the amount of hazardous waste you generate. At Jasper Compliance Services, we have an eye for finding ways to minimize the waste volume by careful observation of the material handling techniques.

Orphaned Waste

Hazardous wastes that are discovered and for which there is no information presents some considerable difficulties. The discovery of a hazardous waste will require several actions to quickly determine its character and to make disposal arrangements.