Reviewing & Maintaining Your Hazardous Waste Profiles
Shipping routine waste streams has a habit of becoming just that -- routine. This isn’t always a good thing. Waste streams often change or are altered over time resulting in inefficient or incompliant processes. This change in waste stream profiles could occur when:
- You’re adding and eliminating chemical constituents to achieve a new outcome or product.
- 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.
For both cost and compliance reasons, it’s important to review your waste profiles and maintain accurate waste description.
To keep your profiles current you should hold an annual profile review. You can do this alone or with your waste vendor. Address the generation of each active profile on record. For a compliant and efficient hazardous waste management program, you should consider the following questions when profiling your waste.
Consider These Things When Updating Your Waste Profiles
- 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?
Keep Records of Your Waste Profiles
Some states are required by their regulatory bodies to submit specific documentation describing their waste generation and composition.
Keep a hard copy of these records and supporting analytics on hand in your facility. These will act as a record of all waste amendments and general activity. Compiling a binder with current/active profiles stored will also be a helpful reference.
The Cost of Inaccurate Waste Profiles
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. This could 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.