“… and there are several drums around back that we want you to pick up as well.”
“What’s in them?”
“I’m not sure. The drums have been re-purposed and they’re not labeled. At least one has some kind of green sludge leaking out of it and the boss says they need to go.”
Because we are in the Waste Management business, we expect to see the “ugly” side of business and production environments. Our job is to clear your production facilities and work sites of waste and debris for the health and safety of your employees and to maintain a clean environment as well. In the course of our day-to-day operations, we deal with all kinds of waste materials—including hazardous waste. The Environmental Protection Agency (EPA) strictly regulates all aspects for dealing with hazardous waste, whether you are the hazardous waste generator, transporter or the disposal site.
As a generator of hazardous waste, you are well aware of the fines and penalties the EPA can impose if your company is found to be in violation of hazardous waste collection and disposal. You may know from your own experience that when an EPA inspector comes on site, your hazardous waste site is probably at the top of the list for inspection.
Is your company ready? Or will your inspector find violations? Read on for some recommended Best Management Practices (BMP) for Hazardous Waste Containers. By following these guidelines, you’ll help us to better help you in maintaining a safer and cleaner work environment. And, you’ll be confident your hazardous waste containers and storage area will be ready for your next EPA inspection.
- Keep your hazardous waste storage containers in good condition. These should be free of dents, bulges, and corrosion, as well as structurally sound. Consider the volume of waste generated and choose a suitable size container for temporary storage.
- Ensure your waste won’t react with the container itself. Consult a corrosion resistance guide to determine if the container and waste are compatible.
- Maintain written procedures for managing filled hazardous waste containers.
- Keep containers closed at all times, unless you are adding or removing waste from the container.
- Label each hazardous waste container with the words “HAZARDOUS WASTE” and identify the contents and the date the container was completely filled. Store these containers with the labels clearly displayed.
- Ensure hazardous wastes are not stored on-site for more than 90 days without a permit. The clock starts when the hazardous container is full. (This is the most common problem found by the EPA: hazardous waste generators failure to meet permit exemption requirements for the temporary storage of hazardous wastes on site.)
- Maintain appropriate distances between incompatible wastes. Ignitable and/or reactive wastes should not be stored within 50 feet of your property line and they must be managed to preclude fire or explosions. “NO SMOKING” signs must be posted at all areas near ignitable or reactive wastes.
- Don’t push, roll or drag hazardous waste containers. Use the proper equipment for transport and leave sufficient space between containers to allow for inspection as well as pedestrian or vehicle access.
- Store hazardous waste containers within a containment area—such as dikes, berms or walls—to provide containment in case of leaks or rupture.
- Inspect your container storage areas weekly, using a standard checklist to document each inspection and save a copy of each inspection in a notebook. Train your inspectors to look for leaks, container conditions, proper labeling and accessibility. Make detailed notes on the checklist of any problems noted and the corrective action taken.
If you are a client and have questions about any of the waste produced by your company, let us know. Our Total Waste Management Program is designed to work with you for the proper handling and disposal of all the waste materials generated by your company. Pinnacle Environmental Services can help with on-site training for your management and production staff to ensure compliance with all regulations. If you are not a client, contact us for an on-site Waste Analysis Study. Our highly-trained analysts will talk with your management team and production staff to understand your specific needs, then develop a cost-effective, customized waste management plan for you.