Hazardous waste treatment, storage, and disposal facilities (TSDFs) are required to not only obtain but also maintain their operating permits. Generators of hazardous waste are required to ensure that their hazardous waste is sent to a reputable TSDF. So, it is critical that generators know whether the permit at the TSDF they use is up to snuff. Yesterday we reviewed requirements for updating hazardous waste permits. Today we offer tips for generators when choosing a TSDF.
|
Certain operational changes at your facility mean that you will become a hazardous waste generator. Or, you want a TSDF that offers more services than your current one. Or, you have come to realize that the TSDF you have been working with is not in compliance. These are some of the reasons you may be in the market for a hazardous waste facility.
Given RCRA’s “cradle-to-grave” provision, hazardous waste generators are responsible for their waste even after they hand it over to a transporter or a TSDF. Both the transporter and the TSDF must have permits and be in compliance with their respective state or federal regulations. What can you do to ensure that the transporter and/or TSDF you contract with is reliable and reputable?
Here are some tips when shopping for a hazardous waste transporter and/or a TSDF.
Tip 1. Obtain references from business colleagues who have used a specific transporter or TSDF.
Tip 2. Check trade associations for your industry. Some of them may keep files on companies that handle hazardous waste.
Tip 3. Check the Better Business Bureau in your area. It might have records of any complaints registered against a transporter or a TSDF.
Tip 4. Contact the U.S. Environmental Protection Agency (EPA) or your state agency to see if a transporter or TSDF has an EPA ID number or a permit.
Tip 5. Check federal and state online compliance databases, such as EPA’s ECHO, for a company’s compliance history.
Tip 6. Ask for copies of permits from any TSDF and their contractors. Make sure they are permitted to handle your specific waste.
Are you not sure of your hazardous waste responsibilities? Enviro.BLR.com® has hundreds of guidance documents, tips, and training materials to help you in your hazardous waste compliance efforts.
This list of Tips did not include 2 of the most important things to look at when selecting a TSDF. The first is conducting a site visit or audit to see what site operations are like. I’ve been to facilities that were “in compliance”, but when I visited them, for the life of me, I didn’t understand how. The second is insurance including environmental liability. This is your protection from financial liability should the company do something wrong with your or another customers waste. Also, get the declaration page of the policies. An insurance policy with $10 million in liability insurance looks good until you see that $9 million is the deductible that the TSDF will need to cover.