Waste management is inherent to manufacturing operations; however, compliance with waste management regulations may not be so inherent.
Helping manufacturers with waste services such as characterization & sampling, storage, transportation, and disposal, as well as permitting, training, and reporting has been a large part of what Tom Maher, P.G., a vice president in CEC’s Environmental Engineering and Sciences practice, has done throughout his career. CEC’s manufacturing clients operate in the metals; chemical and petrochemical; forest products/pulp and paper; and food, beverage, and agribusiness industries. The firm also serves machine shops, construction companies, and slag processors, among other clients.
“We interview the operations team and perform a walk-through of each waste generation and storage area to collect the information necessary to develop a custom waste management plan. If we partner with a new company that already has a plan in place, we conduct an audit and make sure their plan is accurate, comprehensive, and being implemented as designed,” Maher says. “We help correct portions of waste management activities that are not in compliance with federal, state, and local regulations.”
Proactive and Prepared
Maher notes that clients must be proactive in maintaining compliance rather than being reactive when an agency shows up for a facility inspection. “I have had numerous instances throughout my career when my first interaction with a facility was a call from their legal counsel to discuss a Notice of Violation (NOV) issued by an agency during a site inspection. In those cases, they are trying to understand the vast number of waste rules and regulations while responding to the NOV and staying focused on their core business. We help clients maintain compliance and be prepared for those unannounced site inspections, which makes the experience much less nerve-wracking.”
“It’s imperative to develop and maintain good working relationships with the various governmental agencies to understand their points of emphasis and to maintain open lines of communication to discuss interpretations of the applicable regulations and guidance documents.” This is especially important due to differences in waste management regulations from state to state.
Records and Reports
According to Maher, it all starts with appropriate characterization of the various waste streams. “USEPA requires the waste characterization process be documented in writing only for hazardous wastes. State-level regulations are often much more specific and often include requirements for characterization of non-hazardous waste.
Maher recommends keeping records for all steps in the waste characterization process, even if the waste is non-hazardous and regardless of whether state regulations require it. “The person who made the waste determination is often not on site during unannounced site inspections by regulators, and the regulators expect site personnel to be able to demonstrate why the way the wastes are being managed is appropriate while the inspection is occurring,” Maher says. “It is much more time-consuming and expensive to rebut allegations of waste mismanagement included in site inspection reports and NOVs than it is to have the documentation available on site for review by the regulator during the site inspection.”
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