Federal hazardous waste regulations changes in 2017 and 2019 under the Resource Conservation and Recovery Act (RCRA) have increased regulatory oversight and scrutiny of “non-industrial” business sectors such as hospitals; healthcare-related businesses like pharmacies and laboratories; retailers; and academic institutions. These sectors and their environmental impact have been historically overlooked when discussing RCRA compliance, but accompanying increased regulatory attention is an increase in the environmental risks these business sectors are facing. This translates to new challenges in unfamiliar territory for many businesses.
Since nearly every facility within these sectors is a hazardous waste generator, business and facility leaders must understand the complex environmental compliance requirements their business and properties are subject to. Understanding these requirements while implementing a compliant waste management system is a mammoth task given the hundreds, if not thousands, of wastes and waste streams generated by these entities annually. These facilities, which for many companies are spread across the country, are also subject to state and sometimes local hazardous waste regulations which are often more stringent than federal RCRA rules.
Key Processes Towards Compliance
Before even approaching the meat and bones of compliance, there are two major initial components to address. Step number 1A in minimizing the environmental, legal, financial, and other inherent risks in being a hazardous waste generator is knowing and applying regulations and the corresponding hazardous waste program compliance requirements. Step number 1B is completing an accurate and up-to-date waste inventory to determine the actual hazardous waste compliance requirements that apply to your operations. From this point on, the hazardous waste notification; segregation; collection; storage; training; spill response; manifesting; disposal; and reporting (if required) practices and procedures are developed and implemented so that your facility can adhere to your specific regulatory compliance requirements.
Organizational Deficiencies and Systemic Blindspots
Given the complexity of RCRA regulations and the nature of these non-industrial sectors, business leaders in the hospital, healthcare, educational and retail industries may lack the internal institutional experience to adequately meet regulatory compliance requirements related to RCRA. And, unfortunately, systemic or acute compliance issues may only be uncovered during a government agency compliance inspection or a waste or chemical management incident. When either of these scenarios occurs, it is commonly found that no single person or business department was responsible for the RCRA hazardous waste program.
Practical Compliance Steps for a Zero Violation Program
To avoid situations like this — which sometimes can trigger significant environmental risks such as unwelcome publicity — there are practical compliance assessment steps (at either facility, regional or company-wide levels) businesses in these sectors can proactively take to minimize the impacts of non-compliance with RCRA hazardous waste regulations.
What do these steps look like? Join environmental consultant Darrell Oman on September 24th for a webinar on comprehensive program management approaches for industrial and non-industrial sectors. Darrell has more than 30 years of consulting, program development, and risk management experience in the Environmental, Health and Safety (EH&S) field and is excited to share his insights in this live interactive webinar.