Environmental, Health & Safety Blog

Managing a waste program is complicated. With so many moving parts, keeping every project up to standard can seem impossible. If your organization is managing waste internally, make sure your team is following state and federal regulations to ensure compliance and avoid the five consequences of mismanaging hazardous waste listed below. 

On September 5, 2017, the U.S. Environmental Protection Agency awarded North Carolina Department of Environmental Quality (NCDEQ) for the third time in fiscal year 2017 with $1,018,260. This monetary award was given to NCDEQ to support their hazardous waste programs. Initially, the EPA awarded $1,352,976 to NCDEQ to support their hazardous waste-related environmental programs. I wanted to give you some perspective on two recent visits that my clients received from NCDEQ, and discuss how these visits can be a good thing and not something generators should be nervous about. If you would like to learn more about the specifics please click here.

The Resource Conservation and Recovery Act (RCRA) requires large quantity waste generators to submit a report every two years detailing their hazardous waste activities generated in the year prior. This is referred to as a Biennial Report or the National Biennial RCRA Hazardous Waste Report.

Managing a waste program is complicated. With so many moving parts, keeping every project up to standard can seem impossible. If your organization is managing waste internally, make sure your team is following state and federal regulations to ensure compliance and avoid the five consequences of mismanaging hazardous waste listed below. 

In the world of environmental health and safety, we are accustomed to constant change and fluctuation. Most of us at one point or another have been part of a company who has either expanded or moved spaces to accommodate changes in need for functional workspace. The expectation from leadership is to make these moves as economically and compliantly as possible.

This can make things very hectic as managing these transitions are often piled onto an already “at capacity” workload. One thing that typically falls to the bottom of the priority list during these changes is the Hazardous Waste program. Particularly the details around setting up an adequate Hazardous Waste room that will maintain program efficiency well beyond the initial installation. It’s often difficult to think “down the road” when so much emphasis on project based costs and timelines are driven by leadership. Taking the time to assess these 5 items will create long term program success and maximize efficiency. The pain/gain curve is well worth the initial effort and will keep from costly retroactive program adjustments and chronic inefficiencies.

Sodium azide (NaN3) is extremely toxic and potentially explosive under certain conditions. This azide compound is frequently used as a preservative in many reagents and stock solutions that are utilized in healthcare facilities. Here’s what you need to know about drain disposal of sodium azide as well as other solutions.

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.

As hazardous waste generators, we are all pretty familiar with the U.S. Environmental Protection Agency’s (EPA) biennial reporting requirements—even if they don’t directly apply to us. The hazardous waste export reporting requirements found in 40 CFR 262.56, however, are due on the same date and are much less familiar. 

Unless your hazardous waste is being transported from your facility to a TSDF outside the U.S., which is not usually the case, your hazardous waste transporter is generally deemed the “primary exporter” and is responsible for fulfilling all applicable federal requirements—like the annual export report.  Even though the waste generator is not responsible for submitting the reports or filing notifications with the EPA, they are responsible for their waste from “cradle-to-grave” and should be educated enough to know whether their hazardous waste transporter is complying with regulations.

What are the federal requirements for exporting hazardous waste?