Do you profile your waste? Believe it or not, this is a high-priority task for many manufacturing companies. And, unfortunately, it is one environmental issue that commonly slips through the cracks. Profiling means to determine the characteristics of the waste, and determine whether it is hazardous waste or non-hazardous waste. Profiling can be done using the MSDS to inform the landfill what is in the waste or by using a laboratory to analyze the waste.
Many industrial waste streams are categorized and disposed of as non-hazardous waste. This is fine as long as the generator is diligently keeping up with the requirement to profile the waste stream at appropriate times. It is the responsibility of the generator to ensure that the waste is being disposed of properly. Many waste management companies are very helpful in helping the generator assure this, but it is ultimately the generator’s responsibility. In other words, if you placed your trust in a helpful hint or educated guess, the fault still falls back on you.
What’s more, once a waste is improperly disposed of, it is much too late to change course. This may result in fines at the very least, and in egregious cases, criminal prosecution. That is why it is essential to be proactive and stay on top of all waste streams at your facility.
What follows is an actual account of one customer that DECA Environmental recently engaged.
A manufacturer had been using the same paint for years, and disposing of non-hazardous filters with a nearby landfill. As is customary, the landfill required companies to profile their waste every three years. The manufacturer’s previous two samples had determined the waste to be non-hazardous. Why expect any different this time around?
But this year, the sample that was submitted was found to contain chromium (Cr) greater than the regulatory limit of 5 mg/l. After the results were received an immediate investigation was conducted to determine the source of the increased Cr. The manufacturer kept detailed records of the paint usage and subsequent emissions of VOCs and hazardous air pollutants (HAPs) as was required for compliance with their Air Permit.
DECA gathered purchase records from the paint supplier, and using their custom-built database software, determined the emissions. To date, no purchase records with new paints had been added to the source. However, the paint used to fill in sanded stainless steel parts was being used as a trial paint. Luckily, the filters were all still onsite and had not been disposed of in the non-hazardous landfill.
The potential issues if the filters were shipped off could have been very expensive. Let’s go down the trail: The manufacturer (generator) would have offered filters (hazardous waste) to a non-hazardous waste permitted transporter. The transporter would have then transported the waste to a non-hazardous waste permitted landfill. The waste would have been improperly characterized to determine if it is hazardous waste or not.
Furthermore, improper labeling would have been on the containers. There would have also been Land Disposal notification and proper manifesting requirements. All of these issues would have been indicated on the citation and subsequent Agreed Order. This would have lead to a fine from the Indiana Department of Environmental Management (IDEM) Office of Land Quality. A typical fine could be as high as $25,000 for this type of issue.
As a generator, what should you be paying attention to? The following is a short list:
- Process changes such as changes in material usage or production techniques
- Changes in maintenance procedures
- Increases in production
- Changes in the utilization of production equipment that produces waste
These are just a few examples. Having a laboratory analyze your waste can be costly and is not always necessary. If the generator can conclusively demonstrate that nothing in the process has changed which would have caused the waste material in question to become hazardous, they may see much lower analysis costs. The operative word, however, is conclusively.
Could you be at risk? The costs of ignorance may be more than you can afford. A quick call to DECA may be just what you need to find out what, if any, risks you might have looming and what you can do to mitigate them.
