Reviewing and Maintaining Your Hazardous Waste Profiles
Posted on Tue, Feb 16, 2010 @ 09:52 AM
By Amanda Mendonza, Technical Services Representative
Shipping routine waste streams has a habit of becoming just that...routine. However, many lab experiments and industrial processes change frequently. This could mean adding and eliminating chemical constituents to achieve a new outcome or product. It's possible the manufacturing line or HPLC the waste comes off of is the same, so the name of the waste or the generation might not change. This does not necessarily mean the waste composition has remained the same. It is very important to review your waste profiles and maintain accurate waste description.
You can keep your profiles current by holding an annual profile review where either you alone or you and your waste vendor address the generation of each active profile on record. If you are a Connecticut facility then you are actually required by your state to submit specific documentation describing your waste generation and composition. It is very important to keep on record all of your hard copy profile forms and any supporting analytical. These will act as an eternal record of all waste amendments or general activity. Compiling a binder with current/active profiles stored toward the front or in a completely separate binder from legacy profile information will be most efficient for referencing.
When completing your profile review here are some questions to keep in mind:
• Is the profile active (meaning is the generating process still in operation)?
• Has the generation process been altered since the last review/initial generation?
• Have any new chemical constituents been added? Have any been removed or replaced?
• Will any RCRA codes need to be added or removed?
• Will analytical be required to compile and accurate waste profile?
• Have the above amendments altered the shipping information?
• Should the profile be amended or inactivated and recreated?
Maintaining current and accurate waste profiles is a measure in safety as well as a cost-efficient practice. Per your hazardous communication to your employees, you want to make sure you are making all workers aware of all potential hazards at any given moment. This is difficult to achieve if you are not consistently reviewing your waste streams. Inaccurate profiles will also increase costs when disposal facilities discover changes to waste compositions for you. This leads to off-specifications and full waste rejections which will in turn result in additional shipping and processing fees. Keeping your waste profiles current and accurate is an important part of running a successful environmental management system.