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As a generator of HSM, you ultimately decide whether the material is safely managed. The decision to send your HSMs to an off-site recycling business should be followed by a careful review of the qualifications of available recyclers.
Improper management can increase liability of the originating company (remember RCRA’s “cradle-to-grave” mandate). Environmental managers investigating recycling opportunities should consider the following tips when choosing an HSM recycler.
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- Learn all you can about the business.
The recycler should be able to give you a general description of the business, including a point of contact, number of employees, years in business and ownership history, site information and history, summary of operations, and services offered. In addition, the recycler should provide the facility’s record of compliance with federal and state environmental and safety regulations.
- Understand the recycling process.
Make sure you have an understanding of recycling processes in general and query the particular recycler you are considering as to their processes. For instance, does the recycler normally accept the materials you want recycled and does the recycler track the material through its processes? The recycler should be able to describe the processes and procedures for recycling, reuse, or resale. The recycler should also have environmental and safety management systems in place to ensure sound management practices.
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- Find out what happens in the aftermath.
The recycler should be able to answer questions about what happens to your HSM after the process at the facility. Ask if there is a reliable market for the saleable products. Are any residuals from the recycling process managed in a manner that is protective of human health and the environment? Can the recycler provide names and locations of businesses, landfills, or incinerators to which it sends products and/or residuals? Can the recycler supply certification of the final disposition of your materials? Does the recycler maintain appropriate environmental liability insurance, and are mechanisms in place to ensure cleanup costs would be covered if the facility unexpectedly closes or has to perform an environmental cleanup?
- Make a visit.
You can learn a lot about a recycler by visiting the facility and getting a tour. And, obtaining references should be part of any business transaction of this type.